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Responses to Questions Posed in the Consultation Paper
General Comments
12. A number of responses were very positive about the introduction of the Strategic Development Planning Authorities. Scottish Water were particularly positive about it stating "We welcome the development of Strategic Development Plans as they will assist Scottish Water in understanding the future demands on our infrastructure and impact on our delivery plans".
13. Some responses highlighted the need for proper links with other strategic planning vehicles.
14. The Royal Town Planning Institute ( RTPI) said that " we believe strongly that, where possible, strategic development planning areas should be defined to achieve synergy with areas, planning cycles and policies defined for economic and transport planning". The Scottish Environment Protection Agency ( SEPA) also requested that SDPAs should be aligned with Waste Strategy Areas ( WSAs). Its response states that "we anticipate that there are likely to be challenges ahead for the Agency in securing synergies between SDPAs, the WSAs and their constituent councils in implementing Area Waste Plans and the SDPAs, the Area Advisory Groups for River Basin Planning and their constituent Councils in supporting implementation of the Scotland and Solway Tweed River Basin Management Plans". Scottish Environment Services Association ( SESA) also had concerns about the poor fit of the SDPA groupings within Area Waste Plans and Strategic Option Review Groups. As a result, it felt that the SDPAs may lack the ability to adequately plan and account for strategic waste management planning decisions.
15. Another common concern raised in the responses was the disparity between the areas covered by SDPAs Regional Transport Partnerships. This related in particular to Falkirk and Clackmannanshire Councils.
16. The Strathclyde Partnership for Transport felt that Ayrshire should be included in the Glasgow City Region: "the 2001 census showed that nearly 20,000 people a day travelled from Ayrshire to work in one of the council areas within the proposed Glasgow SDPA".
17. Homes for Scotland felt that joint committees should co-opt representatives from major stakeholders, particularly the private sector, to serve in an advisory capacity.
Responses from the Residents of the Scottish Borders
18. Just over 50% of the responses received to the consultation were from residents of the Scottish Borders. The main concerns expressed about the proposed SDPAs was:
19. The Borders has different characteristics and societies to urban environments. A regular comment was " the borders is a rural area with a way of life, set of issues and problems that are in no way connected to the issues of Edinburgh, the Lothians and Fife" and "to have only 2 reps from this region on a mainly urban committee would negate input from our own councillors".
- This would add an extra layer of bureaucracy
- That the Borders has little or no links to Edinburgh
- Edinburgh would be able to dump all its problems onto the Borders
- The Borders would become an overspill for Edinburgh houses
- Matters relating to the Borders should be decided by those elected to represent the people of the Borders
20. A number of these respondents felt that the Borders would be forced into decisions which they were opposed to by the other members of the SDPA as one respondent stated "I would also worry that other areas could force development in a region where it is not required or wanted in that region, ie ganging up". Another respondent suggested that "We need a mechanism in the joint committees through which (a) policies that suit the 'town' authorities are not forced on the 'country' authorities and by which (b) decisions affecting any one authority area cannot be progressed against its wishes, where solid arguments exist to the contrary".
21. However, the responses received from Scottish Borders Council, Gavinton Fogo & Polworth Community Council and 1 individual were supportive of the proposals made in the consultation paper.
22. Gavinton Fogo and Polworth Community Council stated that "on the basis that the Strategic Development Planning Authority has no impact or influence over the development of local plans/planning matters out-with the designated area then we see no reason not support the proposed membership".
Question 1 - Do you support the proposed membership of the strategic development Planning Authorities?
Aberdeen
23. The proposed membership of the Strategic Development Planning Authority was supported by those who responded specifically about the Aberdeen City Region particularly Aberdeen City Council and Aberdeenshire Council.
24. Shetland Islands Council felt that it should be included in any discussions around the strategic planning for the Aberdeen area as it is its main link to the Scottish mainland. In its response it said: "we cannot stress enough how heavily we rely on Aberdeen and Aberdeenshire in terms of transportation links and goods and services so should be seen as part of the city/region as well. These links are important to the population of Shetland wishing to travel outwith the islands, in addition to those visiting the islands".
25. Concern was raised that, because only 2 authorities were to be involved, that the chair would inevitably occupy a difficult position where there was disagreement.
Dundee
26. The proposed membership of the Strategic Development Planning Authority was supported by those who responded specifically about the Dundee City Region.
27. However, a couple of respondents were concerned about how the split of Fife council would be managed between the SDPAs for Edinburgh and Dundee. It was felt that there was the potential for conflict between the two plans.
Edinburgh
28. The main issue raised was the inclusion of the Borders in the Edinburgh SDPA. This is discussed separately above.
29. As already stated above, concerns were raised about how the split of Fife Council would be managed between the SDPAs for Edinburgh and Dundee.
30. The Interim Edinburgh and South East Scotland Strategic Development Plan Joint Committee was concerned that the SDPA boundary is not consistent with the South East of Scotland Transport Partnership's ( SEStran) Area which includes Falkirk and Clackmannanshire. It was also surprised that the recently announced Scottish Enterprise arrangements for East and Central Scotland will have a different geography from either the SDPA or SEStran.
31. However, Falkirk and Clackmannanshire Councils did not seek inclusion in the Edinburgh SDPA. Stirling Council did not respond to the consultation.
Glasgow
32. The proposed SDPA for Glasgow was broadly supported by those responses which provided specific comments. The responses refer to the existing Glasgow and Clyde Valley Structure Plan as providing a good model on which to base the new SDPAs.
33. However, North Ayrshire Council wanted to be included in the Glasgow City region. It responded to question 1 stating that "North Ayrshire Council does not support the proposed membership of the Strategic Development Planning Authority for the Glasgow City Region as set out in the draft Designation Order (No1) (Scotland) Order 2007. North Ayrshire Council is not identified as a constituent member of the Glasgow City Region Strategic Development Planning Authority despite strong and developing cross boundary links with the Region. These links are particularly strong in terms of housing market areas, travel to work areas and access to services".
34. In addition, it requested that "the Scottish Government include North Ayrshire Council as a full member of the Glasgow City Region Strategic Development Planning Authority, failing which secondary legislation and statutory guidance, as referred to in question 6, must ensure that Glasgow City Region is required to have full and a meaningful consultation and extensive and interactive engagement with North Ayrshire Council".
35. East Ayrshire Council did not consider it necessary to follow a similar approach. It felt it would be appropriate that the SDPA, once formed, established full and meaningful consultations and engagement with the council.
36. Helensburgh Community Council and the Helensburgh Study Group proposed that Helensburgh be included in the Glasgow SDPA on the basis that, Helensburgh looks to Glasgow for its main transport links, employment, retail, entertainment, higher/further education, hospitals etc. Conversely, Argyll & Bute Council, within which Helensburgh is situated, did not call for membership of the Glasgow SDPA. It considered that issues could be dealt with appropriately through continued liaison with the relevant authorities.
37. Glasgow & Clyde Valley Structure Plan Joint Committee commented on the proposed exclusion of the part of the Loch Lomond and Trossachs National Park that currently lies in the structure plan area. It was concerned that the proposed SDPA excludes Loch Lomond, which it sees as an integral part of the metropolitan area, from its long-term development strategy and would result in its strategic development planning being controlled by a separate planning authority. It felt that "If it is accepted that the National Park Authority is an appropriate governance model for that part of the metropolitan area, there will require to be close liaison between the two bodies to ensure that the separate plans are integrated in their strategic thinking".
Other Areas
38. One respondent felt that there should be an SDPA covering the Inverness area as it is "rapidly expanding and has issues very different to those covering the rest of the Highland Council area".
Question 2 - Do you have any concerns about the proposed arrangements for joint committees?
39. Except for the responses from the residents of the Scottish Borders, which predominantly focus on the make up of the Edinburgh SDPA, the majority of the responses support the arrangements for joint committees.
40. Reponses about the Glasgow SDPA were particularly supportive of the make up of joint committees as it is based on the already established Glasgow and Clyde Valley Joint Structure Plan Committee.
41. One of the responses from the Borders suggests that due to the size and diversity of the Borders that each distinct district (Berwickshire, Ettrick and Lauderdale, Tweeddale and Roxburgh) should be represented by 2 council members from each of these districts. A similar idea was proposed by Helensburgh Community Council that if Helensburgh was included in the Glasgow SDPA that a member of Argyll and Bute Council should be included who is resident in Helensburgh.
42. One concern that was raised, which has been referred to earlier in this document, is in relation to the Joint committee for the Aberdeen SDPA and how conflict between the 2 authorities will be managed. Another concern that was raised about the Aberdeen Joint committee was that they may have difficulty resolving contentious issues and that "the usual solution to such an impasse has been to water down policy, or to draft it ambiguously or so as to be almost devoid of real meaning". A proposed solution was to appoint a fifth member either independently of the authorities involved or varied every 2 years.
43. Aberdeenshire Council felt that " it is important that the chairing arrangements be agreed locally between the Councils rather than there being an imposed arrangement". It believed that the chairing of the Joint committee should alternate between Aberdeen City and Aberdeenshire.
44. Another suggestion that was made was that each local authority should provide an expert who is independent of the planning authority and Scottish Government for councillors to consult with. It was also proposed that Regional Transport Partnership ( RTP) Lead Officers should be involved as statutory advisers on the joint committee with a similar role for Strategic Development Planning Managers on RTP Boards.
45. It was recommended that councillors that are to be members of the joint committee should receive training on strategic waste management issues and sustainable development.
Question 3 - Do you have any concerns about the proposed arrangements for the effective establishment of dedicated teams?
46. A number of respondents commented on the arrangements for dedicated teams.
47. West Dunbartonshire expressed concern about the ability of the smaller councils to cope with the workload of having to participate in completing an SDP and LDP. It considered that "from experience within the Glasgow & Clyde Valley Joint Structure Plan Joint committee considerable strain can be placed upon smaller authorities at times due to their smaller staffing levels and their ability to service relevant topic groups over and above development planning work within their own authority. It is therefore vitally important that in managing both the SDP and the LDP, the dedicated teams and Councils formulate realistic and dovetailed timetables for the preparation of their plans".
48. It was also suggested that the same dedicated teams approach does not need to be the same for each SDPA as they all comprise a different number of councils, population and area. Perth and Kinross felt that "the details of these arrangements should be kept flexible so that each authority can modify structures appropriately to suit their individual circumstances". This view was supported by a number of councils particularly those involved in the Aberdeen and Dundee City Regions. However, another response suggested that to maintain a degree of consistency between various stages of plan-preparation a core team should be identified rather than different staff being involved at different stages.
49. East Lothian Council had concerns about the costs involved in setting up dedicated teams: "The implications of recruitment, secondment and the backfilling of posts when staff are assigned to a dedicated team, as well as the costs of separate accommodation, require to be addressed, particularly if equal representation means equal share of costs".
50. A number of responses felt that the powers of ministerial direction that are mentioned within the consultation paper were a step back from democracy for a process that should be led by elected councillors (and which are set out in the Planning etc (Scotland) Act 2006, S.4(3)).
51. The responses from NESTRANS and SEStran felt that transport should be a core competence of officers in the team.
Question 4 - What issues do you anticipate in agreeing plan boundaries?
52. As has previously been stated throughout this analysis, the responses from residents of the Scottish Borders opposed the inclusion of the Borders in the Edinburgh SDPA.
53. The main issue raised in relation to the Edinburgh SDPA was how much of Borders and Fife should be included. This was seen as especially complex for Fife given its relationship to both Edinburgh and Dundee.
54. One respondent felt that to assist with the drawing up of the boundaries for each of the SDPAs that a clear definition of the city region in terms of travel time and distance to the city centre needed to be established.
55. A number of responses felt that Fife Council should decide its boundary split for Edinburgh and Dundee i.e. whether it is a 50/50 split or more in either Edinburgh or Dundee.
56. One respondent suggested that if agreement over boundaries could not be reached then Ministers should be brought in to resolve those issues and within at least 3 months.
Question 5 - Should funding for the SDPA be shared equally across the constituent authorities and if not why not?
57. The responses focussed on 3 main options for deciding how the funding of each SDPA should be split. There was fairly even support for either equal contributions or contributions based on either population or area covered by SDPA.
58. The first of these options was an equal split over the authorities involved. This would mean that they were all on an equal footing and no one authority would contribute more than another which could lead to a situation whereby the authority contributing the most money assumes greater power. One respondee felt that "funding should be equally shared, to reinforce the message that the SDP is a joint responsibility of each constituent authority, divorced from considerations of local responsibilities".
59. The second option put forward in responses was for the funding to be based on the basis of the population of the local authority areas that are covered. One respondee felt that "it is likely workload would be centred on the more populous areas, and therefore there is a reason to split costs on a population basis".
60. The third option discussed was for funding to be based on the percentage of the local authority area covered by the SDPA. This would mean, for instance, that if the Borders area was only 15% of the entire SDPA area then Scottish Borders Council would only contribute 15% of the cost of the SDPA.
61. It was also felt that because the authorities not included in the SDPAs would not have this additional burden placed on them those that were involved should receive extra money from the Scottish Government.
62. A number of the responses were concerned about the additional funding required to resource the SDPA. As one respondent stated "The statement that a redistribution of resources (rather than additional resources) will be required is based on the assumption that strategic planning has been adequately resourced to date. This is questionable in some parts of Scotland and additional resources may well be required. Aberdeen City Council has agreed, as part of a wider package of reforms, to significantly increase its resource for strategic planning but whether this will be enough will need to await the consultation on strategic development plan regulations and experience over the next few years. However, a more fundamental concern is that with SDPAs varying in size from 2 in the North East to 8 in Glasgow, there could be a significant gulf in funding. This may have unintended and undesirable consequences".
63. Another respondee stated that "it cannot be assumed that the establishment of the dedicated team will be cost neutral at council level. The experience in Glasgow and the Clyde Valley, for example, has been that constituent Councils make significant contributions to structure plan work, while a separate dedicated team carries out core tasks. In addition, there will be a number of overheads to be met such as providing dedicated accommodation, support staff and ICT. There is also the mandatory requirement for an examination in public, which has not been a feature of structure planning in Scotland for many years, and may give rise to additional costs".
Question 6 - What other issues would you like to see covered in the statutory guidance for SDPAs?
64. A number of the respondents used this question to summarise their views which have been discussed in the previous sections of this analysis.
65. In addition to this, one respondent stated that "it is important that the guidance gives a clear steer on the role and authority of the new SDPA".
66. A number of the respondents felt that if the SDPAs were not aligned with the waste, transport and economic zones then they should at least be required to engage with those groups in the preparation of the strategic development plan and any supplementary guidance. It was felt that the statutory guidance should include a requirement for SDPAs to consult with relevant voluntary bodies and the public. It was also suggested that the expertise of community councils should be utilised by the SDPAs.
67. One respondent suggested that the statutory guidance should make clear the relevance of the revised National Planning Framework to the drawing up of SDPs. It should also require SDPAs to take into consideration the development plans of neighbouring areas.
68. A number of respondents felt that there should be clear guidance on the definition of sustainability in terms of SDPs. It was also felt that sustainable rural development and rural enterprise in terms of SPP15 should be afforded special status in the preparation of SDPs.
69. One respondent thought that guidance would be helpful in relation to requirements associated with planning applications submitted to any of the constituent councils which may raise regional/strategic issues and any protocol for consultation between planning authorities and SDPAs on such applications and the role of the Scottish Government.
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