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ITEM EX6 - ANNEX A

EXECUTIVE – 23 DECEMBER 2003

GOVERNMENT PLANNING POLICY STATEMENTS

Planning Policy Statement 11 (PPS11) – Regional Planning

  1. Paragraphs 1.17 and 1.18 set out the expected format of the regional spatial strategy (RSS). Does this cover the right key points or do you think that there should be changes or additions?

    2. No comment.

  2. Paragraphs 2.8 to 2.10 discuss the relationship between the RSS and other regional strategies and the need to join these up. Do you have any suggestions about ways of securing better integration or other examples of good practice?

    3. There is a lack of clarity over which strategy takes precedence if there are points of conflict.

  3. Chapter 2 and annexes D and E stress the importance of community involvement and partnership working in the RSS preparation process. Is the current balance between procedural policy and guidance right at the moment or does this need changing? In particular:

    1. Paragraph 2.21 and paragraph 8 of annex D request the RPB to hold a public conference to seek agreement to the issues identified for the review. Should this requirement be retained?

    2. Paragraph 21 of annex D encourages the RPB to establish a formal group, chaired by someone from outside the RPB or a local authority and with a membership representative of the community, which is consulted at key milestones on the road to the draft RSS revision. Should this guidance be a requirement?

    No comment.

  4. Paragraph 2.14 refers to the role that it is anticipated strategic planning authorities may play in leading sub-regional studies. Should we include more on how to make these arrangements effective and if so do you have any suggestions?

    5. Paragraph 2.14 says that the RPB should consider whether it would be appropriate. It is considered essential that strategic planning authorities have a lead role to ensure effective commitment to partnership working. See also comments in main report (paragraphs 21-23) about the role for county councils.

  5. Paragraph 2.17 lists areas of work where RPBs may wish to enter into partnership arrangements with strategic planning authorities. Do these highlight the right areas of work or should there be changes or additions?

    6. In general it is considered that the right areas of work are highlighted although there are concerns about advising on conformity issues and major planning applications (see paragraph 21 of the main report).

  6. Paragraph 2.20 sets out the key features of the project plan for the RSS revision and paragraph 6 of annex D elaborates on this in relation to community involvement. Does the current text adequately describe the features of the project plan or are there others that should be included?

    7. There is a need to ensure that it covers key areas of work that may need to be carried out and how these interrelate and to set out a realistic timetable for achievement.

  7. Figure 2.1, the diagram of the RSS revision process, sets out a timetable from start to finish of thirty-two months. Is this in your view about right, too long or too short? If too long, how might we be able to speed the process up further? If too short, where in the process and on what grounds should we allow more time?

    8. The timetable is considered to be very ambitious given the emphasis on community involvement and the overall complexity of the process.

  8. There is currently no requirement for the draft RSS to be advertised in newspapers (see paragraph 2.31). Should there be? Do you have other suggestions beyond those in paragraph 28 of annex D about how the RPB can best publicise the draft RSS?

    9. Yes. Should look to good practice by county councils in consulting on structure plan proposals and encourage stakeholders to disseminate information through their networks.

  9. Do chapters 1, 2 and 3 provide adequate procedural policy advice or are there other areas where we should set out procedural policy. If so, what are these?

    10. Where a structure plan gives a particular sub regional dimension which is not addressed in the RSS or where an LDF has not been prepared for an area.

  10. Does paragraph 3.2 adequately describe the content of the annual monitoring report or would further guidance be useful in an annex? If more guidance would be useful what should be included?

    11. Paragraph 3.2 should perhaps refer to implementation of the RSS in line with purposes and policies of the RSS. The paragraph does not really address the content of a RSS as such – may be helpful if an annex referred to good practice.

  11. Do chapters 1, 2 and 3 provide adequate procedural policy advice or are there other areas where we should set out procedural policy. If so, what are these?

    12. No comment.

  12. Are the main aims of a regional transport strategy set out in annex B between paragraphs 3 and 4 and described in more detail at paragraphs 19 and 37 right? If not, what changes or additions should be made?

Annex B Para 3, Main Aims ‘The RTS should provide:’

Fifth bullet - this aim seems not to be clear in expressing what the RTS can achieve. It would be better to distinguish measures that are to be identified at the regional or sub-regional level from locally determined measures. The term ’accessibility to public transport at the regional level’ is unclear and appears not to be explained or used elsewhere in the document.

- Suggested alternative wording:

    • a public transport strategic framework to identify the regional and sub-regional measures that are deliverable and will support the spatial strategy, also to give guidance for achieving integration across the region, expanded travel choice, improvement of access for those without a car and accessible new development;

Para 7

Robust analysis of transport issues in relation to the intended regional spatial strategy, as indicated in the fifth sentence, is strongly supported as part of the formula to ensure that the RTS will be deliverable. The final sentence places too great an emphasis on the use of completed studies, such as the MMSs, which were specified for a particular purpose and are limited in their scope. Reliance on these would compromise robustness of the RTS.

- It is suggested that ‘represent a substantial source of information to inform’ should be replaced by ‘should be taken into account, but should not be relied upon for’

Para 31

From this paragraph as written it appears that the strategic framework acts at just the regional and sub-regional level, but this is not true for ‘access to jobs’ at the end of the paragraph since paragraph 18 clearly refers to accessibility planning as a local matter and paragraph 32 too implies that the framework extends to the local planning level. The paragraph should make it clear that the framework generally acts at all planning levels though ‘access to jobs’ is a more local matter.

- Therefore it is suggested that ‘a regional or sub-regional level‘ be replaced by ‘the regional, sub-regional and local levels’ and that ‘and enable those without a car to have greater access to jobs and key services’ be replaced by ‘and to improve local access for those without a car to jobs and key services’.

Para 32

There needs to be an aim for the LDFs to facilitate public transport development. This will include making land available for transport networks and interchanges as well as guiding the location of development to aid the improvement of public transport accessibility and services generally. This should be incorporated at the first bullet point. The example ‘such as encouraging development near public transport interchanges’ does not help the generality of this aim.

- It is suggested that the aim in the first bullet be changed to ‘give transport and to improve local public transport accessibility through the location of new development’; also that a sentence be included on the lines of ‘The LDFs should be integrated with the LTP and should reserve land required for transport measures.’ The example ‘such as encouraging development near public transport interchanges’ should be deleted.

Para 35

As written this paragraph fails to recognise the importance parking policy can have for managing traffic demand.

It is suggested, at least to avoid exclusion of this function of parking policy, that the words ‘and other aims of the RTS’ be added to the end of the first sentence.

    xiii. Does the consultation document, and in particular annex B, place sufficient emphasis on the integration of transport and spatial planning at the regional level? If not, what else should be added?

    Annex B

    In order to provide satisfactory integration between transport and spatial planning existing problems and trends need to be addressed at least as much as how best to arrange and make provision for development pressures. The RTS guidance should recognise this by requiring existing problems to be catalogued, including problems in transport infrastructure and services, unsustainable trends and areas of potential increase in activity where the use has been committed and the location is unsuitable in terms of current assessment. Without a full recognition of existing problems it is unlikely that the proposed strategy will be robust.

    One specific suggestion on deliverability of the RTS is made above for paragraph 7. Deliverability of the strategy also needs to be tested in terms of the availability of finance for the measures required.

    xiv. Is the guidance on the conduct of examinations in public at annex C sufficiently comprehensive or are there areas where further guidance would be helpful? If so, what are these?

    The guidance appears to be very comprehensive in some respects. (Indeed, it seems ironic for central government to be providing guidance on seating and eating arrangements at such examinations, while remaining silent on issues such as how the proposed new system should allocate having to the district level.) Planning authorities are not included in the list of likely participants for the examination in public. Paragraph 19 says only that there may be occasions when a representative or representatives of groups of local authorities may be invited in view of the matters to be discussed. There should be a firm indication that appropriate local authorities should be invited to be represented at the examination particularly where there are areas of conflict eg between a strategic authority and the RPB.

    xv. Paragraph 20 of annex D draws attention to the importance of involving harder-to-reach groups and provides advice on how this might be achieved. Views should be welcome on how else these groups might be effectively involved, including whether any of the procedures set out in this PPS should be refined.

    No comment.

    xvi. Should there by any additions to or deletions from the list of bodies at the end of annex D that the RPB may want to consult when preparing an RSS revision?

    No comment.

    xvii. Do you have examples of best practice in partnership working or advice on the principles which should be followed, relevant to annex E?

    No comment.

    xviii. Is the list of proposed national core indicators at annex F correct or should there be any changes or additions?

    Housing land supply is an area that is not covered. However, it should be the case that relatively few core indicators are listed and each region is left to establish what the key areas for monitoring are.

    xix. Are there any other comments you would like to make that cannot be accommodated as answers to the questions above?

See comments in main report.

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