LDF L&DG: Core Strategies and What Goes Where

Date: 23/5/2005

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:

• what goes where? how to decide where best to put particular policy material in th eplanned suite of LDDs
• some principles of approach
• the content of the core strategy

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.

• what should go where?
• principles of approach
• content of the core strategy

What should go where?

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

• the possibility of allocations or development policies DPDs being prepared before the core strategy
• the option of having both an allocations DPD and one or more area action plans
• the alternatives of using an area action plan or SPD to set out detailed local proposals
• choices as to where best to put implementation policies

It is suggested that in deciding where in the suite of DPDs to locate particular aspects of policy, the following matters should be considered -

• the importance of the issue locally, eg if the need for affordable housing is a key driver of the plan it will figure in the core strategy, whereas if it is a secondary consideration it might be more suitably dealt with in a development polices DPD
• the structure of the LDF and the order of DPD production, eg if the particular situation in an area makes it more logical to begin with an allocations or development policies DPD, it may make the document more coherent to include certain policies which might otherwise have gone first into the core strategy
• similarly, if an area action plan is prepared before the allocations DPD, it may be necessary to set out key allocations as proposals of the AAP which would otherwise have been dealt with in the allocations DPD
• the pattern of development - eg an area where there will be one or more urban extensions may call for area action plans to deal with the allocations, whereas if most development will be on small brownfield sites within the urban area an allocations DPD may be more appropriate
• the desirability of each individual DPD being coherent and comprehensible in itself at the time it is prepared - this matter of coherence is addressed next

Principles of approach

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 -

• how to make each individual LDD coherent in itself
• how they will fit together in aggregate
• how to make the LDF as a whole coherent as each new LDD comes forward

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 -

• failing to collect necessary evidence in a timely way
• having difficulty in demonstrating deliverability through not being able to say with confidence where a particular policy of the core strategy, say, will be developed in more detail
• missing the boat, ie realising a policy area should have been covered in an earlier LDD

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 -

• structure plans have generally either not referred to locations, or have done so in such a generalised way that people would accept that the effective decisions would be made by the local plan
• by contrast, core strategies will relate to smaller areas, and will be expected to be sufficiently explicit about broad locations that they can be assessed through sustainability appraisal, and a proper examination made of their deliverability
• the fact that it is the same authority preparing all the elements of the LDF, and therefore will be seen to have choices over their content

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 -

• be alert all the time to the potential for suspicion and be proactive and honest in explaining the realities of the situation
• explain from the outset that staged preparation is a feature of the new system, and that key decisions willbe made in the core strategy before the detail is painted in, and that people do need to engage at that stage
• ensure that everyone associated with LDF production knows clearly where and when the detail will be provided, so that credible answers can be given
• spell out in the core strategy how the production of other LDDs will contribute to its delivery
• preparation of the allocations DPD alongside (but a little behind) the core strategy will enable all interested parties to see what the detailed proposals are at the same time as they consider their views on the core strategy
• consider engaging Planning Aid to work with local communities and groups to help them understand the workings of the new system and the stages at which they need to make their voice heard
• put key implementation policies into the same DPD as the primary policies or proposals they support
• use the key diagram of the core strategy as a vehicle for communicating the overall strategy, and consider carefully how it should be presented to avoid misinterpretation - consider a "test drive" with non-planners to bring out unintended readings of its meaning
• be prepared to resist calls for more detail, but be ready to promise when the detail will be provided and explain the opportunities for influence which will arise at that time

Content of the core strategy

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 -

• whether all the material being considered for inclusion is of genuine strategic significance - a possible question to ask is "Would the core strategy be any the less complete and coherent without it?"
• the wider context of the area both in terms of the main factors affecting its future and the effect of higher level policy or that of adjoining authorities
• the relationship between the various policies and strategic proposals (not allocations), and how they support each other
• the roles of the main players who will shape the future of the area, and any interdependencies between their intended actions
• how at a level of principle the strategy and key policies will be delivered, and the associated risks
• an implementation strategy, to demonstrate in concise terms how the strategy will be delivered - this is important because of the attention which the examination will give to deliverability. It should be kept in mind that the other LDDs and the strategies or programmes of other agencies are themselves significant tools of delivery
• whether there are implementation polices which are so central to delivery that there is a case for including them with the proposals or policies to which they relate
• a brief summary of the key messages from community engagement at the issues stage and (in the submission version) from engagement in relation to the preferred options stage, and how they have influenced the choices made. This can be brief because the authority will wish to provide separate reports on the results of community and stakeholder engagement.
• similarly, a brief summary of the key messages from sustainability appraisal, and how it has shaped the strategy

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.

Possible addition
Challenging options

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 -

• What are the main problems from a wide-angle perspective, and what are the different ways in which they might be tackled?
• What are the main opportunities, and how might they be captured for the benefit of the area? Could different approaches to the location and scale of development offer greater opportunities for provision of community goods through planning obligations?
• Are there opportunities which might become possible if the assumptions behind current local strategy are challenged?
• Are there established disagreements between political parties or within the officer corps which point to different approaches and prospective outcomes? - sustainability appraisal could evaluate these and illuminate choices
• Could considering a longer timescale offer radical alternatives to incrementalism which would present greater benefits? - this would necessarily lead into consideration of deliverability, since more radical options often require new infrastructure
• Is the public perception of needs and problems different from what has become conventional corporate thinking, and does that call for alternatives to be considered which do not form part of the current mind-set?
• Do the current programmes of the various agencies fit coherently together, or is there a case for one or more changing its approach so as to improve the aggregate impact?
• Are there options in relation to commercial opportunities which could be brought forward to offer new benefits?

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.