With a week left to respond to the call for evidence on the Planning (Scotland) Bill, this is the last opportunity to shape the Scottish planning system into one that really delivers for us all. On which, we wanted to briefly summarise our thoughts on the questions that the call for evidence asks (or some of them at least!).
More houses or better places?
A deeply personal issue for many of us, one of the initial drivers behind the planning review was increasing the delivery of new homes. The call for evidence now asks whether the Bill’s proposals will help to achieve this, and the short answer to this is that they probably will.
At the same time, while we welcome the Bill’s efforts to increase house building, focusing purely on quantitative improvements risks losing sight of the fundamental purpose of planning, which is to create great places. Some mechanism is required to ensure that planning performance takes account of quality outcomes, not just the number of houses built, and how quickly that is done.
A plan-led system, but led by which plan?
With the Bill proposing to remove Strategic Development Plans (SDPs), bring an amalgamated National Planning Framework (NPF)/Scottish Planning Policy (SPP) into the statutory Development Plan, and give communities the opportunity to create their own Local Place Plans, the call for evidence asks whether these proposals meet the needs of developers and communities in delivering development.
Overall, we welcome the Bill’s focus on delivery. The constant cycle of preparing plans without realising the positive outcomes they promise is as frustrating to planners as it is to both developers and communities, and this needs to be addressed.
However, we would question the merits of removing SDPs, as the two-tier system has worked well in the north east (our home area), although we appreciate this hasn’t necessarily been the case everywhere. We’re also concerned that, where there is conflict between the amalgamated NPF/SPP and the Local Development Plan, the proposal to give the most recently prepared plan precedence effectively makes decisions subject to a timescale lottery.
At the most local level, we believe the proposed new Local Place Plans could bring planning home to many people, allowing places to be planned by and for those who live and work there. They also present an opportunity to better integrate land use planning with community planning and to really deliver the aspirations of communities. The lack of a defined procedure, and the uncertainty over that, may though mean that as much time is spent agreeing the procedure as preparing and implementing the plans.
At the same time, feedback from communities indicates that the proliferation of plans for both land use and community planning is generating confusion about exactly which plan does what, and the status and priority of each. As such, serious thought needs to be given to how these plans are rolled out in practice. Otherwise, in trying to be helpful, it’s possible that these proposals will simply add a layer of complication that did not previously exist.
A new Infrastructure Levy?
The question here is whether the proposed Infrastructure Levy is the best way to secure investment in new infrastructure, and how this might impact on levels of development.
The lack of funding for infrastructure has long been a frustration for many, and we welcome the idea of a levy to provide certainty on contributions towards this. However, it’s disappointing that there’s no apparent mechanism for a regional level body to manage and administer those elements of the levy that relate to, for example, regional transport infrastructure. It is also interesting to note that the Community Infrastructure Levy in England is currently being reviewed, so lessons may be learned from that.
A balancing act
Leaving the first (and probably most fundamental) question in the call for evidence to last, this is whether the Bill effectively balances the need to secure appropriate development with the views of communities and protection of the environment.
Given the extensive engagement exercise the Government has undertaken over the two years that the Bill has been in the making, we’d like to give this a resounding yes. However, considering some of the points above, and with vital detail about how many proposals will work in practice still to be confirmed through secondary legislation, there’s not yet any guarantee that the Bill’s potential in this regard will be realised in full.
An evidence led system!
On that note, David Hume once said: “A wise man proportions his belief to the evidence”. So, if you want a planning system that works for you, then we would encourage you to submit your evidence to the Parliament by 2 February 2018. Follow the link below to find out how:
Thanks for reading!
Maggie and Pippa