SECTION 1: MAKING PLANS FOR THE FUTURE
|Scottish Government Proposals||Issues identified by Planning Democracy|
|1||Align community planning and spatial planning by “introducing a requirement for development plans to take account of wider community planning”||Good in theory, but how will it work in practice?|
At present, neither community planning or spatial planning process is very inclusive, how will that be changed?
How will the process overcome potentially conflicting priorities of different partners? In particular, how can Community Planning commitment to tackling deprivation square with spatial planning’s reliance on private developers seeking profitable development opportunities?
If community planning and spatial planning priorities conflict, which will have the greater weight?
Requires resourcing and skilling up of planners
|2||Abolish strategic development plans and replace with “more proactive regional partnership working”||Unclear as to the reasoning behind strategic plans being abolished. Will regional partnership working really be more efficient and effective?|
Will the proposal lead to increased centralisation of planning? How will this fit with community empowerment objectives of more localised planning?
Who provides the resources to enable effective collaboration in regional partnerships?
Will this reduce public engagement opportunities on important regional issues such as green corridors, transport issues.
|3||Develop the NPF to better reflect regional priorities; Use NPF to make LDPs simpler and more consistent.”||Greater statutory weight for the NPF seems another highly centralising prospect.|
|4||Extend the LDP plan period to 10 years. Remove MIRs and SPG. Introduce ‘gatecheck’||The LDP will require reviews and changes during those 10 years or risk becoming outdated. How will public be consulted during these reviews?|
Public engagement on LDPs is currently inadequate. How will public engagement opportunities be improved in future to ensure meaningful debate and high quality involvement, where the public’s views are taken into account?
Main driver of abolishing Main Issues Report in LDP process seems to be efficiency. But more effective public involvement, gate check etc requires more time and effort, not less.
We propose planners acquire a better understanding and use of participatory techniques to improve MIR process rather than removing a consultation opportunity.
Proposal for citizen panels is interesting, and a great potential to use elsewhere in planning too, eg LRB’s.
|5||Making plans that deliver. Strengthen the commitments in the plan and ensure planned development happens on the ground.||Proposals make plan-making more complex, which puts extra pressure on development planning rather than development management without necessarily resolving any problems.|
Relies on the flawed assumption that early engagement irons out contentious issues. More likely to get “plans that deliver” if those plans are formulated and “owned” by communities
Stronger development plans have the potential for better planned development if resources allow, however often the detail of the application itself is crucial, conferring planning permission in principle is therefore risky. Eg in environmental protection, initial proposals may miss crucial information that would later lead to a dismissal of a proposal.
Changes to the system should not make the assumption that allocating sites in the LDP reduces the right of communities to respond to individual applications at a later date
Besides, surely a designation in a plan already confers a sort of outline planning permission, what does the SG intend to gain from granting planning permission in principle to sites allocated in the plan, which only increases the workload of local planning authorities.
Disenfranchises late challenges but does not really penalise speculative development applications that are made against the provisions in a plan