The Scottish Government

« Previous | Contents | Next »

Listen

MODEL POLICIES IN LAND USE PLANNING IN SCOTLAND: A SCOPING STUDY

CHAPTER SIX MODEL POLICIES: THE PROCESS

INTRODUCTION

6.1 This chapter explores a number of options for taking model planning policies forward. Relatively few respondents to the Consultation Paper considered how to draft model policies. Not too much should be drawn from this, however, since the questions posed in the Consultation Paper did not specifically address this particular matter. A number of practical concerns were identified with respect to the drawing up of model policies. Cross-checking this evidence from the Digest with the discussions and comments made in the individual focus groups demonstrates that the thinking around the potential of model policies falls into two broad areas. First, a model policy may be considered in terms of a product (a set of words) which could form the basis of guidance or a suite of model policies. This was discussed in Chapter 5. Second, a model policy may be considered as part of a wider process of policy making. The emphasis is then upon identifying and sharing best practice.

6.2 This chapter focuses on the procedural aspects of policy making and their implications for best practice in policy making. It also highlights particular ways in which the Scottish Executive could act with respect to policy development and model planning policies. It considers policy drafting as one stage in the overall policy process. Model policies are thus examined in the context of the policy cycle. The chapter concludes with a collection of good practice guidance literature concerned with promoting a robust policy discipline. This is intended to add to an important resource bank for policy making.

WHAT ARE THE PRACTICAL CONCERNS TO BE ADDRESSED?

6.3 Chapter 3 set out the practical concerns of users and service providers as expressed in the Digest. It was confirmed during the focus groups that the difficulties in the exercise of drawing up national model policies should not be under estimated. Indeed, it was suggested that the processes involved might be 'tortuous' and unlikely to achieve a ready consensus among stakeholders. Further, there was a shared view amongst the focus group participants that developing model policies was likely to be difficult in practice and would likely need to be supported by specific technical expertise. Thus, whilst recognising the potential of model policies, a voluntary body in a focus group discussion noted that developing a suite of model policies might not be a swift exercise:

I'm not suggesting this can be done quickly or easily and also things that are quick and dirty don't have official sanction. This needs to be pulled together by professional institutions.

6.4 The time-consuming nature of drawing up model policies highlighted in the Digest was reiterated in the focus groups. Given that model policies are generally perceived as having potential as a national resource, participants were concerned about the likely implications for the Scottish Executive. Again, a professional body suggested that such an exercise would need to be outsourced and would likely draw on existing strengths in practice. Thus, for example, special interest groups might have a role to play. Indeed, it was clear at the focus groups that particular stakeholders are keen to be more involved.

BEST PRACTICE AND MODEL POLICIES

6.5 The distinction between best practice methods to policy making and model policies as model texts or exemplars is an important one. The relatively more sceptical views, for example, expressed by respondents to the Consultation Paper, and made during the focus group discussions, highlighted the wide-spread interest in securing improvements in planning practice. Here, however, it was considered that such things as guidelines, guidance, standards, and supplementary planning guidance represented a higher priority for many local planning authorities than the drawing up of model planning policies. A local authority view expressed at a focus group was that:

Clearer guidance from the Executive as to exactly what is required from local policies would in fact be a better option than model policies themselves.

The sharing of model texts of policies that work in practice is clearly not mutually exclusive from the sharing of best practice. Nonetheless, the processes involved in drawing up model policy examples, and writing best practice guidance are different. For example, the first may be linked to consultation procedures associated with the revision of national policy guidance. The second, in contrast, may require the commissioning of a specific project to draft and disseminate guidance on effective policy making. The latter example combines the work of special interest groups with a wider interest in the policy cycle and establishing a strong policy discipline.

6.6 To this end, discussions at the focus groups indicated that there is scope for model policies to be an integral part of the work currently being undertaken by the Scottish Executive in its restating and reworking of national policy guidance as national policy statements:

It is essential that model policies are based upon the national planning policy and should become an integral part of the review and publication of revised policy documents.

Two contrasting views emerged. From a developer perspective, it was suggested at the focus groups that there was no need for model policies to interpret national priorities precisely because national planning policy is intended to do this very job. Yet, other participants representing local planning authority and statutory agency views argued that national policy statements should be interpreted and incorporated as local plan policies, and that there was some scope for model policies to be shared. The view expressed was that it is the effective and consistent translation of national policy into local contexts across Scotland that is exercising local planning authorities and that indicative models of how policies are intended to work at the local level would be welcomed. Here, three options suggest themselves.

6.7 The first option suggested at the focus groups is that model policies could be attached to the relevant national policy statement. This would allow for a clear, consistent and certain assertion of the national priorities involved, and link local policies with the national statement. Moreover, this would also offer a vehicle for consultation. The defined and sector-specific character of national policy statements, however, may not cover all of the related policy issues on a pan-Scotland basis. In addition, as the environmental policy examples illustrated, local plan policies often derive their authority from several national policy statements. Moreover, the revised national policy planning series in hand is seeking to reduce and concentrate the content of the guidance. Adding model policies to the new statements may serve to detract from their message.

6.8 A second option suggested at the focus groups was that 'model policies could usefully be accompanied by a good practice guide'. Opportunely, it was suggested that the current approaches to the identification and dissemination of 'best practice' required overhauling to ensure that 'best' practice is based on clear and transparent principles.

You wonder also at the examples picked for the awards and inclusion in PANs. Are they just to look glossy and good? The Scottish Executive could do a lot more in providing clear examples.

This would suggest that attention needs to be paid to the criteria to be used in measuring quality, and also in allocating responsibility for identifying best practice. The process must be open, clear and transparent, based on an agreed understanding of what works. It was asserted, for example, at a focus group that:

The Royal Town Planning Institute has a Planning Committee to look at best practice - we should leave the Scottish Executive to look at policy and separate the Scottish Executive from looking at best practice.

Separating policy and best practice activities in this way could overcome the stated concerns in the Digest (and confirmed at the focus groups), with respect to model planning policies creating greater centralisation. It would also promote stronger partnership between the Scottish Executive and the different stakeholders in the planning community. Indeed, this would allow different actors to play to their strengths, and better contribute to a planning system that works.

6.9 The series of Planning Advice Notes which is intended to disseminate best practice was considered to be the appropriate location for model policies. It was argued at the focus groups that this would avoid cluttering the national policy statements, and allow for the effective interpretation of policy for local purposes. Further, it was suggested that there is scope in the PAN format to address cross-cutting issues where policy stems from a number of national policy priorities. The preparation of an additional PAN which simply addresses development control policies currently not covered by the national guidance, and which would set out model policies was also identified as serving a need.

6.10 The third option mentioned in the course of the scoping study was for the provision of guidance relating to more effective policy making. Reference was made, for example, at different focus groups to the work of the Planning Officers Society in England. This approach explicitly focuses on process, and addresses the necessary stages in policy making. In effect, it serves to provide a focus for best practice in policy writing, policy implementation, and monitoring and evaluation. Such an approach in Scotland would provide support in ensuring that policies remain up-to-date and appropriate to their circumstances. Examples of this type of material are set out at the end of this chapter and this illustrates the extent to which attention to the policy cycle is increasingly being used elsewhere.

6.11 Whichever of these options is pursued, there is a need to identify and collect best practice. Model policies could form an integral part of the intended outcomes of the Scottish Executive research programme, Thus, for example, where research involves the review of development plan policies and policy content, model policies should be identified and promoted as an integral and iterative part of the process. Examples of appropriate research studies include the development of a policy for architecture, affordable housing policies in rural areas (Satsangi et al, 2001) and the current work on green belts. Appropriate input by relevant interest groups and wider consultation would be required as part of this process. These processes may be usefully coordinated by the Scottish Executive.

THE POLICY CYCLE

6.12 Land use planning systems worldwide are confronting the issues of reforming planning administration. In Northern Ireland, for example, topical guidance asserts the need for well-crafted policies that are unambiguous, succinct and easily understood (Department of the Environment, 2003). Recent guidance in England confirms that the plan preparation process needs to be streamlined and well project-managed in order to optimise the available resource (Office of the Deputy Prime Minister, 2002). Further afield, the government of the State of Western Australia has adopted model text guidelines that provide a common approach to policy formulation, supported by indicative approaches to the formulation of policy content. Government guidance in New Zealand likewise asserts the need for clearly stated policies. Moreover, the New Zealand planning guidance clearly argues the case for a solid awareness of the public policy-cycle (Figure 20). This, it is suggested, will help to ensure consistency, credibility and certainty for policy and plans (Ministry for the Environment, 2003). The guidance thus highlights the importance of having a 'policy-making discipline'. This method is echoed in the English makingplans guidance which emphasises 'the place of the plan in a continuous cycle of understanding needs, making policy, managing change, monitoring and review' (Office of the Deputy Prime Minister, 2002: 5).

6.13 The policy cycle model is a useful way of considering policy development. It applies equally to the drawing up of policies that are specific or model. Whilst this scoping study might, at first sight, appear to emphasise the policy formulation stage, clearly what type of problems are identified, how policies are formulated, and how they are evaluated all form part of an iterative cycle The policy cycle model suggests that policy drafting involves a disciplined cycle of policy development and refinement. The drawing up of policy may include the selection or adaptation of a model policy. The policy cycle model clearly illustrates that for model policies to be timely and up-to-date they must form part of a wider process of monitoring and review in order to evaluate whether the desired policy outcomes are met.

Figure 20: A Policy Cycle

Source: Derived from Ministry for the Environment (2003: 3)

6.14 There was a concern expressed at the focus groups that too great an emphasis upon the specific stage of drawing up of model policies would obscure the importance of interpretation and implementation. Thus, it was asserted several times during the discussions that:

Implementation and interpretation are key.

Related to this point was the concern that model planning policies must be understood in the round and in the context of each local planning authority. Thus, one planning officer observed:

'Model' planning policies are all very different. What's difficult is how people interpret those words. Model planning policies have a merit but it's how officers and members interpret and use model planning policies that will be key. Unless you look at the whole you miss the point - if you're just looking at words.

The idea of a policy that works clearly involves more than just words and the repetition of words.

6.15 As such, for example, it was asserted at the focus groups that monitoring and evaluation of policy is critical to determining policy effectiveness. This understanding was already picked up on and stated in the Digest:

There is [...] no reference in the consultation document to the monitoring of such model policies and who would be expected to do this. For instance, would they be expected to form part of the regular monitoring of the development plan by the planning authorities, or would they be monitored nationally? (Geoff Peart Consulting, 2002b: 38).

6.16 The representation of the policy cycle clearly illustrates the significance of these observations around the drafting, implementation, monitoring and evaluation of policies. The drawing up of model texts or exemplars of best practice does not occur in isolation. The introduction of model policies may well help to achieve a short-term efficiency gain in planning administration, but model policies will have to demonstrate the same robustness as planning policies at large. Model policies must not only remain responsive to changing policy issues, but clearly also demonstrate policy effectiveness. As national examples of model policies, their monitoring and evaluation will therefore have to reflect a national perspective. The Scottish Executive already seeks to ensure that its PAN series is up-to-date and promoting best practice. Were model policies to form part of this suite of guidance, their quality will also have to be monitored and amended accordingly. There are likely to be important resource implications to be considered as a consequence.

6.17 Potential sources of information could be drawn from the Inquiry Reporters Unit with respect to how policies stand up at appeal, or through an extension to the planning audit scheme. More informal approaches, such as through particular networks or conferences which could be organised around geography or theme may also serve to evidence what is working in practice. Indeed, issues raised at the focus groups highlighted the urgent requirement for advice in order to speed up and enhance policy making. Thus, from a local authority perspective it was asserted that:

It's a Local Plan Forum that's missing - that would be better than a Scottish Executive web site. Although advice can be covered through the web and Planning Advice Notes can highlight best practice, there's simply not enough advice.

The previous chapter considered some of the approaches to identifying and drawing up model policies and best practice that have taken place, largely through commissioned research. The next section considers a number of relatively more informal approaches, such as emphasising the value of Local Plan Forums, to finding and sharing best practice that were mentioned during the focus group discussions.

EXCHANGING BEST PRACTICE

6.18 The Consultation Paper specifically suggested that local planning authorities together with the Scottish Executive should draw up model policies. The responses in the Digest indicated support for this, although there were 'views that other stakeholders should also be involved in the process.' During the focus groups, reference was made to the approach of working in partnership along the lines of the experience of drawing up model planning conditions (Circular 4/1998). Here, the Scottish Executive worked together with development control officers from Glasgow, Inverclyde, Moray, Scottish Borders and West Dunbartonshire. Circular 4/1998 makes it clear that when considering the use of the suggested model conditions in development control it is important to acknowledge that the list is not exhaustive. Moreover, the purpose of the suggested conditions is to function as a model. As such, they may need to be adapted to the circumstances of particular cases. The emphasis upon partnership in drawing up model conditions, and the recognition that their role is not prescriptive but simply indicative, offers important parallels for the preparation of model policies. The Scottish Executive has asserted that there is no intention that model policies be imposed on other stakeholders.

6.19 During the focus groups it emerged that as part of the internal approaches to the policy rationalisation of development plans currently underway, a number of local planning authorities have put their policies under a critical spot-light. In some local authorities, how policies have evolved and performed has been tracked using a matrix method of evaluation. This has allowed a core of policies to be identified, drawing on whether or not policies have been used successfully, or indeed whether they have been used at all. Related to the identification of model policies is thus a questioning of whether policies are considered to be actually useful in practice. Considerable energy is already being expended in devising approaches to assess, discard and retain policies, whilst at the same time being sensitive to the fact that policies apparently lying dormant are nonetheless potentially discouraging inappropriate development. The focus group discussions highlighted the extent to which policy thinking is proactive in some areas in the search to promote more effective policies and to produce shorter and more consistent plans. An important question is how to best share those experiences.

6.20 The enthusiasm of participants in the focus groups emphasised the interest in such meetings for the sharing of best practice. Such face-to-face discussions would provide important opportunities for drawing upon and learning from wider experiences across Scotland's planning community. At present, approaches to policy writing are often informal and ad hoc, based on personal networks and personal knowledge. These informal processes tend to be different according to the nature of the planning issue, the circumstances of the locality, and the way in which a particular policy gets promoted to the agenda. Focus group participants described how, for example, when confronted with the drafting of a new policy, they looked at how other local planning authorities were dealing with this. The value of 'learning from the experience of others' was highlighted as being of critical importance in solving local policy dilemmas. There was a recognition, however, that even here considerable sensitivity to local circumstances was required:

We're looking for slim policies - we barter - get agreement. There might be a core of model policies - but standard wording jeopardises difference.

Rather than directly importing policies from another local authority professional planners engage in a dynamic process of identifying ideas, sifting solutions and innovations from elsewhere, and, importantly, tailoring them to meet their own specific context and political circumstances.

6.21 Particular suggestions as to how model planning policies might be drawn up in practice were cited at a number of the focus groups. Aberdeen City Council, for example, has recently set up a Land Use Forum with representatives from Scottish Natural Heritage, Scottish Water the Civic Forum, Scottish Homes, City Centre Partnership, Aberdeenshire Council and the Chamber of Commerce. Other potential approaches to drawing up model planning policies include focus groups on particular topics where particular organisations or agencies could take the lead. There is clearly support to find approaches which will help to identify policies with a 'good track record' and 'preferably those with a 100% rock solid appeal performance'. A further interest is in seeking out policies which are positively worded.

6.22 The experiences of related public policy areas may be a useful starting-point in learning about similar approaches to improving practice. In the Digest, the Society of Chief Officers of Transportation in Scotland (SCOTS), for example, commented on its approach to drawing up guidelines:

The development of model policies avoids the need for individual authorities to reinvent the wheel each time. It also ensures a degree of consistency and recognises that developers operate on a pan-Scotland basis. SCOTS have recently agreed to the principle of developing national development control guidelines on transportation requirements with this very sort of issue in mind. (Geoff Peart Consulting, 2002b: 39).

6.23 Clearly the first step being suggested here is that of drawing up guidelines which can lead to the development of model policies. Importantly, there are issues of precisely who sponsors particular initiatives of this kind. The principle behind the SCOTS study appears to be that it is local authority driven, led by senior officers and seeking to promote greater consistency at a pan-Scottish level. Similar approaches suggested at the focus groups included the sharing of information through key stakeholders, including the Scottish Minerals Officers Group, the Society of Scottish Directors of Planning, or the Royal Town Planning Institute in Scotland. There is a body of collective knowledge available, such as the Coastal Forum, for example, and indeed, individual expertise also exists around specialist topics, such as aquaculture and flooding. This fragmented knowledge requires tapping.

6.24 In addition to the knowledge and experience within local planning authorities, other partners may have an important role to play in raising the awareness of model policies. Voluntary organisations, such as the Royal Society for the Protection of Birds, for example, which has a remit which is broader than Scotland might be useful in sponsoring good practice. Further, since they can draw on wider experience, such bodies could have much to contribute to the identification of innovation and policy success elsewhere. The comments made during the focus group discussions highlighted the extent to which ideas and experiences outwith Scotland are already used and shared. In this respect, the Royal Society for the Protection of Birds, which itself commissions research into policies can offer an important resource. Such bodies can offer useful insights not only into policy development and policy successes, but can also inform our understanding of how to go about improving practice.

6.25 The focus groups revealed the existence of a range of interests interested in actively engaging in the process of sharing expertise and developing policy. Indeed, the responses to the Consultation Paper highlighted a number of such groups. Participation at the focus groups highlighted this enthusiasm. The Garden History Society, for example, asserted that a model policy for the protection of historic gardens would be invaluable and that stakeholder involvement was critical:

Model policies would be useful against a background where planning authorities are failing to safeguard Scotland's historic and cultural landscape. There is no statutory duty on any agency to maintain a register of gardens and historic landscapes. Furthermore, local authorities are failing to adhere to existing national guidance in respect of these matters. In the absence of

such a duty and local authority action a clear model policy should be drafted to afford protection to these assets. Stakeholders should be involved in the drafting of these model policies. (Geoff Peart Consulting, 2002b: 40).

6.26 The Garden Society's objective is to secure appropriate policies for the protection of historic gardens and designed landscapes in Scotland. This reflects the Society's perception that 'the great majority of designed landscapes across Scotland are without any form of protection'. As such, improving the wider understanding of the importance of these sites is part of a wider campaign to raise policy awareness of this issue. The activities of such special interest groups have a role to play in the formulation of good policy. Nonetheless, care is required to ensure that the wider objectives of improving development planning, such as a reduction in plan length, are not lost.

6.27 Extending the drawing up of planning policy to include other stakeholders will require appropriate arrangements in order to minimise any possible policy bias. The wider airing of policy is critical if confidence in the system is to be maintained. The creation of specialist forums or task groups could be encouraged to report to annual planning conferences in order to share policy learning and involve the wider planning community. There are clusters of knowledge and expertise around particular policy areas. There is, however, a case for better co-ordinating and disseminating the wisdom of these particular 'communities of practice'. The use of this approach to the co-ordination of policy thinking by the planning community might usefully be promoted by the Scottish Executive. Newsletters, regional seminars, both thematic and geographic, away days, email newsletters to selected networks, and on-line discussion threads are all useful methods which could be used to raise awareness of best practice and emerging developments.

EVIDENCE FROM ELSEWHERE

6.28 The literature review shows that considerable work is being undertaken with respect to improving policy making outwith Scotland. The Town and Country Planning Association, for example, has established a number of specific Task Teams to deal with particular policy issues. Further, it organises master-classes on individual policy subjects, and commissions experts to produce guides. Such activities and material all add to a pool of information and in changing the culture of planning. Model policy making processes are integral to this thinking. The Town and Country Planning Association recognises, however, that appropriate funding must be secured and sponsorship is thus sought in order to provide the necessary financial resources (Town and Country Planning Association, 2003).

6.29 The study undertaken by Baker Associates (undated) relating to the dissemination of good practice in plan preparation and management in England emphasises the central role of the (then) Department of Transport and the Regions in disseminating guidance in a format that enables practice to be refreshed as new ideas as emerge. They note a number of approaches to the dissemination of policy practice: a web site with layers of information and scope for interactive discussions, and the exchange and development of ideas (such as the Planning Portal being developed by the Planning Inspectorate), conferences (such as those organised by the Royal Town Planning Institute or Planning Summer School), and road-shows. The study identifies two areas where networks might fruitfully be developed:

i The sharing of information between local planning authorities;
ii How others might assist local planning authorities in their work.

6.30 In terms of local planning authorities sharing ideas and material, the Baker Associates study highlights working with partners so as to draw upon their expertise and research. Networks might be national, regional or area-based. The tendency to reinvent ideas may be due to people not having the time to share practice or due to the absence of an appropriate forum for exchange. Local plan groups and Continuing Professional Development events may aid knowledge- and practice-sharing. However, despite a range of conferences already held by institutions, commercial organisations and academic bodies, the precise focus may be missing. The study highlights how joint working is emerging as an important mechanism for policy transfer (regional planning is an example of this in England). There is potential for local planning authorities with common time-scales to pool resources in terms of policy development. Such ideas could work in tandem with model policies.

6.31 The Baker Associates study describes how organisations other than local planning authorities could assist councils by sharing material. Yet the uncertainty over the status and validity of material, and obstacles such as difficulty of interpretation, and convenience of access are often problematic. One suggestion is the development of a database that can be interrogated and which comprises all development plans, the objections received to particular key policy areas and the observations of Inspectors (Reporters). Critically, perhaps, the study emphasises the value of ideas:

In the interest of producing more effective and influential development plans with less distraction, there is a need to reinstate ideas as the most valuable commodity, and as a commodity for sharing (Baker Associates (undated) para 6.10).

Importantly, ideas and information must be easy to access, navigate and use if they are to best serve the planning community.

A CASE FOR THE USE OF NEW TECHNOLOGY?

6.32 The Scottish Executive could provide a useful magnet for collecting and mediating policy development by acting as a cipher for such material. Clearly, the possibilities of electronic technology and the use of the internet may be appropriate. Three points are important.

• First, there is the issue of institutional capacity required for the Scottish Executive to use the Planning Homepage as a central point for best practice in policy development. This is already the case with PANs provided electronically as well as in paper form.
• Second, there is a risk of information overload as the simple dissemination of information does not necessarily result in knowledge transfer. There is an important role for the Scottish Executive to act as a cipher to the emerging on-line resources and to ensure a quality check. The house-keeping of any on-line resource bank is critical to effective knowledge management.
• Third, the presentation and content of policies for use on the web (as opposed to hard copy) requires rethinking. Evidence from England suggests that the formatting of development plans required by the emerging electronic medium will not be identical in style and form as policy material that is traditionally disseminated (ODPM, 2002). Consideration will therefore have to be given to investigating how model policies and best practice can make best use of electronic facilities. Where policies in on-line development plans are capable of interactive access to a national resource, the up-dating of policies could be secured swiftly. When model policies become operable in a particular development plan, however, is clearly critical.

LEARNING LESSONS

6.33 One of the concerns raised in the Digest and reiterated during the focus groups is that the generation of model policies might lead to 'aping' and 'painting by numbers'. As a consequence, it has been suggested that model policies might reduce policy innovation and creativity. Allied to this is a sense that individual planning authorities when faced with the opportunity to take policies 'off the shelf' would avoid thinking the issue through from first principles and import a policy which is alien to their specific local circumstances. The observation in the Digest by Glasgow City Council acknowledges this in suggesting that, whilst key strategic issues might form the basis of model 'policies', their role might simply be contextual, rather than detailed:

Model policies could, perhaps, be prepared for key strategic issues such as open space, environmental protection and transportation, as well as for standard development control matters such as telecommunications infrastructure. They may also prove useful for the setting of a standard 'context' for certain policies. (Geoff Peart Consulting, 2002b: 41).

Yet, a local planning authority focus group participant noted that one benefit of establishing an agreed suite of model planning policies would be that one could 'pick it off the shelf without fear of plagiarism'.

Part of me says were looking for advice - it's about anyone taking part - but, on the other hand, if it tends to spoon-feed and suppress thinking, then it's not so good.

Clearly there is a need to ensure that thinking about policy relevance remains critical to the policy making process, whilst providing a resource which people are able to use without fear of come-back.

6.34 The literature review provided some useful insights here. Research into policy harmonisation in the European Union and the idea of policy transfer highlights the problems that arise when policies from elsewhere are simply transferred or imported into a different context. The problem is that often the policy simply does not fit its new environment. The theories about policy transfer and lesson-drawing suggest a range of ways that lessons can be learned. Following Rose (1993), the role of model policies could thus vary. A model policy may lead to 'direct copying' or, as is the case in the current informal approaches to policy formulation, it may simply provide 'inspiration'. Alternatively, model policies could result in policy adaptation, hybridisation or synthesis. The introduction of a suite of model policies could thus provide a resource that could facilitate each of these different learning approaches. The research into policy transfer would suggest that for a model policy to be capable of transfer across Scotland the political, institutional, administrative, social, economic and cultural conditions need to be the same. Whilst this is unlikely to be the case, the important point is that to work, policies must be compatible with the context in which they are intended to operate.

6.35 In this respect, some cautionary points are thus worth making. In order for a model policy to work well, particular policy settings must be sufficiently similar for the policy to fit. This requires a number of pre-requisites. First, it is important to be aware of the context and conditions that are required for a particular policy to work effectively. Here, the scope of the information and the adequacy and accuracy of information are important. Second, a robust assessment as to the similarity of the problems being addressed and the policy goals being tackled must be understood. Third, it is necessary to consider whether the context into which the policy is to be applied is comparable (Mossberger and Wolman, 2003). Fourth, considerable care is required in the identification of best practice examples which may be 'showcase' rather than 'average', and not, therefore, be useful roadmaps for action (Wolman and Page, 2000).

6.36 This suggests that any attempts to draw up model planning policies must be accompanied by clear criteria for understanding their applicability on a pan-Scotland basis. Indeed, the lessons from research on urban regeneration policy transfer (Wolman and Page, 2002) emphasises the importance of better understanding why policies work. A number of points can be made.

6.37 The use of model policies will require clear guidance. The guidance cited in the resource list at the end of Chapter 5 highlighted the use of guidance rather than particular policy models of ideal practice. Thus, the Idaho Transportation Department (1998) in its guidance on developing transportation policies provides a number of policy excerpts from local jurisdictions by way of highlighting issues, representing practice, sharing standards, and illustrating how policies are shaped to meet the needs of particular communities and places. The 'policy pages' come with a health warning which states:

The examples given in this chapter are not intended to be ideal policies. They were chosen because they are representative of what Idaho cities are adopting. Be sure to adapt what you learn from these examples to your local situation.

This point underpins the current thinking about model policies which is that they should not be mandatory.

6.38 The Idaho Transportation Department (1998) sets out a number of policy development principles, which, the Department notes, 'experience suggests it is wise to follow'. These may be summarised as follows:

• Involve the people of the community in developing the policies for your plan;
• Make the policies in your plan specific;
• Aim at implementation when writing the policies for your plan; and
• Never substitute a photocopy machine for a well-designed planning process.

The important point is that the examples are intended to provide helpful ideas, but the details should be tailored to fit the needs of each particular context. Similarly, understanding why a policy might be expected to work and why a policy might be weak is the device used by the Council for British Archaeology in its on-line policy making guidance. These approaches are part of a growing body of guidance that emphasises the importance of a robust policy making discipline (Ministry for the Environment, 2003) and quality plans (Crow et al, 2000).

6.39 Potential questions that might usefully be asked when considering the appropriateness of using a model policy are:

• Is the authority's policy objective best served by a policy statement or supplementary planning guidance?
• Is a policy for this issue useful in this plan or is it covered elsewhere?
• Does a model policy serve the purpose in this plan? Should it be amended? If so, in what ways?
• Does this policy allow the plan to be consistent with the authority's general approach and philosophy?
• Does this policy fit with the other policies in the plan, and with other policy documents?

OBSERVATIONS ON THE EVIDENCE FROM THE FOCUS GROUPS

6.40 Model policies are part of a broader programme of change in modern planning practice. There is a concern and the recognition by local planning authorities of the need to remove unnecessary repetition of policy in different layers of development plans. There is also a conscious move to reduce the number of policies in development plans and to provide guidance on a supplementary basis. Local planning authorities highlighted that model policies have to fit within this wider changing context and that clear guidance from the Scottish Executive on current priorities is essential. In this context, local planning authorities emphasised the importance of improving the dissemination of good practice, based upon clear principles, rather than the development of model texts.

6.41 An important distinction was drawn between model policies which are blue-print models and model policies that simply provide a best practice example from which local planning authorities can draw and which can be adapted to fit local circumstances. Prescriptive blue-prints, whilst offering the perceived efficiency gains of reduced preparation time, consistency of wording, and less debate at public inquiry may not fit the specific planning problems and spatial objectives of a particular locality. Moreover, departure from an agreed model could result in prohibitive resource implications for authorities and users of the planning system.

« Previous | Contents | Next »