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Statutory requirement to prepare Action Programmes
Local Authorities
Aberdeen City Council: The preparation of action plans should be welcomed to reflect the fact that the production of a Plan is not an end in itself. The action plan would require the commitment of other agencies to make it meaningful and realistic.
Comhairle Nan Eilean Siar: The provision for Local Development Plans to be supplemented by an Action Programmes is included in the White Paper. Such programmes would set out actions required to implement each of the plans policies and proposals. The timing and review of such programmes should however be a matter for the Local Planning authority to determine in line with how it publishes its development plan scheme and requirement to update Local Development Plans every 5 years. Mandatory two yearly reviews are not supported.
East Dunbartonshire Council: Whilst this is welcomed and to a large extend already in operation in East Dunbartonshire the requirements to update every two years and publish the plan will involve extra workload
Glasgow City Council: Whilst this proposal is generally worthwhile, it is likely to include elements which are outwith the direct control of local planning authorities. To this end, it could prove partly irrelevant, unless the other agencies and bodies who engage with the plan process become statutorily bound to deliver agreed Development Plan actions and align their implementation programmes. Action Programmes could be beneficial in summarising proposed actions, timescales, etc but may be difficult to draw up because it would commit other agencies, and private sector bodies to specific timescales and funding. If introduced, Action Programmes should be kept relatively simple and easy to monitor and update, and focus only on those proposals and actions likely to have a significant or strategic impact; and further clarification is required from SE on to the exact nature and content of Action Programmes.
Inverclyde Council: This is accepted but again there requires resources to achieve this, and to a large extent requires suitably qualified and able planners to conduct the inevitably high-level liaison and partnership work involved.
Moray Council: An Action Programme will require the local authority to manage the implementation of its Development Plan more corporately, merging it with 3-year Budget Plans. It may also steer the Development Plan towards a more realistic, manageable implementation programme.
North Lanarkshire Council: Discussion is required on the form and content expected for Action Programmes.
Perth & Kinross Council: Welcomes the introduction of a statutory duty to prepare, monitor and review Action Plans as a significant step forward in providing certainty to the delivery of Development Plan proposals. Planning Authorities however cannot do this on their own and the Plan will only be effective if other agencies co-operate. The question remains as to whether these agencies will have the resources to cope with these new demands.
Renfrewshire Council: Reservation expressed. While monitoring the effectiveness of a development plan is appropriate the preparation of an action programme would only relate to proposals contained in the plan while the greater part of any development plan would be in the form of policies setting out a land use framework for assessing development proposals which may be submitted. In addition the majority of the proposals would not be under the control of the planning authority and therefore the authority cannot be held responsible. While appreciating the objective of the action programme the Council requires more information on proposed form and content before endorsing such a proposal.
West Dunbartonshire Council:If development plans are to be more pro-active then a requirement for an action plan must be seen as a positive recommendation. However, again this requirement, and its updating at least every two years, has resource implications which must be considered and addressed
West Lothian Council: This proposal is supported in principle, although it appears that the action plan will be non-statutory. Given this, it may be necessary to duplicate some of the key details of the action plan within the development plan itself.
Other LA Organisations
Glasgow and the Clyde Valley Structure Plan Joint Committee:
Action Plans are a key tool in delivering the development planning system proposed in the White Paper yet the nature, content and status of such Action Plans remain unclear. The nature of linkages between Plans and implementation remain to be defined. Whilst the Joint Committee agrees with this element of the White Paper and the overall aim of the Ministers in principle, it is essential that there be greater specificity in the nature and status of Action Plans and the linkage to spending programmes. The White Paper proposes that these Action Plans be reviewed and published every two years. Whilst monitoring and review is an essential part of managing the development planning process from plan preparation to implementation, the lack of specificity related to Action Plans and the linkages between Plans and delivery mechanisms places a real question-mark over the validity of the two yearly review period, especially as Strategic Development Plans have twenty year time horizons. This could well provide a context for adverse and unfair criticism of the SDPA, if the linkages remain weak. Additionally, given the stress that the White Paper places upon delivering Plans, it seems contradictory to move towards greater prescription of form and content of the Development Plan (para. 14 above), yet leave the form, content, status and mechanisms of the Action Plan un-defined.
Non Departmental Public Bodies
Scottish Environment Protection Agency: Supports proposal but one practical issue that the Executive should consider is whether these Action Programmes will qualify under the Environmental Assessment (Scotland) Bill when it is enacted. This will depend in part upon the form, scope and content of these documents which is still to be set out, however it is important to be aware of the practical issues that might arise should these programmes qualify ( e.g. in respect of timescale, public consultation, taking account of the Environmental Report etc). Further clarification of the proposed form and content of Action Plans would be helpful in this regard.
Scottish Water: We note this requirement and believe this area will impact significantly on Scottish Water due to the development constraint issue and the timing of investment in our assets to accommodate development. At this stage we are unclear on the extent and detail of this impact in the light of the recent Ministerial statement on development constraints and the requirement for Scottish Water to prepare annual action plans.
Sportscotland: A greater focus on the preparation for action plans would help to deliver a better success rate on the implementation of development plan policies and proposals.
Other Public Bodies
Strathclyde Passenger Transport: The implementation of many actions outlined in these plans will often be the responsibility of another organisation. We would envisage the key role of action plans to be monitoring the implementation of action programmes by those organisations. We do not envisage land-use planning authorities becoming involved in the execution of such projects themselves. The process should be clarified in the action plans guidance. We believe that the action plan review should be seen as further evolution of existing action plans, not as redrafting from scratch. Again this could be addressed in guidance.
Development Industry
Elphinstone Land: We particularly welcome the introduction of "action plans" for the new generation of plans. Too often in the past, some planning authorities have seen the completion and approval of plans as being the end of the process, with little thought being given to implementation. The setting of responsibilities for action to the various agencies and the setting of targets for implementation will assist in ensuring that where problems occur, they can be dealt with in time to ensure that the overall aims of the plan are achieved.
Homes for Scotland: Both Barker and the Minister call for much more effective monitoring of development plans. Barker asserts that it should be based on monitoring of the local housing market and the council performance in both house completions and responsiveness to the market. Implicit in this is a much more effective system of Land Audits. Barker recommends that the monitoring should be undertaken at regional level of which there is no Scottish equivalent. The Barker Report also noted that data was poor in Scotland. Our preferred solution is that the monitoring of strategic development plans should be undertaken by independent economists at structure plan level to an agreed system established by the Executive in consultation with users. Homes for Scotland are of the opinion that a key measure of whether housing policies are being implemented is the housing completions that are being achieved, not just the land that is allocated. The proposed Action Plan should also be used to review the success of the Plan in terms of housing completions. These considerations lead us to the conclusion that there is an early need for clarification on how the new strategic development plans for the city regions will operate in practice.
Manor Kingdom Group: The Barker report and the Minister call for much more effective monitoring of development plans. Manor Kingdom s preferred solution is that the monitoring of strategic development plans should be undertaken by independent economists at structure plan level to an agreed system established by the Executive in consultation with users. Manor Kingdom is of the opinion that a key measure of whether housing policies are being implemented is the housing completions that are being achieved, not just the land that is allocated. The proposed Action Plan should also be used to review the success of the Plan in terms of housing completions. These considerations lead us to the conclusion that there is an early need for clarification on how the new strategic development plans for the city regions will operate in practice.
Waterfront Edinburgh Ltd: The proposal to include action programmes for development plans is welcome but it is essential for infrastructure, education and health service provision on a major project such as Granton Waterfront that there is commitment. These aspects are vital to the success of this major project.
Other Businesses
Scottish Rural Property & Business Association: It is proposed that there will be Development Plan Schemes (reviewed annually) as well as action programmes (reviewed bi-annually). We feel this could be simplified into one scheme. This would help to streamline the system further for users.
Professional Organisations
RTPI Scotland: We do not support the provisions to remove applications for outline planning permission. We sympathise with the improved status which development plans should carry through their currency and relevance, including essential details for the purposes of density, infrastructure provisions, significant design constraints and developer contributions etc. However, it is unlikely that any plan will provide a sufficiently comprehensive briefing for developers of more complex sites to make it cost effective for them to go directly to the stage of detailed planning consent. Outline consents are necessary to purify many project management contracts and will be sought in any situation not covered clearly by the development plan where there is likely to be significant expense in going directly to a detailed application. This should be much less of an issue if plans are more precise and kept up to date.
Planning Consultants, Architects and Lawyers
Warren Consultants We agree with the White Paper's proposals that Reporter's recommendations are binding subject to an "appeal" by the local authority to Scottish Ministers based on the proposed criteria.
Community Councils
Currie Community Council: We note that "local people will be more involved" in the preparation of Development Plans, but there is nothing to indicate that they will have any input into their implementation.
Voluntary Organisations
Greenspace Scotland: The proposal that an action programme should be prepared alongside each development plan is welcomed and will assist the culture shift from development control to development management.
Academic Bodies and Individuals
Macaulay Land Use Research Institute: The proposed action programme is welcome and makes the authority more accountable within a particular plan.
Private Individuals
Piggins JM Dr: I welcome the proposals for quicker drafting, and a 2-year action programme but the magnitude of change required is considerable. In Aberdeenshire, for example, a consultation exercise was last held in 2000, but the consequent Local Plan is still not fully adopted, nor likely to be so before 2000. I note with approval the various measures proposed in Section 8 of the White Paper, but I would not under-estimate the considerable pressure and resources from the Executive that may be required to encourage and enable local authorities to implement the desired improvements.
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