Select Committee on Environment, Transport and Regional Affairs Memoranda

Memorandum by SERPLAN (PI 33)

  1.  SERPLAN is the London and South East Regional Planning Conference: It is constituted by the London Borough Councils and the county, unitary and district councils in the county areas of Bedfordshire, Berkshire, Buckinghamshire, Essex, Hampshire, Hertfordshire, Kent, Oxfordshire, Surrey, East and West Sussex and the Isle of Wight. As such, it covers the whole of the area of the South East Government Office, part of the area of the Eastern Region Government Office, and London.

  2.  SERPLAN has the role of advising the Secretary of State on the contents of Regional Planning Guidance (RPG) for the South East (the SERPLAN region). In December 1998, SERPLAN submitted to the Secretary of State, its Sustainable Development Strategy for the South East covering the whole of its area (SERP500). This SERPLAN Strategy was consulted on in early 1999, as Draft Regional Planning Guidance, by the Government Office for the South East, under the merging new arrangements for the preparation of RPG that promote greater transparency and regional ownership. The Strategy was then subject to a Public Examination in May and June 1999 resulting in a Report of the Public Examination Panel published in October 1999.

  3.  This memorandum deals with Public Examinations into draft Regional Planning Guidance as produced by Regional Planning Bodies (RPBs), which is the area of activity of direct concern to SERPLAN. This was not covered in the list of questions received by SERPLAN, but I understand that the Committee wishes to cover such Public Examinations in its enquiry. It must be borne in mind that Panel Chairs in such cases, although assisted by Planning Inspectors as members of the Panel, would not necessarily be themselves members of the Planning Inspectorate. SERPLAN's case was perhaps peculiar in having as its Chair the retired Chief Planning Inspector.

  4.  The main points arising from SERPLAN's recent experience are as follows:

    (i)  All briefings to the Panel, including the commissioning brief/terms of appointment, should be made public at the earliest opportunity and certainly before the final preliminary meeting, after which there should be no more.

    (ii)  Some means has to be found to introduce to the Examination proceedings the weight and balance of opinion/evidence garnered through the written consultation procedures. Otherwise, as SERPLAN has seen to its cost, the Examination can be dominated by a vocal minority (albeit representing important interests) with a distorted picture resulting.

    (iii)  The Examination is intended to be investigatory and non-confrontational, but given the stakes involved, this was always going to be a vain hope. It would be better to acknowledge the fact that the draft RPG is being tested and that the RPB is inevitably in the position of the defence. Given the fact that the Panel will pick participants who can assist this testing process (ie predominantly critics and opponents), would it not serve to achieve a more balanced discussion to give the RPB the right to nominate some of the participants in the discussion? At the SERPLAN Public Examination the choice of participants was heavily weighted in favour of the major critics and there was no representation of the widespread support which SERPLAN's Strategy had received during its public consultation, both within and beyond the South East.

    (iv)  Public Examinations are daunting events for all concerned, particularly for non-professionals. It is likely they will become more so, as the big interest groups gear up and dominate proceedings as they do in Local Plan Inquiries. Regional planning is a pretty arcane process, but it is important that as wide a spectrum of opinion as possible is represented round the table. This really is up to the Panel, in how they select participants and how they conduct discussions.

    (v)  It costs a lot to participate fully in a Public Examination. At one point "Living Over The Shop" withdrew from the SERPLAN Public Examination because of funding problems. In the end they appeared, but the issue needs to be addressed. By way of example, participants in the South West RPG Public Examination are required to submit thirty copies of each submission—purely for the convenience of the Panel Secretariat, but at considerable cost to local charitable groups.

    (vi)  SERPLAN strongly endorses what is said in the second bullet point of the recent LGA Statement on Regional Planning, about the Panel reporting to the RPB, not the Government Office. The Panel must remain independently appointed, but its report should be to the RPB and be made public at that moment. This would greatly strengthen the sense of regional ownership of the Guidance as opposed to a feeling of it being imposed by Central Government. The RPB would be obliged to indicate to Government how it had taken into account the Panel's report in the final version of the Regional Guidance; but with the Secretary of State retaining arms-length powers of intervention.

    (vii)  There is also an issue of timing of the Public Examination in the overall process of producing RPG, It would be better for it to follow the first period of consultation on RPG. Two periods of consultation appears very long-winded and also heightens the impression that RPBs are really not to be trusted and that the whole process needs to be gone through again by Central Government.

February 2000

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