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Select Committee on Transport, Local Government and the Regions Appendices to the Minutes of Evidence

Memorandum by Unison South West (PGP 58)



  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.


  2.1  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 hours.

  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 of Dean.

  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.



  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 Councillors.

  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.


  4.1  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 planning system.

  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 Committees!


  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 process—our 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 first.

  5.4  The Green Paper proposes a fundamental change in the development control process—though maybe this isn't before time—but 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 frameworks

    —  Lack of references to transport planning and European planning in our region

    —  the limited number of skilled planning staff available

    —  lack of consistency for developers across region

    —  lack of accessibility by stakeholders: business, voluntary and community sectors


  7.1  UNISON requests that the clear wishes of Members in Planning Departments be put across to Government as follows:

    —  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 place; and

    —  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., MRTPI

4 March 2002

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