INTRODUCTION

1. Since the finalised versions of these two documents will need to be read together, and there are some inconsistencies in the current drafts, it aids clarity for the Society to set out its observations on the two together.
   
   
2. We shall begin with some general observations, then address transitional and other important issues, and then make some more detailed comments on the two draft documents.

GENERAL OBSERVATIONS

3. Getting the Key Messages Across - It is now clear that the Bill does not merely change the existing system of development plans, but replaces it by a system which is very different and requires significant changes in thinking and approach.  It is also apparent that many planning practitioners are struggling to come to terms with the extent of the changes.  There is a distinct risk that people will attempt to engage with the new system by relating its stages to those under the existing where that is simply not valid, and in doing so may seriously misdirect themselves at the outset.
   
   
4. The Society therefore urges that both the PPS and the Guide should begin with a clear exposition of the new system, the important ways in which it differs from the existing, and the key implications for practice.  This should cover the requirement to incorporate SEA and sustainability appraisal, with testing at each decision-making stage; the change to a spatial plan; the statutory function of the SCI; the principle of front-loading decision-making on the overall strategy underlying the plan, including the introduction of a formal options stage; the change in the function of the inquiry to an examination of the soundness of the plan, and the consequent requirement for a robust base of evidence; and the Inspector's report becoming binding.
   
   
5. It will also greatly aid understanding to build the text of both documents so far as possible around the chronological stages of LDF preparation.  Practitioners will need to comprehend what is required at each stage of plan preparation, and how the various stages relate to each other.  In this regard, we were surprised to see so little coverage of SEA and sustainability appraisal(SA) in the draft PPS 12, and their virtual absence from the Guide.  We consider this a serious omission having in mind how important SEA and SA will be both as ongoing aspects of the planning process and in examination of the soundness of the plan.  We are aware that separate guidance is to be prepared, but there is an important process issue about tying SEA and SA into the relevant decision-making stages, which is lost in the draft as it stands.