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Greater prescription of form and content of Plans
Local Authorities
Aberdeen City Council: Shorter and more focused development plans are welcomed. However, enhanced community engagement would be likely to produce pressure to include further detail, there is likely to be conflict between this and the aim of making development plans more focused. Improved cross referencing to other corporate and partnership plans and strategies will be important to address issues which are not strictly related to land use planning. The greater use of supplementary guidance should also be supported, although there will be resource implications given that these will be subject to a consultation and approval process. The proposal that a schedule of local authority land ownership interests is to be included in the Development Plan is to be welcomed in the interests of openness.
City of Edinburgh Council: Support proposals pursuing improved transparency and understanding of plans but there must be sufficient flexibility permitted to reflect local characteristics
Dundee City Council: The use of Supplementary Guidance is considered essential to keep local plans concise and focused but allow for more detailed examination of complex issues where appropriate. The status of supplementary guidance should be recognised by Reporters.
East Dunbartonshire Council: This is considered to be a questionable intrusion into the economy of Planning Authorities to decide the priorities for their plans. The recognition of the importance of supplementary guidance is however welcomed.
East Renfrewshire Council: It is accepted that there should be a degree of consistency in Development Plans. However, care needs to be taken that a balance is struck between uniformity and local control. Local Authority areas vary considerably and so the content of Development Plans in relation to strategic and local issues will by necessity vary. Local Authorities are best placed to decide how to address the issues facing them. The use of supplementary guidance needs to be restricted to matters that complement the provisions of the Development Plan and not as a quicker substitute for updating the Development Plan. Further consideration also needs to be given to the weight that will be given to such guidance in Planning decision making and the extent of consultation required.
Glasgow City Council: This proposal is in line with current thinking on the development of the City Plan and Structure Plan and is supported in principle. The final content of the plan will only become clear after public consultation has been undertaken and an Inquiry held. Consideration will be given, as part of the City Plan 2 policy review process, to reducing the number of policies in Part 2 of the Plan. While the Council broadly supports the proposal, there is a need to clarify the mechanism to bring planning guidance into the statutory process. The opportunity to accord statutory status to supplementary guidance is supported in principle and further consideration of the option is required. However, if this guidance is to accrue statutory status, for example, there will be a need to consider how the public consultation process engages with the formal development plan process. Consideration will be given within the overall policy review for the development plan and associated planning work to the preparation and establishment of supplementary planning guidance to support the local development plan.
Inverclyde Council: This is one of the less important proposals. However, there is clearly a need for greater consistency and comparability across the country in terms of what a City Region Plan and a Local Development Plan should cover, but any changes here should not be at the loss of important local diversity where it is essential to have it, and where there is always the potential for new thinking and ideas emerging from different experience across the country, from which others (including the SEDD) can learn.
Perth & Kinross Council: The key to a successful Plan is not its overall length but the ability to navigate the Plan to find those sections relating to the users' interest. There are major resource implications associated the new procedures of plan preparation. Taking account of staffing and other costs the implications per annum are initially estimated at a net increase of £90,000.
West Dunbartonshire Council: The Executive wishes development plans to be shorter and more focused and this, generally, should be seen as a positive way forward. However, with every piece of guidance and advice that comes out from the Executive there is a requirement for development plans to embrace more issues. There has, therefore, to be a rationalisation - hopefully in the form of this greater prescription - if this worthy aim is to be met.
West Lothian Council: This proposal is supported, although there is some concern that the use of supplementary planning guidance fragments the development plan, i.e., those using the development plan may miss a key element of policy as it is not accessible from within the development plan. A requirement for all SPG to be identified in the development plan scheme would go some way to mitigating against this possibility.
Other LA Organisations
Glasgow and the Clyde Valley Structure Plan Joint Committee:
When the Executive first raised this aspect following the Review of Strategic Planning and listed the strategic planning issues which it anticipated should be components of future SOPs, it omitted Retail Policy as a strategic issue. The Joint Committee made strong representation regarding this omission, arguing that retail policy is a strategic economic and planning issue at the Glasgow metropolitan level, with significant substantive evidence to support that claim. The Joint Committee further argued that it is more appropriate for the Strategic Development Planning Authorities to define the strategic issues that should be included in its development strategy, since these will vary between different city regions and over time.
Non Departmental Public Bodies
Scottish Natural Heritage: There is some tension between the aim of reinforcing the primacy of development plans and the intention to shorten these documents. For the proposed approach to be effective, it is important to ensure that these plans, supported as necessary by supplementary material, can provide sufficient clarity and detail to guide development management. A number of mechanisms could help to achieve this, including the provision of additional spatial guidance through the NPF, supplementary guidance and/or SPPs/ PANs. An adequate core of necessary information should, however, be contained in the development plan, as this document will better reflect local circumstances, and because the dispersal of guidance through a large number of documents could work against the Executive's stated objective of increasing the transparency of the planning system. The development plan must also contain sufficient detail to provide a meaningful basis for SEA.
Scottish Environment Protection Agency: While we understand that there is a need for some diversity to reflect the differing circumstances faced by each Planning Authority, a more consistent approach to development plan form, content, layout and map presentation would be very helpful. A clear and consistent approach to development plan proposals in particular would be extremely valuable to us as a stakeholder engaged in plans all across Scotland. Clearly, Scottish Executive guidance on form and content would be an early requirement.
Professional Organisations
RICS Scotland: There is no doubt that currently, the Local Plan tries to cover everything. Therefore, we agree with the proposal to attempt to restrict the Local Plan to land use, however, we are also concerned that there is much duplication in the planning process where structure plans and local plans overlap. In some areas, such as Falkirk, Stirling and Clackmannanshire, this is significant. RICS Scotland welcomes the removal of two tier planning outwith the 4 City Regions.
RTPI Scotland: We support greater prescription without loss of flexibility for planning authorities to tackle issues as they are appropriate to their local level. Nevertheless, the planning system has always suffered immeasurably from the lack of consistency of approach to both procedure and policy as a result of the lack of a commitment to standard practices. The same principle underpins the case for model planning policies. We consider that there is scope for much more extensive use of these than is currently involved in the pilot project, that they should have status within the relevant SPP/ NPPG, but that authorities should be able to justify departure from model policies to address local circumstances, and justify this in their local plans.
Development Industry
EDI Group Ltd: Guidance on the content of Development Plans should be updated to take into account the changes proposed to the planning system. The thrust of the White Paper is that where proposals have not been allowed for in Development Plans they are unlikely to succeed. Any flexibility to cope with change will depend on how detailed plans are. There is currently an acceptance of "windfall" development and it is important that the next generation of Development Plans retain this safety valve.
James Barr Ltd (on behalf of various development industry businesses): Given the proposed streamlined nature of plans, it is welcome to note that supplementary guidance will be given greater status in the development management process, perhaps addressing concerns over the use of model policies. Against this general welcoming note, it is imperative to ensure that such supplementary guidance is only adopted and used on a daily basis by Councils following a proper consultation exercise involving key stakeholders, statutory consultees and members of the public alike.
Other Businesses
Association of Electricity Producers: We have concerns over the proposed increased status of supplementary plans. It is likely that supplementary plans will become a material consideration in many proposals. There is a danger that an over reliance on supplementary plans could undermine the content of the development plan. This would be counter productive. There is no commitment to keep supplementary plans up to date. Supplementary plans should be revised regularly to prevent them from becoming out of date. This is especially important given the potential influence they could have on planning decisions.
Crown Castle UKLTD: We support the use of Supplementary Planning Guidance to help take out some of the unnecessary detail from the development plan system. However, at the same time we would wish to ensure that LPAs do not impose their own agenda within such Supplementary Guidance which may conflict with national guidance. As an example, East Dunbartonshire Council's SPG introduced exclusion zones for telecommunications.
Scottish Power: We have concerns about the weight to be awarded to supplementary guidance. Very often supplementary guidance is a statement that has not been subject to consultation and may contain inaccurate and irrational statements of 'guidance' for the Developer. For supplementary guidance to be given enhanced status, there must be full and fair consultation and an opportunity for the Executive to withdraw guidance that is contrary to their policy.
SITA ( UK) Ltd: The White Paper makes reference to enhancing the status of supplementary guidance where statutory requirements for consultation and approval have been met. In the Company's view, where this is the case such guidance should form part of the development plan. A scenario where development plans jostle with enhanced supplementary guidance would not simplify or clarify the planning system.
UNITE Group plc: The role of supplementary planning guidance to provide an interim stage of policy for areas of major change must be maintained in the system. UNITE would welcome consultation on the need for a Planning Advice Note to guide future supplementary planning guidance.
Planning Consultants, Architects and Lawyers
Collar, Neil: The use of supplementary guidance can be controversial. If such guidance is to be given enhanced status, clear guidance will be required on the circumstances in which such guidance can be used and its scope. The emphasis must be on the guidance supplementing development plan policy, and not dealing with significant issues which should have been dealt with in the development plan. There must be a requirement for detailed consultation with stakeholders.
Drysdale, Robert: This remains an elusive goal. Others have described the plan-led system as being dead and buried. Too many policy planners in local authorities set out with the aim of writing a rule book. Because they want to tie everything down and make sure everything is covered, the process takes longer and attracts more objections. We need more enlightened thinking - in particular, we need land use allocations which leave room for alternative forms of development in an area, rather than just one solution.
GVA Grimley LLP: The role of supplementary planning guidance ( SPG) to provide an interim stage of policy for areas of major change must be maintained in the system. Further to several experiences of working on successful SPG projects, GVA Grimley considers that the use of SPG be greater encouraged. For example, the supportive reference in Designing Places, A Policy Statement for Scotland (2001) (p36) should be re-emphasised in further relevant policy statements and policy. The Review of Strategic Planning Consultation exercise of 2002 revealed a significant level of demand for clarification of the status of SPG. This was the most frequently made recommendation by the consultation respondents. GVA Grimley therefore suggests that a planning advice note on this topic would be helpful in providing clarification on the status of SPG, its weight as a material consideration and to specify more detailed requirements for its preparation processes, including community consultation. Given that the relevance to the decision making process depends on the extent of public consultation on the supplementary planning guidance, it is essential that detailed procedures for public consultation on SPG is set out in policy guidance, to encourage robust and successful practice. At present, policy guidance on this increasingly widespread practice is fragmented between a number of different policy sources, and would benefit from a co-ordinated approach through a PAN. Alternatively, the PAN on community engagement which is proposed in the White Paper should ensure that detailed guidance is specifically provided on community consultation for SPG, which will be different in form to that required for the statutory development plan.
Muir Smith Evans: We welcome the proposal to limit the policies within development plans to those required to deliver the plan's aims and to support decision-making. We anticipate that a regime with fewer policies is likely to lead to increased emphasis on (and need for) intelligent interpretation of these policies. Guidance on this would be welcomed. It may be required to successfully deliver a culture change in the way policies are used in a balanced way (enabling as well as controlling).
Turley Associates: Greater prescription for the content of plans should provide more consistency between Councils. Shorter and more consistent form and content for plans makes sense. However, it is important that the right balance is struck between what is dealt with in plans and what is left to supplementary planning guidance. As things stand, SPG is consulted upon but there is no mechanism for independent scrutiny. It is therefore recommended that if there are objections to SPG, there should be provision for a Hearing chaired by a Reporter.
Community Councils:
Hillhead Community Council: Briefer local plans in a city the size of Glasgow are not practicable. We already find that amalgamation of local plans for particular areas into one city-wide 'local' plan has removed necessary special provisions distinguishing between areas of different characteristics. A city the size of Glasgow cannot include in a shorter plan the many provisions, policies and guidelines which are essential to the best development of the city. Briefer local plans in a city the size of Glasgow are not practicable. We already find that amalgamation of local plans for particular areas into one city-wide 'local' plan has removed necessary special provisions distinguishing between areas of different characteristics. A city the size of Glasgow cannot include in a shorter plan the many provisions, policies and guidelines which are essential to the best development of the city. Development plans for a city like Glasgow need to have much more rigorous guidelines. The strengthening of guidelines is welcome, but this is not coordinated with the proposed bill. Another concern is how they are interpreted. We were dismayed to hear that matters which are to inform the plans will not be in place until the next parliament. All such guidelines should be agreed and in place before this bill goes to parliament and a new planning bill is introduced. This is a fundamental weakness of the planning white paper. We have found to our cost that the absence of the conservation area appraisals which were to inform Glasgow City Plan has led to inappropriate development. There is a marked lack of understanding of the area on the part of the decision makers. Pertinent advice from other departments ( e.g. roads, conservation) is ignored.
Knightswood North Templar Community Council : Proposals to better proscribe the form and content of development plans are welcomed, particularly proposals to enhance the status of supplementary guidance as a vehicle for more detailed planning policy
Voluntary Organisations
Colinton Amenity Association: We welcome the proposal to enhance the status of supplementary guidance to provide a vehicle for more detailed planning policy.
Planning Aid Scotland: Greater prescription of form and content of development plans could prohibit local solutions to local problems which would run counter to the concept of culture change.
Pollokshields Heritage: We suggest that the Structure Plan Rules must be modified so that the elements provided for in
the Act must be dealt with. Our current draft Structure Plan is in effect silent on physical features. In fact there has been a substantial change in the rivers, there have been serious floods, and there are some alleviation measures. None are mentioned. Actually, the words, "and climate change" should be
added to the physical features component. Viewed simply as a constraint on development and having regard to the recent express guidelines on flood prevention, the omission is astonishing. "It was in the last but one" is not an adequate response. Likewise population is dismissed in a couple of lines as a regional
number, whereas the variation within the regional area is a key development feature. By the same token we suggest that the Development Plans must be regulated, by statute, by more rigorous guidelines. We suggest that these would require
that the following should all be fully developed in the Plan:
- the activities of the local authority, including schools and their catchment areas, parks, open spaces and playing fields;
- hospitals, health centres and GP surgeries;
- universities and further education centres;
- rail, road and air traffic developments and proposals, especially parking.
Scottish Federation of Housing Associations: Local Plans must be subject to enforceable timescales and related performance management, and must: Respond to local housing needs, with land zoned for affordable housing where appropriate. Be informed by local housing needs assessments and by Local Housing Strategies. Demonstrated need for affordable housing should be a material planning consideration. Set targets for affordable housing and be subject to rigorous monitoring. Be Development Plan and Development brief led. Development briefs should be agreed and published to reflect community aspirations prior to formal adoption. Be monitored and adequately resourced in terms of trained staff and funding as well as supported by streamlining of the plan-making procedures. Be informed by Local Housing Strategies and should be integrated by: establishing common objectives, operating to the same timescales and drawing on the same, consistent demographically oriented evidence base, and regular review of development plans and local housing strategies.
Scottish Renewables Forum: We welcome the limitation of those policies to those required to deliver plan's aims and support decision making and we welcome model development plan policies. However, we must express serious concern at the enhanced status for supplementary planning guidance. There is a very real risk that Local Planning Authorities will use this to undermine model policies in the development plan and in national guidance. Also, there is every likelihood that SPGs will persist beyond the five-year development plan life so we would urge that SPGs have a similar lifespan of the main plan to prevent conflict.
The Council for Scottish Archaeology: Historic Landscapes are currently grossly underrepresented in current development plans. This is despite the significance that historic landscapes have in defining the places and communities in which we live. They are also significant in identifying the special character of the places that are attractive to visitors both within and outside Scotland. The Historic Land Use Assessment ( HLA) Project, being jointly carried out by Historic Scotland and the Royal Commission on Ancient & Historical Monuments Scotland, will be a valuable tool in defining areas of high archaeological potential in future development plans, but it is not anticipated as completing its coverage of all of Scotland until 2009. Even with this data there are serious concerns about the ability of planning officers to assimilate this data into Development Plans. Excellent work has recently been carried out in training planning officers in Aberdeenshire Council area. CSA would, therefore, wish for the Executive to devote sufficient resources so that all planning departments in Scotland have the facility and expertise to incorporate historic landscape concerns into all development plans.
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