Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by the Countryside Agency (PGP 29)



  1.  The Countryside Agency has a statutory role in advising ministers on the social, economic and environmental well-being of rural areas. We summarise our role as working to achieve the very best for the English countryside—its people and places.

  2.  We are pleased to submit evidence on the recent planning Green Paper to the House of Commons Select Committee. Our evidence emphasises the need to attain social, economic and environmental objectives for rural areas, and to make sure that these objectives are reached together. The importance of integrating rural policy is our main message.

  3.  The Select Committee has asked for evidence on a range of proposals outlined in the Green Paper. We have views on most topics identified for discussion but we concentrate here on two areas where we have a particular expertise. We are grateful for the opportunity to expand our views on:

    —  the scope and nature of local development frameworks and their links with the plans of other public bodies;

    —  National Parks and Areas of Outstanding Natural Beauty (AONBs) and the opportunities they provide to promote integrated rural policy.

  4.  Many of the Green Paper proposals and those of the associated documents on planning obligations and major infrastructure projects are of a detailed nature. We do not wish to add to our earlier submission to the Department but we would be pleased to answer questions or provide further information on any of our recommendations.


  5.  The primary purpose of current development plans is to set out the intended land uses for a defined area and to provide a sound policy basis for the control of development. This role will apply equally to the new suite of local development frameworks and we support it.

  6.  The Green Paper also offers good opportunities to give local development frameworks a more positive purpose:

    —  to show how policies can be translated into the sort of sustainable proposal that the area needs;

    —  to co-ordinate their proposals with those of a range of other public bodies to provide a truly integrated strategy for local areas.

  7.  Translating policy into sustainable proposals. We offer three connected points on how local development frameworks should operate and evolve.

  8.  Our first point expands the philosophy behind local development frameworks, which should carry the implicit notion that development is acceptable almost anywhere provided that it fits the vision of the plan, meets the sustainability criteria appropriate to its location, and achieves high enough standards.

  9.  The more sensitive the area, the more demanding the criteria. National parks and AONBs, for instance, would continue to be safeguarded through the strength of the criteria that will be applied to development proposals. This approach should apply to green belts, too.

  10.  This type of criteria-based approach should not need a land-use distribution plan that identifies all development sites. Local development frameworks should have a key diagram which shows the location of significant changes in pursuit of the vision. This might show either the general location of change or major target sites.

  11.  Our second point expands the proposals for master planning and introduces the idea of "concept statements". This approach maintains that simple land allocations are unlikely to lead to sustainable development without further guidance. In other words, allocating land for "housing" or "employment" gives no indication of the type of development required to meet local needs and leaves potential developers second guessing the local authority's thinking. As a consequence, much time is spent in negotiation and appeals when proposals come forward for approval.

  12.  Rather, local authorities should use their local development framework to introduce a "concept statement" which would give a clear indication of what they expect from a given site. So, instead of "housing", the plan would express matters such as housing type, tenure, density, provision of open space, mixed use, principles of design and layout and so on. A concept statement should be accompanied by an indicative plan showing how the development might proceed, but set out in the form of guidance rather than prescription.

  13.  In this way, the local development framework would clearly express the local authority's requirements for a development site and developers can respond accordingly with their proposals. Clarity so early in the planning process will diminish the time and effort needed in negotiating planning approval.

  14.  The South Hams District Council has recently introduced this approach in its local plan review.

  15.  Our third point recommends that planning authorities should be given the duty of implementing their plans. Plan making is not an end in itself and local authorities should be judged on the extent to which they achieve the changes needed to meet their vision, strategy and policies. Tools available to local authorities include the co-ordination of public spending plans and the use of compulsory purchase powers to overcome obstacles to implementation. Clear delivery targets should be established, together with the necessary action to deliver the local development framework.

  16.  Co-ordinating policies. Development plans are currently prepared in isolation. It is true that all incorporate a wide range of views drawn from consultation stages and that the more ambitious authorities have made good connections with the plans and strategies of others. But this sort of good practice must become better practice, and better practice must become the norm.

  17.  We recommend that the Green Paper proposals should be extended to include a fully integrated planning process in which local development frameworks have a dual role of delivering land use policy and of acting as a co-ordinating document for a range of other "planning" activity. This might involve:

    —  economic strategies, including those prepared by the Regional Development Agencies;

    —  the spending and investment plans of other public bodies: most spending plans have a spatial dimension;

    —  land management strategies and initiatives where they have a spatial element: these should include the management plans of national parks, AONBs and community forests.

  18.  In this way, a local development framework would draw on the spatial elements of a variety of plans and, as such, could co-ordinate the policy needed for a wide range of social, economic and environmental benefits for an area.

  19.  This approach could also be applied to the proposed level of sub-regional planning, where we see a key role for county councils. We have no strong views on whether structure plans should be retained in a formal sense but we do recommend a statutory role for county councils in the strategic co-ordination of spatial strategy at a "structure plan" sort of level.

  20.  That co-ordination should be "vertical", making sure that policy flows from regional to local level; and "horizontal", where land use policy is closely linked to the strategies and spending plans of the main public bodies.

  21.  County councils would also need to join up their own key county services to form a coherent planning and delivery strategy, perhaps working jointly with neighbouring authorities. This would provide an integrated strategic part of the planning process without the necessity of a formal middle tier of plan-making.


  22.  National parks and AONBs are designated because they demonstrate a cohesive set of qualities which provide a coherent basis for integrated rural policy. Such qualities are social, economic and environmental. The ability of these landscape designations to demonstrate joined-up policy making should not be underestimated.

  23.  We make three points on the role of national parks and AONBs in the planning system.

  24.  Firstly, we see good opportunities to widen the scope of planning in national parks by making much stronger connections between the land-use based local development framework and the management plan (which all are obliged to prepare). The Green Paper points to the "relevance" of such connections but such an approach is too weak. The proposal should be expanded to require planning authorities to demonstrate these connections and the multi-purpose nature of national parks.

  25.  Secondly, we see greater role for AONBs in strategic planning. AONBs, unlike national parks, are not constituted as planning authorities in their own right and will not automatically benefit from an AONB-wide local development framework. AONB authorities do have powers to prepare joint plans and we urge the Government to encourage a jointly prepared local development framework linked to the AONB management plan, where it is sensible to do so.

  26.  Thirdly, it is important to note that national parks and AONBs have two distinct "communities". The involvement of local communities is fundamental to plan preparation and decisions in designated areas, but national parks and AONBs also have national "communities" and specific statutory responsibilities for them—for visitors, tourists and many outdoor and conservation organisations. These two communities might well have very different views on planning matters. Local development frameworks must resolve this potential tension.

Countryside Agency

March 2002

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