- We propose
that local planning authorities should adopt a spatial planning approach
to local development frameworks (Chapter 1). Do you agree?
1a. Would
you like to see any other information on the scope of local development
documents?
We
agree that local planning authorities should adopt a spatial planning
approach. However, there needs to be greater clarity about what is involved
and how it differs from what was done in the past and also of the different
roles of LDF’s and community strategies.
- Chapter 2 sets
out the main elements of local development documents – the core strategy;
site specific allocations; area action plans; proposals map, and supplementary
planning documents. Do you agree with the principles set out for each?
If you consider that any of these principles give rise to particular
problems in preparing local development frameworks, please make suggestions
to deal with them.
2a. The
core strategy.
2b. Site
specific allocations.
2c. Area
action plans.
2d. Proposals
map.
2e. Supplementary
planning documents.
We
have no specific comments to make on either the main element or principles.
There is a general concern which applies to other areas of the PPS,
particularly chapters 3 and 4, about the level of detail in the PPS
and the detail and potential for duplication in the related guides on
LDC preparation.
Overall
the new system appears considerably more complex than the current one.
- Chapter 3 sets
out the process leading to the preparation of local development documents.
3a. Are
the requirements for the statement of community involvement reasonable?
Should any requirements be added or removed?
3b. Are
the requirements for the statement of community involvement in respect
of avoiding discrimination (paragraph 3.1.10) sufficiently addressed?
If not, what alterations would you suggest?
3c. Does
the statement of principles for the local development scheme provide
the right level of prescription to enable a firm programme to be prepared
for the preparation and adoption of local development documents?
See
general comment on Chapter 2 above – given that the requirements are
part of the regulations what is set out in the PPS does not appear unreasonable.
The process for producing statements of community involvement including
examination adds another stage to the process of development plan preparation.
On
3c the principles appear reasonable although it is not clear what is
meant in para 3.2.3 iv) on providing "an explanation of the relationship
between development plan documents".
- Chapter 4 presents
the requirements for the preparation of development plan documents and
supplementary planning documents. Are the stages set out with sufficient
clarity? If not,
4a. What
additional requirements need to be considered for development plan documents.
4b. What
additional requirements need to be considered for supplementary planning
documents?
4c. Are
the criteria for the assessment of soundness of the plan (paragraph
4.4.8) comprehensive? Should any considerations be added or removed?
4d. Are
the sections on monitoring and review (4.8) comprehensive and clear?
If not, what alterations would you suggest.
See
general comment on chapter 2 above.
The
emphasis on community involvement is welcomed although there appears
to be an assumption that conflict can be resolved early in the process
prior to formal submission of proposals. In paragraph 4.4.2 it says
that local planning authorities should not propose changes to the document
prior to examination. This raises the question as to how local planning
authorities are to be seen to respond to consultation and at examination.
As the Inspector’s report is to be binding this appears to reduce the
potential for the local planning authority to influence the final form
of the document. This goes against the grain of building consensus and
trying to negotiate on objections.
Paragraph
4.3.4 could usefully make reference to the local transport plan.
Paragraph
4.4.3 is odd as it requires the Inspector "to prepare recommendations
which will be binding". In what sense will what the Inspector says be
recommendations? The PPS should explain why it is considered necessary
to make the Inspector’s report binding.
There
is a concern about paragraph 4.4.6 which states that after the commencement
of the Act LDDs will no longer need to be in general conformity with
structure plans (see paragraph 15 of main report).
- Chapter 5 deals
with transitional arrangements. Is this clear? If not, what other information
should be provided?
See
comment in main report.
- Annex A provides
definitions. Do you wish to suggest any amendments?
6a. Is
the list of suggested components of the proposals map set at the right
level? Do you wish to suggest any amendments?
No
comment.
- Annex B provides
advice on other subjects with which local development frameworks will
need to relate. Do you have any comments on the content of sections
on:
7a. The
community strategy?
7b. Resources?
7c. Infrastructure
provision and utilities infrastructure?
7d. Transport?
7e. Hazardous
substances and air quality?
7f. Are
there any omissions to the subjects on which policy needs to be provided
in this statement?
See
comment under 1 on the role of county community strategies and LDFs.
The
sections on resources and infrastructure provision seem weak. One of
the major criticisms of the current planning system is that it is ill
equipped to ensure that necessary investment in infrastructure, transport,
services, etc is provided at the right time. There is too much reliance
on section 106 planning obligations which are time consuming to secure
and give rise to public concern over lack of transparency. See response
in the main report to the consultation on planning obligations.
Consistency
between LDDs and LTPs is crucial (paragraph 5.1.3). However, given that
LTPs operate at a sub-regional level with schemes and policies inevitably
crossing and transcending district boundaries, the PPS should give more
guidance as to how this consistency is to be achieved at the county/sub-regional
level.
- Annex C provides
a list of suggested consultees. Do you have any amendments to suggest?
No
comments.
- Are there any
other matters in relation to the preparation and content of local development
frameworks that you would like to see in this statement?
See
main report.
- Do you have
any other comments on this statement?