The LDF learning and dissemination project is working with ten pilot authorities to capture what they learn from the preparation of their LDF and disseminate that learning to practitioners. The reports of the learning from meetings of the pilot authorities are to be found on the Society's website.
The pilot authorities met again on 23 May 2005. This bulletin sets out what came out of that meeting, and also draws on some of what has been learnt from the Planning Advisory Service regional workshops held in May/June 2005. The meeting took forward the discussion at the previous meeting on spatial planning, to consider the content of DPDs and in particular:
HEALTH WARNING - The material here sets out the broad conclusions which came out of discussion with the pilot authorities, and represents an early view of what seems to be sensible practice. It is not presented as good practice at this time, because the test of that will only come when it has been applied in reality and can be seen to have worked.
The project authorities discussed what kind of policy material should go into the core strategy, and where different kinds of policy might go in a suite of DPDs. Using example policies from the forthcoming POS guide "Writing Spatial Policies", they were surprised how often a logical case could be made that a particular policy could go into alternative DPDs.
It was realised that the reason relates to the very flexibility offered by the new system, including
It is suggested that in deciding where in the suite of DPDs to locate particular aspects of policy, the following matters should be considered -
In considering what policy material should be planned for inclusion in each of the intended LDDs, some preliminary guidance can be offered.
Coherence and comprehensibility -One of the strengths of the new system is that it provides for the LDF to be built up from several different LDDs in the way which best suits the circumstances of the area. It also enables future updating to be restricted to the LDD(s) which needs to be revised, rather than having to review all elements of the LDF at once.
However, the loose leaf structure does present the possibility that at the time an LDD is prepared it will not provide a coherent picture in the absence of further LDDs. This could make it difficult for the general public and stakeholders to understand, and problematical in use. The issue is partly one of style and presentation, thinking about how best to present the LDD to make it easy to grasp and use. This includes making it clear that other LDDs are planned and will provide more detail about particular aspects of policy. But it is also a matter of content, ie including within the LDD policy material which is necessary for it to make sense and for users to understand clearly what is intended. Consideration should be given to -
Prior planning for content - It is suggested that a practical way to tackle the issue of coherence is to map out in advance what each LDD will contain, in the form of a simple schedule. In some cases it will be sufficient to use broad headings, while in others it may be desirable to consider where specific polices will go. As part of the process attention should be given to how saved polices will be progressively replaced by LDD policies. Existing knowledge of the area will enable many of the headings to be identified, but of course some policy issues will emerge from the process of spatial planning which were are foreseeable in advance, so it will be necessary to review the schedule from time to time.
Apart from acting as an aid to making the several LDDs coherent the mapping process will offer other benefits, though reducing the risks of -
It is stressed that the advice here must not be construed as suggesting that every existing local plan or UDP policy should be programmed for inclusion in one LDD or another. That would be to see the new system as the old one with new labels, and to seriously miss the point about spatial planning and the radical change of approach required . Moreover, many existing policies should be replaced within a small suite of generic development polices, and will not therefore need to go forward individually into the LDF.
Expect pressure for more detail -The staged preparation of LDDs will mean that proposals will be put forward for the location of development without the detail of exactly where it will go and how it will be configured. This will be particularly the case with the core strategy, which is intended to deal with broad locations rather than allocations, but it could also arise where an allocations DPD sets out the principles of allocations but leaves the detailed articulation of proposals to an Area Action Plan or SPD. It is also possible that some proposals will be further developed within a development policies DPD.
It should be anticipated that there will be calls for more detail to be included, whether from residents anxious to know how they may be affected, developers seeking clarity as to how their land is affected and just what are the opportunities, or elected members responding to residents' concerns. In a sense there is nothing new in the situation, since structure plans have dealt with broad locations for development and left the detail to local plans. However, there are differences from that position which may make the pressures more difficult to resist -
Apart from the external pressures, practitioners may feel that aspects of the new system itself tend to create a case for more detail, notably the emphasis on delivery and the fact that it will be a key issue at examination.
It must also be anticipated that could be suspicion on the part of some local people as to just what is going on. They will have to get to grips with a new system, and their uncertainty about the changes could easily turn to suspicion. In particular, there are likely to be those who believe that the planning authority is keeping back its true intentions until it has fixed the strategy, in an attempt to deny them influence over development sites or other contentious issues. This will tend to reinforce the pressure for more detail to be forthcoming.
Since the concerns and pressures can be foreseen, they can be planned for. A number of suggestions are offered -
PPS 12 says that the core strategy should contain "a spatial vision and strategic objectives for the area, a spatial strategy, core policies and a monitoring and implementation framework with clear objectives for achieving delivery" (PPS 12 para 2.9). The pilot authorities discussed what might be covered to meet those requirements.
The broad principle is that the core strategy should be restricted to genuinely strategic issues, which should be illustrated by a key diagram. It should not normally contain detailed allocations or development policies which would need to be shown on the proposals map. To do so would draw public and member attention away from the consideration of real strategic choices to matters of detail, and put the function of the core strategy at risk. (It is acknowledged that there are particular circumstances in London in relation to some polices of the Mayor's Plan). If it is considered that allocations or development policies need to be brought forward at the same time as the core strategy, this can be achieved by producing the relevant DPD broadly in parallel or close behind.
In considering the specific content of the core strategy in terms of descriptive as well as policy material, a number of matters are suggested for consideration to assist in communicating the essential messages -
However, the temptation to include too much detail will need to be resisted. Separate supporting documents can be produced to set out the evidence needed by other parties and, in due course the Inspector, to help them see that the strategy is soundly based and deliverable.
Given that the core strategy will set the overall strategy for the area, it is important that it considers the true key choices for the future, and that there is a real challenge to established thinking in identifying those choices. It is stressed that this is not about identifying radical alternatives which fly in the face of government policy or regional guidance, and which could not in fact be taken forward. Nor is it about presenting an option which is designed to scare local people into supporting the option the authority wants. No option should be put in front of communities which the authority could not deliver because of higher policy constraints, or is not prepared to adopt even if there proves to be a high level of public and stakeholder support.
Spatial planning calls for an approach to strategy which starts with the vision and strategic objectives and asks how they might best be achieved, without any presumption that the delivery mechanism will always be development control. The bulletin of the 26 April 2005 meeting of the pilot authorities gave suggestions on how to choose approaches which will ensure that planning is truly spatial. A key message there is about working with partners and other agencies to harness their different perspectives of the area, its needs, problems and possible solutions.
It is suggested that some challenging questions can be asked which will help bring out the key choices -
The challenge process should bring out a range of real choices for the area. They then need to be considered in terms of how they fit with what communities have had to say about their needs, concerns and priorities; the support or otherwise of key delivery agencies; the fit with national and regional planning policy; and political acceptability. From that process it should be possible to identify sets of alternatives which go well together and provide genuine options for further development and appraisal.
Of course the role of the planner in this process should not be passive. There is real scope for imaginative leadership and advocacy to persuade the various interested parties of the merits of options and win their support. A lucid plan which self-evidently tackles the key issues and seeks to harness opportunity can be used build consensus and drive forward delivery.