Supplementary memorandum from the Royal
Town Planning Institute
RESPONSE TO
SPECIFIC QUESTIONS
FROM THE
ENVIRONMENTAL AUDIT
COMMITTEE FOLLOWING
THE ROYAL
TOWN PLANNING
INSTITUTE'S
ORAL EVIDENCE
SESSION, 13 OCTOBER
2004
Q1: Your proposal for a UK-wide Spatial Development
Framework was mentioned briefly during the session. It would be
very useful to have some further detail of what you are proposing,
together with any work you are doing to determine the feasibility
of such a framework, and details of any dialogue you have had
with ODPM regarding this
1. A briefing note on the UK Spatial Development
Framework is attached.
Q2: You have submitted a response to the Countryside
Agency's consultation on unlocking the potential of the rural
urban fringe. It would be of use to the Committee if you could
send us a copy of this
2. A copy of the Institute's response to
the joint Countryside Agency/Groundwork UK consultation, dated
27 April 2004, is attached.
Q3: You mentioned various times during your
evidence session that you expect the new approach to planning
to result in a much more participatory and democratic process.
What are the changes that you hope will achieve this and how?
3. This is the very much the Government's
ambition for the new planning system introduced by the 2004 Planning
and Compulsory Purchase Act. From the outset, the December 2001
Green Paper—Planning: Delivering a Fundamental Change
- spoke extensively of "community engagement",
and much more effective and extensive participation in the planning
process. This related both to preparation of the new style development
plans and to consideration of major planning applications. It
is reflected in the requirement (in section 18 of the Act) for
each local planning authority (LPA) to prepare a Statement of
Community Involvement (SCI). The importance of community engagement
and the "front loading" of participation in the plan-making
process are heavily endorsed in ODPM's "procedural policy"
set out in PPS 12—Local Development Frameworks and
in the recently-published "how to do it" guidance to
LPAs—Creating Local Development Frameworks. The final
check, or balance, is that the public examination of a development
plan document is centred on testing its "soundness",
and one of the tests of soundness is whether the requirements
for participation in the plan-making process (as set out in the
SCI) have been met.
4. Early in the Bill's consideration by
Parliament, the Institute proposed an amendment the effect of
which would have been to require an SCI from regional planning
bodies when preparing their Regional Spatial Strategies (RSSs).
This was not accepted by the Government at the time, but what
is now section 6 of the Act was added during the Bill's final
stages in the House of Commons. The requirement for consultation
with a wide range of stakeholders is underlined in PPS 11—Regional
Planning.
5. Having said that effective community
involvement is the Government's ambition, it is one that is fully
supported by the Institute. It is, of course, much too early to
measure the practical effect of the new requirements as Parts
1 and 2 of the Act only came into effect on 28 September 2004.
6. Relating this back to the discussion
with the Committee at the evidence session on 13 October, the
context there was very much on the ability of local communities
to influence the numbers and distribution of new housing, which
would first be established in RSS and then "cascade"
down to the LPAs' development plan documents (the new style local
plans). We suggested that this must be an iterative process, combining
the bottom-up and the top-down, and that given the statutory requirement
to involve fully stakeholders and other interested parties at
both the regional and local levels, we were optimistic that the
process would be more transparent and democratic in the future
than perhaps it has been in the past.
Q4: The Government suggests that PPS 1 will
put sustainable development at the heart of planning. Would you
agree with this?
7. It is section 39 of the Planning and
Compulsory Purchase Act that puts sustainable development at the
heart of planning. We are unable to comment on how effectively
PPS 1 may interpret the primary legislation—simply
because the policy statement has yet to be published in its final
form! The Institute understands that it is being substantially
re-written, following the less than enthusiastic reception received
by the consultation draft earlier this year.
8. A copy of the Institute's response to
the consultation draft is attached. While we were supportive of
the general thrust of the draft, we were least impressed by the
section on sustainable development. It seems that, given the Departmental
strapline of Creating Sustainable Communities (a phrase,
significantly, also used as the title of PPS 1), ODPM really
is beginning to believe that everything it does is in the name
of sustainable development, though it appears to be unable to
go the extra mile to get under the skin of what is involved in
ensuring that future development is genuinely sustainable. This
tends to devalue the concept.
Q5: You state in your memorandum that materials
used in construction is not an issue that can be directly influenced
by the operation of the planning system. However, the use of sustainable
materials is directly related to ensuring we build sustainable
housing and from our understanding is an issue many planning authorities
are getting involved with. If it is not to be done through the
planning system, how do you suggest we ensure the use of natural
resources used in new housing construction is minimised and recycling
of materials encouraged?
9. On reflection, the statement in our memorandum
may have dismissed the role of the planning system too readily.
It is true that the materials to be used in a development can
be specified in conditions attached to a planning permission,
but this mechanism is used mainly to ensure that new buildings/extensions
fit in with their surroundings, and particularly in conservation
areas and other sensitive locations.
10. However, this is not the main issue
in the sustainable use of materials. With the exception of the
"system" building of the 1960s, there is little evidence
that the traditional materials used in housebuilding in the UK—brick,
stone, tiles, slates, etc—are not sustainable. The large
numbers of 19th century houses that are still in good structural
condition show that, with a responsible level of maintenance,
the traditional materials are capable of lasting well over 100
years. Where major demolition has taken place—such as inter-war,
peripheral council estates—this has been primarily for social
reasons rather than a lack of building integrity.
11. On this evidence, the Institute would
argue that, as a nation, we are not wantonly using scarce natural
resources to needlessly make new building materials. Where we
have some distance to go, though, is in the re-use of materials
arising from demolition and other activities. The reclamation
of bricks and building stone, for re-use on a wide scale, is a
resource-intensive process that is probably itself unsustainable.
(It does have limited applications in conservation work.) However,
the conversion of demolition waste into secondary aggregates is
a much more viable process.
12. Present fiscal arrangements—the
Aggregates Levy and the Landfill Tax, for example—have some
perverse effects, and do not necessarily achieve their intended
objectives. They do increase the cost of using primary aggregates
or taking inert materials to landfill, but the extra costs are
simply passed on to the customer. What is needed is a regime that
directly recycles the product of these taxes into subsidising
the preparation and use of secondary materials, so that this becomes
the first choice for developers. This would have the twin benefits
of reducing the reliance on scarce natural resources, and minimising
the amount of waste that goes to the rapidly declining supply
of landfill sites.
November 2004
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