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Observations on the Consultation Draft of PPS 11
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The response to the Government consultations on draft guidance on the new development plan system. |
- The Society is broadly supportive of the changes proposed to the regional planning system, and their expression within draft PPS11. Particular concerns remain about the nature of the potential continued role of the County Councils, and the need to retain and utilise strategic planning experience within the new system. In this respect, the proposals within the draft PPS11 for sub-regional components of the RSS, and for the scope for strategic planning authorities to support RPBs on a contract basis, are of particular interest.
- The observations of the POS which follow have been organised in relation to the specific questions posed within the draft PPS11 (no observations are offered at this stage on the questions omitted).
- Paragraphs 1.17 and 1.18 set out the expected format of the regional spatial strategy (RSS). Does this cover the right key points or do you think that there should be changes or additions?
Achieving a concise document, which relates solely to regionally relevant matters (as distinct from reproducing national guidance) will be essential. This may however require quite radical rewriting of existing RPG. The need for the inclusion of “strategic development control policies” within RSS is not clear, and needs to be re-considered. It would seem preferable for RSS to operate in this respect by providing guidance on policies which should be included within LDFs, rather than bypass that tier, in seeking to influence development decisions directly.
- Paragraph 2.14 refers to the role that it is anticipated strategic planning authorities may play in leading sub-regional studies. Should we include more on how to make these arrangements effective and if so do you have any suggestions?
The principle of such a role is stated clearly. There may well be issues in practice, since co-operation between all parties, including all tiers of local government, will be essential. The Government Offices, supporting the RPBs, may be able to assist in encouraging such co-ordination and co-operation. It may well be (as para. 2.17 suggests) that assistance from strategic planning authorities could extend beyond “sub-regional” studies, to include leading on other issues or topics which contribute to the development of the RSS.
- Paragraph 2.17 lists areas of work where RPBs may wish to enter into partnership arrangements with strategic planning authorities. Do these highlight the right areas of work or should there be changes or additions?
The range of work indicated is broad and generally appropriate. However, it may be difficult for County Councils to assume a role of making representations on particular planning applications. How will this relate to the remaining planning powers of the County Councils? Also, the undoubted accountability of officers of the strategic authority which will remain to their own members may cause practical difficulties, particularly in this area of changing responsibilities.
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