The Society has published its consultation response.
- General Comments:
- The Society has supported the Lord Taylor review of practice guidance, and welcomes its culmination in the publication of the concise and focused re-casting of guidance. The creation of a single place for all Government guidance is exceptionally helpful, as are the direct links within the text to relevant pieces of legislation and regulations. The web-based resource is accessible and generally easy to use, and has the signal virtue that it should be readily susceptible to updating as and when that becomes necessary.
- It is anticipated that practitioners will find the web-based resource convenient much of the time. However, it should be recognised that there are many circumstances where the internet is not readily available eg in meetings, inquiries and examinations, and when travelling. CLG is therefore urged to complement the web-based guidance with pdf versions of each section, so that they can be held on laptops and notebooks and printed off for immediate access. These should show prominently the date when they were last updated. The references to the NPPF, Government websites and other hyperlinks can appear as footnotes in the printable version.
- CLG should recognise that even if they leave the guidance in Web format, practitioners will print it off anyway. It must be better to have a secure version presented in the way CLG considers most appropriate, than for a wide variety of formats and styles to be in circulation
- It can be expected that the guidance will be need to be widely quoted in professional practice. This will be greatly assisted by adding paragraph numbers, which will enable practitioners to simply refer to the paragraph number rather than quote the relevant text in full (in the same way that the guidance does when referring to the NPPF). Paragraph numbers should be unique to each section of the guidance. CLG is advised not to re-number paragraphs where changes are made, but to simply leave a gap where a paragraph is removed or use suffixes (eg a, b c) where new paragraphs are added. This practice already applies to legislation, where practitioners are used to the occasional gap or added clause
- When reading some sections such as that on minerals, there are regular links to more detailed material or to other parts of the guidance. Whilst regular users of a particular section will become familiar with the structure, it could lead a newer user to be unaware of the full range of guidance relevant to a topic. It is therefore suggested that once the guidance is finalised, a site map should be added for each section to provide an immediate picture of the full content available on that subject. The present site map deals only with main headings and does not show all the levels within each section. An index of questions under each subject would also be helpful for the purposes of printing a subject index, and to ensure that all matters can be picked up under a particular subject when searching the guidance.
- Some of the content appears to be aimed at non practitioners. However, this results in over-simplification which is actually potentially misleading. We would urge that the audience should be those who are involved in the planning system and that the content should be aimed at the professional practitioner. The place for simple advice aimed at the general public (as opposed to practice guidance) should be the Planning Portal.
- We consider that there is a significant gap in the content of the guidance in that there is nothing on the Green Belt. Currently there is no guidance on how to go about a review of the Green Belt where it has been concluded that the exceptional circumstances exist to necessitate changes to its boundaries. Moreover, valuable content from Annex C of the former PPG2 is still required to provide guidance on the future of major development sites within the Green Belt.
- It will be important that there are clear protocols for future changes to the guidance. Whilst the guidance needs to be kept up to date and consistent with any changes in national planning policy, there is a risk of creating uncertainty and difficulties to practitioners if parts of the guidance are revised ad hoc or unexpectedly. The Society therefore suggests that once the guidance has been "finalised" following the Beta period, it should only be revised from time to time, with proper prior consultation on any significant revisions. There should also be effective arrangements for publicising the fact that revisions are being made, including media publicity, Chief Planner's letters and announcements on the CLG website and on the home page for the guidance itself. The facility for users to sign up for email alerts of changes is welcomed, but should not be the sole means of communicating that revisions are being made.
- The guidance has been prepared to a timetable which has been demanding for both CLG and practitioners. Whilst the opportunity to comment on the Beta version is welcomed, it must be expected that as the guidance is applied in the full range of planning practice, it will become apparent that some parts are proving inadequately clear, ambiguous, or open to debate about interpretation. The Society therefore urges that there should be a review of the body of guidance in about a year, with the opportunity for interested parties to suggest revisions or clarifications.
- Observations are offered on separate sections of the draft guidance. In some cases the Society has comments on a section as a whole. These are set out before coming to specific observations, which are referenced by the headings within them.
- Download the full response (in WORD format)