Memorandum by the Countryside Agency (PGP
THE GOVERNMENT'S GREEN PAPER: PLANNING: DELIVERING
A FUNDAMENTAL CHANGE
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 countrysideits people
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
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
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
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 themfor 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.