Memorandum by Unison South West (PGP 58)
THE PLANNING GREEN PAPER
The need to retain and strengthen a forward
looking plan led system of which the Structure Plan, Local Plans
and Development Control comprehensively represent the strategic
and local components is clear. The case for change has not been
made in relation to the abolition of the development plan functions
and UNISON seeks adequate justification before supporting changes
that will further undermine the essential role of Local Government
and its ability to plan for the future of local communities.
1.1 The Government Green Consultation Paper
"Planning: Delivering a fundamental change" (published
by DTLR on12/12/2001) has raised a number of important TU issues
for workers in the Local Authority planning system of this region.
1.2 The proposal to abolish Structure Plans,
if implemented, will remove the power to control development,
which Local Authorities exercise and account for through the democratic
process in their areas. Counties and Unitary authorities prepare
Structure Plans and if the proposals are implemented, will lose
the ability to deal directly with a number of key needs in this
Region. These include strategic consideration of industrial development,
housing provision, conservation, social infrastructure, and responding
to the local requirements within a vast, peripheral and largely
rural area of five million people.
2. THE MAIN
2.1 The South West Region stretches from
the Scilly Isles to Tewkesbury, which is closer to Scotland than
it is to Penzance! Put another way London to Brussels takes two
and a half hours by train; London to Penzance five and a half
The needs of the area differ widely, from the
poorest, most remote and disadvantaged eg Cornwall, Rural Devon,
Dorset, Somerset, to the affluent, but at risk, areas of Wiltshire,
East Dorset, and Severnside, with Gloucestershire and the Forest
As an example of the officially acknowledged
needs of this diverse region, the bulk of the area includes substantial
Objective 1 and 2 European Funding Assistance, LEADER+ and massive
support from the CAP and CFP funds.
2.2 A number of dedicated UNISON members
are employed by Counties and Unitary Authorities to help their
communities cope with their own particular strategic planning
and development needs under the guidance of Government through
"Strategic Planning Guidelines". They work within a
planning system that relies on full co-operation with colleagues
in Districts who prepare detailed Local Plans and process Planning
Applications from the public in a well tried system based on full
collaboration on all levels of local government to work effectively.
They fear that in abolishing the Structure/Local Plans system,
the strategic function work will be taken up by default at regional
level by as yet unelected bodies, unaccountable to the communities
they serve. Moreover the changeover will involve additional public
reaction and disenchantment with remotely taken decisions specifically
on controversial matters, particularly where previous experience
in communities is lost through wide transfers of staff or growing
shortages of specialist planners.
THE GREEN PAPER IMPACTS ON THE ABILITY TO
3. DO THE
3.1 The Green Paper makes proposals based
on the experience of the London region and the Home counties.
It applies the lessons to other areas, particularly the South
West, without consideration of the importance of the strategic
planning role exercised through the Counties/Unitaries in supporting
tailor-made strategic planning for local conditions in partnership
between Counties and Districts and with Unitary authorities.
3.2 The Green Paper advocates, without giving
any reasoning or justification, the abolition of the Structure
Plans, each of which is prepared by our members on behalf of democratically
elected Councils. It supports a transfer of the strategic planning
function to Regional (and as yet non-elected bodies) which would
result in the greatest measure of transfer of power and responsibility
to Central Government civil servants ever experienced in the UK.
It goes against the European Union concept of subsidiarity in
Government where the lowest effective level needs to be consistent
with the types of decision being made.
3.3 In a bid to accelerate Planning decisions
apparently to appease Private Sector percieved needs, land will
be developed apparently more quickly than at present and local
communities will have less say in the process. The gain may prove
to be illusory simply because the planning system is merely one
stage on the complex process of development. The current Structure
Plans and Local Plans system is certain, quick and carries both
the local communities and government overall approval. Decisions
on commercial/industrial development in future will be taken at
Regional level with citizens being forced to raise matters of
development in Parliament as opposed to locally through their
3.4 In addition to the proposed shift of
responsibilities away from democratically elected Councils, UNISON
is most concerned about the ability of staff to deliver the system
efficiently and consistently across the Region. As an example,
current Regional Planning Guidance (RPG) is provided mostly by
a number of staff in each of the County/Unitary offices, whose
main duties are the preparation of Structure Plans that are the
blueprints of development in each geographical county in the SW.
The policies set out in these documents are then incorporated
into detailed proposals in Local Plans (District function) which
are the practical basis for the planning application decisions.
Both of these Plans are submitted to public scrutiny before approval
and are constantly revised to ensure they are robust tools for
evaluating and approving a whole range of possible development
proposals for any area.
4. WHAT IMPACT
4.1 Planning Staff are most concerned that
the Green paper will result in their workplaces either being transferred
to a Regional body or indeed remaining in the same place, but
in reality working to a distant and unaccountable quango. The
brutal truth is that Local Authorities currently have insufficient
qualified planning staff to share with any regional arrangement
and that if this expertise is to be spread too thinly over the
region, it will fail to provide anything like an adequate and
fast responding strategic planning system in the future.
For example: Devon County Council has about
five staff currently preparing and reviewing the County Structure
Plan, in addition to other colleagues in Plymouth, Torbay and
Dartmoor National Park. At the time of Local Government reorganisation
(April 1998) planning staff had to be decanted from Devon County
to the new Unitary Authorities but the County still had to provide
staffing for a continuing County and District two tier planning
system. Adequate staffing, however, could only be provided by
actually increasing the number of posts across the authorities.
In Devon the Structure Plan applies throughout the Geographical
County and is used in the preparation of Local Plans in each of
eight Districts and two National Parks (one of which is mostly
in Somerset). District colleagues in Devon are hard pressed to
draw up their Local plans, with the result that complete and updated
coverage is currently a hard target to achieve.
4.2 This pattern is repeated throughout
the region, and would not be improved if the simplistic approach
to substitute Structure Plans by the complex and untried Green
paper alternatives were to be implemented as set out.
4.3 Staff in County Councils and Unitary
Authorities have delivered on the current system since 1974; this
has provided strategic planning certainty and ensured consistency
for a clear interface between strategic and local decision making.
It has also allowed for local input to be considered in the many
major planning choices which have arisen throughout the Region.
4.4 Staff acknowledge that the Development
of Regional Planning Guidelines has provided a "more strategic"
level of overall planning, reducing the need for Local Authorities
to second "guess" central Government intentions for
regional development. These have recently been fully incorporated
in Structure Plans with positive effect on the understanding of
issues to be determined at local level. The process is fully subjected
to consultations, and the "Examination in Public" ensures
that the issues are fully debated at the local level and by all
concerned. In this process County Councils and Unitary Authorities
are recognised by all local bodies as the appropriate focus of
strategic planning decisions.
4.5 Staff are concerned that the proposed
system apparently envisages more than 50 Local Development Frameworks
in the South West, with Action Plans, Master Plans, Regional Spatial
Strategies, Sub Regional Strategies etc all constantly under review:
will they all get done? Will they "add up"? Will they
all be really up to date at any particular time? Will they take
any less effort to prepare than the current system? Who will decide?
Will the process reduce duplication?
4.6 The answers to these questions, staff
point out, are not given in the Green Paper but as experienced
members in the Planning System they doubt very much that this
represents more than a wish to improve matters. They really doubt
from experience of the system they currently operate, that the
outcome will actually meet the optimistic expectation of the authors
of the Green Paper.
4.7 While the Green paper seeks changes,
and the persons working in the current system would agree that
change is needed to improve the system, the extent to which the
real issues at sub-regional level and Regional Level can effectively
be tackled is limited. Energies could be better employed to improve
the current working of the system. Green Paper changes will require
additional resources and cause disruption to a system already
providing effective strategic planning. Moreover if the Green
Paper approach is blindly followed into a new untried and potentially
inconsistent framework there will be considerable problems to
tackle if we are to retain a credible, functioning, strategic
4.8 While there is still considerable urgency
to deal with the overcoming of peripherality and remoteness in
this region, and difficulties of finding planning solutions for
the future well being of our cities, towns and settlements, particular
to our Counties; the paper is silent on a number of critical aspects.
In the European context, it is nowhere suggested that transport,
major infrastructure or trans-regional approaches should be in
line with the European Spatial Development Perspective (ESDP);
and that the Trans European Networks (TENS) and Local Transport
plans should be considered within the physical planning framework,
as is currently the case with the evolving Structure Plan system.
4.9 Because the paper is "green"but
no alternatives have been provided, the paper makes no attempt
to examine modification of the existing Structure Plans/Local
Plans system, gives no clear evidence to support its main assumption
and contentions that the current plan led system is too complex
and too slow.
4.10 It proposes instead an ad hoc
decision making approach, uncertainty and key decisions to be
made "outside" the system, presumably led by civil servants
instead of Elected Local Authority members through locally accountable
Committees. These have operated within a Planning system that
has been fully tried and tested at local and sub regional levels
over the last thirty years.
4.11 What is proposed is neither less complex
nor certain. Does it remove a tier of government? Will it be quicker?
Is it democratic? The Green Paper reveals a fundamental lack of
experience by the authors of how the system has worked over the
last 30 years. Consequently any decisions to be taken on this
superficial basis lack the rigour expected by practitioners and
experienced local authority councillors alike. It appears to be
a crude attempt to find justification to abolish a fundamental
component of County and Unitary Planning functions authorities
and an additional excuse to remove that level of government altogether.
4.12 UNISON's support for Community Plans
and local strategic partnership is based on the experience gained
by our members who for many years have worked the current planning
system ironing out its inconsistencies at local level. We therefore
suggest that before a new approach is adopted considerable technical
work needs to be done to anticipate and remedy the gaps that this
untried new approach may throw up. But the Green Paper needs to
address other aspects: Community involvement in Local Development
Frameworks and consultation is an opportunity for UNISON members
to assist in improved community focus.
4.13 The Green Paper, however, on the one
hand attempts to provide for neighbourhood assessment at community
level, but on the other fails to support the democratic council
decision-making process; it pushes decisions to regional level
where contention can be removed, limiting local accountability
and local inputs to unacceptable levels in a democracy. It has
the signs of having a pedigree based on similar superficial proposals
prepared at the time of Nicholas Ridley when the "Private
sector could do no wrong" and development was approved if
ministers felt this was desirable in the interests of accommodating
the wishes of the more insistent developers.
4.14 This approach will add nothing to the
transparency of the process and could conveniently ignore local
factors, possibly without the "embarrassment of interference"
from sustainable, socially excluded and turbulent groups, which
have normally operated by focusing on the Local Authority Planning
5. LOCAL PLANNING
5.1 UNISON Planning Officers in Development
Control also believe that there are implications for District
Councils, especially where local plans preparation and revision
are concerned. Unison members anticipate public local participation
in the planning process will diminish and speed of decisions on
planning applications will be at the expense of careful consideration
of all aspects related to an application. Our members in development
control work very closely with local plans teams and structure
planners. We think planners in District Councils should also be
heard and comment on the Green Paper.
5.2 The Green Paper states that there is
a need to simplify Local Plans and the plan adoption process.
The aim is to reduce the number of policies, though it acknowledges
that there is a need for more specific site development briefs,
area master plans, design statements etc. How much above this
very localised level will become of regional competence?
5.3 There are clear staffing issues here
as well as the loss to accountability processour members
point out that we don't as yet have a democratically elected regional
government.It seems to us that there are elements of putting the
cart before the horse in the Green Paper that require to be addressed
5.4 The Green Paper proposes a fundamental
change in the development control processthough maybe this
isn't before timebut it also promises faster delivery at
a time when there are major problems with recruitment and retention
of staff throughout the South West Region.
5.5 This shortage is in all areas of Planning
including Development Control. Surprisingly the Green Paper does
not consider matters such as permitted development limits to assist
in securing a more rational consideration of major planning applications.
6.1 The Green Paper raises the following
matters of concern:
Potential democratic deficit
Increased number of plans
Is there capacity at regional level?
Lack of balance of wealth creation
with environmental and social factors
From regional level to 45 Local Development
Lack of references to transport planning
and European planning in our region
the limited number of skilled planning
lack of consistency for developers
lack of accessibility by stakeholders:
business, voluntary and community sectors
7. WHAT ARE
POINTS UNISON SHOULD
7.1 UNISON requests that the clear wishes
of Members in Planning Departments be put across to Government
seek retention of direct District
and County/Unitary accountability;
ensure that strategic planning in
this Region be dealt with by County and Unitary authorities;
that a Regional Elected Assembly
be put into place before a radical shift of subsidiarity takes
that the interests of accountable
Planning functions in the Community are best served by strengthening
the ability of local planning staff to serve their elected councils.
Prepared on behalf of UNISON, South West Regional
and Local Government Committees.
Roberto Franceschini, BSc(Econ), MA, Dip.TP.,
4 March 2002