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Culture Change in Planning
Local Authorities
Aberdeenshire Council: The White Paper highlights the need for a change in the culture associated with the planning system. While we would suggest that within Aberdeenshire Council the statutory planning system is given a high profile, and receives considerable support from members, it remains sadly true that on occasion the system is brought down by an obstructive and reactive culture from a very small number of developers and development interests. We see nothing in the proposals that will address the basic fact that some commercial interests have much to gain from working outwith the system to thwart the development plan. Indeed your proposals for statutory review of development plans every 5 years may fuel such actions. In this context, the need for culture change within all sectors party to the planning system requires, in our view, greater emphasis than it is currently afforded.
East Renfrewshire Council: Support in principle. However, based on past experience, to be effective this will require to be backed up with a mix of incentives and penalties. Voluntary co-operation and commitment is not enough.
Inverclyde Council: This is an unfair criticism of planners. There is no lack of enthusiasm amongst planners for the real task. The problem is the system of endless bureaucracy, paper pushing, consultation with single issue services, organisations and individuals, and criticism from those who don't get their way. A system created by the Scottish Executive.
North Lanarkshire Council: It would have been appropriate to acknowledge that there are good examples of enthusiasm, vision, leadership, management and quality outcomes emerging within the current system. However it is equally appropriate to identify the need for the system to foster best practice throughout. It is welcome that the proposals are addressed to all users and operators of the system. It is agreed that, overall, there needs to be a shift in focus towards the 'front end' of the process, concentration on more significant development (rather than the many minor developments to which a high proportion of resources are currently devoted), greater attention to weighing long-term implications, and the achievement of good design. For many users and operators of the system this will require changes in attitude.
Scottish Borders Council: Although a simple re-branding in itself is unlikely to bring about a culture change in planning, the underlying objective of the system is more accurately conveyed with the proposed name change.
Non Departmental Public Bodies
Disability Rights Commission ( DRC): The modernisation of the planning system has implications for the way in which the planning system works. The DRC recognises the pivotal role that planners will play to ensure the system delivers the key principles of modernisation. This will involve a change of culture in the planning system to achieve this.
Historic Environment Council for Scotland: The culture of change required to achieve the desired improvements will be reliant not only upon strong guidelines from the Planning Division, backed up by appropriate legislation but, increasingly, on the performance of local authorities. However, to be fully effective, it will have implications for all of the participants within the system. In the case of the historic environment this must encompass
- Scottish Executive , recognising the wider role that the historic environment plays in economic and social regeneration of communities
- Historic Scotland, whose inspectors, in the light of the requirement for pre-application discussions, would need to ensure that the advice given at that stage, and at any later stages, would be relevant to the nature of the development in terms of the wider objectives, and given informally without prejudice to later, more formalised, arrangements
- Local Authorities, recognising their requirement to be increasingly pro-active in the delivery of policy relating to the historic environment and being able, and willing, to resource specialist services as part of a speeded up planning system
- Applicants, who should be able to demonstrate at the time of making the application for any proposed development having an impact on the historic environment that the proposals are based on sound knowledge of the significance of the site or building in question; evidential supporting material should be a conservation plan for larger developments and a proper archaeological evaluation and recording of sites and structures; this should be in addition to any requirements for design statements, or masterplans for the larger sites
- The amenity societies, who may need to move from a presumption towards protecting the historic environment against development pressures, to supporting the role of the historic environment as the agent for regeneration, but who will need an adequate time frame in which to respond
To achieve the very necessary changes in culture, any modernised system must deliver the expected improvements. The present fallback position must be averted - of having to protect the historic environment only as a last resort through existing heritage protection legislation and through a range of non-statutory, outmoded and underfunded working arrangements. HEACS sees no merit in perpetuating an adversarial approach with consequential delays to the planning system, which can lead to the unfortunate impression being given of the sector as preservationist, and therefore against development of any kind.
Scottish Water: The paper notes the relationships between "those who operate the planning system, those who use it and those who are affected by the decisions which it takes". A reform of the way in which these groups interact will improve perception and confidence of the planning system. We support the vision documented and hope that Scottish Water will be involved at all stages in this process. There is scope for improvement in the quality of decision-making across the board, for instance a decision-making process should be defined to ensure decisions are based entirely on planning details. This would provide an increase of confidence to the system whilst supporting the culture change required.
Development Industry
Elphinstone Land: The White Paper recognises that the current culture in many planning departments is one of regulation, rather than an enabling one. The use of the term "development management" rather than of "development control" advocated in the White Paper is welcome and the complexity of this is recognised. This is where the statutory purpose would help to serve as a focus for such a culture change but this will also require the support of the professional organisations within planning and a culture change in planning education. It is not clear that the way this change it to be brought about, and the timing of it, has been fully examined and it will require coordinated efforts by the Executive, the local authorities, professional organisations and the development industry to ensure that it happens. Without such a culture change the aims of the White Paper will not be achieved.
Homes for Scotland: In our opinion, without a positive and significant change in approach by local authority staff, many of who are responsible for delivering the existing system, the new plan-led system will fail and plans will not be kept up to date. The proposed changes come against a background of increased workloads and at a time when planning authorities are struggling to both retain and attract highly competent and motivated staff. Many planning authority officials do not have adequate training or expertise to address matters such as the role of the market in housing or detailed matters such as planning agreements and their implications for development economics. Additionally, we understand that as part of the recent Scottish Executive financial settlement with local government, some local authorities are now seeking early retirement for staff over 50 years old. In summary, without the right culture, training, level and quality of staff in local authorities, including major improvements in the management and delivery of the planning system, we believe that these positive and encouraging proposals from the Executive will flounder.
Mactaggart and Mickel Ltd: The Executive appear to rely upon providing training for planners in local government, when in fact it may be that it is large sums of money that are required.
Walker Group (Scotland) Ltd: It is our view that a significant cultural change in planning is required. We support the Paper in its sentiments. However, we are not convinced that what is required is wholesale reform in order to deliver this cultural change. The perception of a "user of the planning system" such as the Walker Group is that the planning system is operated and implemented by planners who adopt a negative and sometimes hostile attitude towards the housebuilding industry. We have seen no evidence to justify criticisms of "land banking" and "over supply of housing land", yet these same comments arise time and time again. Cultural change alone would do more to reform the planning system than all of the measures contained within the White Paper. Cultural change would improve this stakeholder's perception of the system if; (1) planning officers were positive and indeed sought to approve planning applications subject to conditions rather than refuse planning permission; (2) planning officers returned phone calls and emails; planning officers viewed development proposals with a view to considering how they can be approved rather than how they can be changed; (3) planning officers recognised that the payment of a planning fee was not a penalty for proposing development, but rather payment for a public service which demands that they advocate both the pros and cons of a proposal; planning officers understood the legal test applied to section.25 via the City of Edinburgh case.
Other Businesses
Association of Electricity Producers: We welcome the proposal that those involved in the planning process should act responsibly and ensure it operates effectively. However, this should apply equally to developers, planning authorities and consultees. Developers of electricity projects have a very good track record of actively involving the public and local communities at a very early stage in the development cycle.
CBI Scotland: Successful reform of the planning system process will require new processes/procedures, but this will not be sufficient on its own. A radical shift in culture and 'mindset' on the part of every stakeholder is also needed. This is especially true of local authorities, where a combination of negative factors will have to be overcome. The problems are well documented: low morale, a historical focus on development 'control', a focus on bureaucracy rather than the intrinsic design value of a proposed development; skill shortages, inadequate training for local officials and limited financial resources. They have to be systematically addressed.
Scottish Chambers of Commerce: Welcomes the proposals to re-energise the planning profession. Local authority planners are often striving to maintain and improve a quality of service in trying circumstances, against a background of more applications, lack of financial resources, shortages of skilled staff, and increased public interaction often of an adversarial nature. Business in general fully appreciates the problems that can arise due to lack of key staff, hence the growing interest in incentive schemes, which could equally be applied to planning professionals. Delivering the proposals in the White Paper should help rectify this, improve the perceived standing of the profession and help to address the large number of vacancies in local authority planning departments.
Scottish Rural Property & Business Association: It cannot be over stated that Local Authority managers and planning officers will need to undergo a sea change in attitude and culture. This will involve re-training not only to acquire relevant knowledge about the new system, but also to think and operate in a completely different way. This training needs to reflect that local authorities must adopt different approaches between different rural regions - for example central belt and the more fragile rural areas require quite different approaches. The new planning system must be flexible enough to facilitate this. Local Authorities will require to be properly managed, motivated and incentivised in order to deliver. This will all take substantially higher resourcing, particularly in the short term, than is currently available. The White Paper indicates that this will be achieved through revised targets. There must be corresponding, meaningful rewards and sanctions. These are not detailed in the White Paper.
The Scottish Coal Company Limited ( SCCL): This measure is particularly welcome as there is a perception amongst many users of the planning system that the process has become more important than the delivery of the result, while the vision of planners as enablers has been lost in overly complex administrative procedures. The can-do mentality needs to be regained.
Unison (Scotland): Planners will welcome the recognition that their role is primarily visionary and enabling. Unfortunately the pressure on under resourced departments means that many are forced to concentrate on their regulatory role. We are disappointed that the White Paper concentrates its comments on culture change almost exclusively on planners and local authorities. If culture change is to succeed applicants, particularly those in the commercial sector also need to respond to the need for culture change.
Professional Organisations
RIAS: What architects regard as the most serious issue, the apparent inability of some local authorities to cope with their workload. In this context, 3 main factors operate.
- One is the complexity and quantity of legislation being issued by the Scottish Executive. It would appear that some Local Authorities simply do not have the staff resources to operate that legislation, the number of applications local authorities are handling is up considerably and there are some special pressure points, e.g. Edinburgh and the Lothians
- the internal systems within some local authorities mitigate against efficient processing of applications. This may be down to the "organisation culture" of these authorities.
- the difficulty of effectively dealing with 'consultees' such as highways departments and the public utility companies such as Scottish Water. These organisations are, none the less, an essential cog in the planning process and unless they are held accountable, will continue to frustrate the planning and development process.
RTPI Scotland: While this recognises that there is a range of stakeholder interest in culture change, we are concerned that it gives entirely the wrong impression that culture change in planning is something which somehow must be led by the planning profession and for which it is primarily responsible. The Institute does, however, strongly support culture change and the need for the profession to play its part. In the Institute's view, the stakeholder involvement in culture change is a complex one which needs to be carefully worked out on an entirely even handed basis. A clear strategy for culture change involving the key stakeholders now needs to be prepared as soon as possible.
Scottish Association of University Directors of Estates: While most of the changes announced are positive and should help promote a modem and vibrant Scotland, a modem and up to date planning system needs to be accompanied by a shift in the attitude of Scotland's planning authorities. Many still view their role as preventing, rather than assisting development. In addition, we have concerns regarding whether there are sufficient resources to deliver the reforms outlined in the White Paper.
SSDP: The Society gives its full support to the concept of change in culture and the move towards true and effective social inclusion in the planning function. The Society would welcome the opportunity to participate in the production of a Planning Advice Note on "best practice."
Planning Consultants, Architects and Lawyers
Collar, Neil: This is indeed key to making many of the proposals work, particularly since it is difficult to formulate workable sanctions. Much will depend on changes to attitude and approach. It is disappointing that the White Paper itself fails the culture change test. Changes are proposed to speed up local authority processes, but nothing is said about the need for the Executive to act more quickly. For example, why is it that the Executive so often have to extend the initial 28 day period for applications notified to them? Why does the proposal for processing agreements to set a timetable for determining major developments not also include the Executive's determination of national developments?
Humberts Leisure Consulting: Comment welcomed on need for planners to improve awareness and understanding of the needs of businesses.
Muir Smith Evans: The White Paper time and time again talks about a "culture change" being needed in order to deliver the prizes which are held before us. But this culture change must involve an understanding of the mechanics which drive the creation of wealth and 'added value' which in turn delivers all the other benefits we seek to enjoy in a smart and successful Scotland. Community involvement must encourage developers, not frighten them away to invest in another country. Developers and investors will change - they have to if they want to successfully navigate the planning system. We are not so sure about planning authorities (at both officer and member levels). Training and guidance will be essential if planning authorities are going to start taking open and balanced decisions on the degree to which a proposal does, or does not, conform to the development plan.
Paull & Williamsons: We think the clear statement of the primary role of planning - the promotion of sustainable, high quality new development, the fostering of the right development in the right places -is much needed. While we recognise the importance of the qualifications 'sustainable' and 'high quality', this statement will require a cultural change on the part of all those involved in planning, but particularly the officers and members of the planning authorities and also reporters in the Inquiry Reporters' Unit. For too long the planning system has been a vehicle for giving effect to local resistance to change.
Scottish Planning Consultants Forum: We believe that planning, as a professional activity geared to serve the national and local community, is an intellectually demanding task and one which is not currently fulfilled. We see in the White Paper the opportunity for the planning profession to rediscover its former role in connecting elected members to those they represent. In our experience true cultural change will require a raised awareness of the relevance and importance of planning as an activity.
Academic Bodies and Individuals
Lloyd, Greg Professor: The White Paper seeks to put into effect a broader culture change by all those concerned in the planning and development process. What this means in practice will inevitably be contested - but it must involve a transformation of the rights and responsibilities as they are currently discharged (or are not discharged) in the current land and development planning process. This is not only an ambitious and overdue innovation, but, in the overall context of the proposals set out in the White Paper, it is the very necessary pre-requisite to securing the intended modernisation of planning. Essentially, Scotland requires an informed, mature, visionary and engaged discourse around planning. This is essentially about introducing greater responsibility into the planning system by all those different interests concerned. Planning is about making choices (in space and places), and inevitably there must be trade-offs, and these have to be robustly debated by appropriate interests. Essentially the political debates at all levels around land use planning have to become more mature and considered.
Macaulay Land Use Research Institute: The cultural change required for the planning system requires significant investment in support and facilitation. Change will not happen overnight and it is unclear how this process will occur given that local authorities will have limited extra resources, and indeed much of the cultural change may arise within these organizations.
Community Councils
Currie Community Council: We would like to have seen the value of local representation and knowledge referred to in the "Culture Change in Planning".
Craiglockhart Community Council: There is no question that changes will be required to the outlook of all those involved in planning. Pre-application discussion is an interesting example of a procedure which may not always prove fruitful. The intransigence of a developer in response to reasoned, informed comment can very easily turn interested people into vigorous objectors for whom mediation is not an option.
Helensburgh Community Council: The authority councillors' Code of Practice should emphasise that the granting of planning permission should be for planning reasons, especially when against the recommendation of officers and / or when substantial objections have been raised.
Merchiston Community Council: Culture change must start with qualifications of professional staff in planning authorities. The success of many of the proposals in the White Paper depends on the expertise and creative perception of the professional staff. A review of standards set by University Departments of Planning and Architecture could identify the range of professional expertise required to develop a modern planning system for Scotland as now outlined in the White Paper and depending on visionary planners. It is for local groups (Community Councils etc) to accept that they will have a responsibility for, or indeed should insist on, taking a much more active role from the very earliest stages of the production of development plans ( i.e. we don't always wait to be consulted) so that, within this new plan-led system, we are therefore better prepared to consider and have a full say in any subsequent planning decisions.
Voluntary Organisations
Built Environment Forum Scotland: Significant culture change is required amongst all stakeholders in their involvement with the planning system, if objectives are to be met and quality outcomes improved. Aspirations need to be raised beyond minimal standards towards achieving a higher quality outcome (we need to move towards asking: is this good enough to approve rather than bad enough to reject?). This will require a shift away from reactionary development control processes, to be supported by building the confidence, knowledge and understanding of officers and elected members within local authorities. An enhanced expectation for quality needs to be understood by everyone including the public.
Cockburn Association: The Association strongly supports the Executive's ambitions for a less adversarial planning system. We agree that the emphasis in the planning system should be shifted from inquiries and legal proceedings to discussions and consensus building at an earlier stage. This cannot solely be achieved by a change in legislation but also requires a shift in culture on behalf of all parties: developers, architects, statutory bodies, planning departments, environmental groups, residents associations and community groups such as the Cockburn Association. In achieving such a culture change we support the Executive's ambition to introduce mandatory consultative procedures prior to planning applications and guidelines will be needed.
Gatehouse Development Initiative: Does anyone give our Councillors training in Executive policy? Have any of them ever read your policy documents such as the National Planning Framework or Sport 21? Could you insert in your Bill that all Councillors must attend a training course on the Executive's policy perhaps annually.
Greenhill and Church Hill Amenity Association: "Culture Change in Planning" is indeed an important issue. The difficulty, in our view, will be to achieve this to a meaningful degree without greater involvement by those proximately affected by developments: in short, third parties. Opportunity to comment alone will not bring this about. The present culture is basically "process-driven", and with an emphasis on content, rather than "quality-driven", with an emphasis on context. It will remain so until some countervailing influence is admitted.
Greenspace Scotland: The change in terminology from 'development control' to 'development management' is welcomed, as is the recognition that this will require a culture change and the need to equip planners (both current and the next generation) with the necessary skills, knowledge and competencies.
Inveresk Village Society: The problem in many parts of Scotland, including East Lothian, is that one party is dominant and there is no effective opposition on planning committees. The ruling party can do what it likes with little in the way of debate. As far as development control decisions are concerned the society is pinning more hope on the new local government voting system to change the culture and rebuild confidence than on what is currently proposed in the White Paper. We think that with a range of views being heard around the committee table and some proper debate on the issues then we will get much better decisions that reflect local opinion and are not pre-determined.
Planning Aid Scotland: The delivery of cultural change rests not only with the planning profession but also with other stakeholders, including the community. PAS has a uniquely independent perspective on stakeholder participation and an insight into perceptions held by the community. The White Paper goes a long way in addressing the current community concerns for a more transparent and accountable system. However, processes need to be accompanied by cultural change, which will take far longer to realise. PAS volunteers can and do play a valuable role in educating the community about their role and opportunities available to it. To achieve cultural change, opportunities must be provided for the planning profession to practice and enhance their communications skills. We would welcome the opportunity to formalise arrangements with the planning profession whereby planners who volunteer in our community training programmes are encouraged to do so as part of their Continued Professional Development ( CPD).
Quarry Traffic Monitoring Group: This is perhaps the most important element of the White Paper, notwithstanding the need for Third Party Right of Appeal (vide infra). The public perception is of a profession that is not particularly well informed, arrogant, complacent, often slovenly in its preparation of reports and resentful of any challenges to their decisions. Our experiences show that Elected Members are often too terrified to resist the recommendations of their planning officials for fear of incurring financial penalties. Moreover, few councillors are willing to risk alienating core staff and this in turn has led to a climate whereby the officials control the outcome of the determination. This is fundamentally undemocratic and has played a large part in bringing the system into disrepute. It is vital that the profession is refocused and re-energised to ensure high standards of performance and delivery.
Rural Scotland: Whilst we agree with the need for a cultural change in the practice of planning and in how it is perceived, we do not underestimate the difficulty of achieving this change in mindset, approach and involvement. Progress will need to be made across a number of different sectors including structures of local government, education, media and communications. Legislation may help by providing a system that ensures meaningful participation where citizens can see that their involvement is worthwhile. Requirements to give reasons for decisions at all levels, for wide definition of standing and effective use of hearings and environmental/planning tribunals may help but much will have to be achieved through non-legislative programmes.
Scottish Civic Trust (and Civic Trust Network): The most crucial issue is one of culture change. This needs to permeate through all areas of the planning system, especially the development industry. The statutory planning system forms only a part of the wider development/community-building process. All parties will need to embrace change to further the ambitions of elements of the White Paper, not least the development industry who have looked at it simply a hurdle to be negotiated rather than an important part of a wider community process. There needs to be a serious culture change within the planning system and planning professionals that moves us from the current "is it bad enough to refuse" to a perspective of "is it good enough to approve". There are serious skills deficiencies in local authorities to advance the Designing Places agenda and many planning committees are ignorant of design issues (the same might be said of the general public). This is the key issue in all of the White Paper and the one which has received the least attention. The planning system is judged on what happens on the ground.
Scottish Renewables Forum: We would welcome a culture change in the planning system and agree strongly that all users of the system have a responsibility to ensure its efficient operation. We find it regrettable, however, that developers are particularly highlighted as needing to reconsider their role in the public examination of plans, and their use once the plans are in place. This in itself highlights a culture change that needs to occur: that developers are painted as the 'bad guys' when the majority are responsible and those involved in the renewables industry in particular, proactively work with local communities from an early stage.
The Cramond Association: We would challenge the word 'culture'. What, simply, does it mean? The quality of processing must be measured, not only speed of process. Not only should funds be available to improve capacity to undertake changes but also to assist the community to play its part.
The Grange Association: The concept of culture change in planning outlined on page 31, but not directly alluded to elsewhere, appears to underpin the anticipated effectiveness and success of the proposals for modernising the system. We see the important changes as being "a return to … the task of creating a vision …" that is to planners taking a more proactive role; and "all users of the system (having) a responsibility to ensure its efficient operation". These will call for understanding and respect to be earned by all parties, at all stages in the process. We suggest that the Bill should contain some reference to continuing development of public understanding, in the same way as the White Paper refers to continuing professional development.
Private Individuals
Anonymous: Educational qualification for the preparation and control of the T & C Planning is at the heart of the planning process. No single professional qualification is acceptable. A winning multi-disciplinary planning team cannot be formed if the only available players are all left-backs. Multi-professional, multi-disciplinary teams are required for this multi-dimensional task. Team working to produce professional planning plans for the Scottish Executive and LPAs. This will require a complete overhaul of the present educational system.
Reeves, Dory Dr: Planners need to develop the skills of delivering sustainable economic growth alongside social justice, social inclusion and equality. A proportion of the planning grant could usefully be earmarked for CPD in this area.
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