Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by the Royal Institute of British Architects (PGP 40)



  The members of the Royal Institute of British Architects and the Royal Institution of Chartered Surveyors are major professional users of the planning system. Representatives of these organisations have met to discuss the proposals contained in the Green Paper and have agreed a joint response on a number of issues for your consideration.

Each organisation will respond individually to the DTLR on other detailed issues

  The RIBA and RICS welcome the recognition by Government of the need to provide a planning service that has clarity, is accountable and is efficient. This memorandum takes these three key points as its headings, and where appropriate, refers to the points identified by the Select Committee as being of particular interest.

  It is appreciated that the Green Paper is concerned with the planning system as process and not as product. The proposals would have benefited from being set against a clearer outline of the whole planning process and a core statement of the purpose and principles of planning.

  After 50 years of post-war Town and Country Planning legislation and guidance it is not surprising that the planning system has become complex to us and to execute. As they stand the development and application of many of the proposals set out in the Green paper do not impart confidence that they will deliver the improved planning system that is needed.


  Planning guidance and development plans have the dual function of directing the form and nature of development and providing a measure against which proposals for development can be assessed and determined. To make the planning process more effective it is vital that both guidance and plans offer clarity, avoid duplication and are responsive to emerging social, economic and environmental needs.

Effectiveness of system of local plans and Government's proposals to replace them

  The proposals setting out a new order and form of development plans, ranging from Regional Spatial Strategies and Local Development Frameworks to a range of Action Plans which have to be allied to Community Strategies and Local Transport Plans are, on the limited evidence offered in the Paper, seen as a patchwork of plans rather than providers of clarity through seamless sequence and content.

  It is essential that these plans contain clear and unambiguous policies and proposals reducing to a minimum the level of discretion that is required for interpretation. It is suggested that development plans are simplified and adopt, wherever appropriate, model policies to do so will assist with the speed of determining planning applications. There is also concern that it may not always be practical to regularly update local plans as Local Authorities may not have the resources to do this.


Role of regional planning bodies

  If it is accepted that the planning system should be conducted within the democratic process, and we firmly believe that at every level democracy must be the rule so that decisions about people's enjoyment of their property should not be made by a higher authority, then the proposition of endorsing the principle of Regional Spatial Strategies is premature until the democratic arrangements for Regional Government in England have been agreed.

Procedures for scrutinising major development projects

  The proposal that major projects in the national interest should be determined by Parliament is supported, provided they are done so in the context of a national statement of planning policy.


Whether the Government's proposals will simultaneously increase certainty, public participation and faster decisions, particularly for business

  The need to provide adequate resources for local planning authorities is supported and to this end the proposals to increase planning fees are endorsed, providing this extra income is directed to improving resources.

  The proposal that the time allowed for an applicant to appeal a planning decision be reduced from six months to three months is not supported; we feel that the six month period should remain.

  The proposal that the life time of a planning consent be reduced from five years to three years is not supported; we feel that the five year life time should remain but that it should be made clear that a renewal of the consent at end of the five year period is not automatic.

  The range of fees proposed is complex and there is concern that they will become a source of bureaucracy. By paying fees the user is entitled to a service and there need to be fair provisions for the user to invoke penalties if an agreed level of service is not provided. In return the user as the planning applicant should be required to make available a professional quality of information responding to the proposed checklists, not only to assist the planning process but also to achieve good quality development.

  The proposal that local planning authorities should engage the assistance of the private sector, both in the preparation of plans and the determination of applications to assist efficiency, is supported.

  The proposal that Local Authorities should be able to extend the range of Permitted Development is supported, provided there is also a clear national policy.

  Consultation can both assist and hinder development. The principle of consultation is supported provided it is controlled and responsible. A clearer framework and guidance for involving third parties in the planning system is required. This involvement should not extend to the right of appeal by third parties, which would clog up the planning process. Similarly, other proposals such as refusing repeat applications are supported.


  This memorandum of necessity contains the "headline" comments of two professional organisations that agree on some of the issues by this Green Paper. We do not agree on every issue as will be apparent from our individual submissions. We hope that the appropriate parliamentary time will be accorded to allow for the development and implementation of the responses to the Green paper as soon as possible.

Brendan O'Connor

RIBA Planning Policy Group Administrator

March 2002

previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2002
Prepared 2 May 2002