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Observations on Consultation Drafts, PPS 12 And Guide to LDF Preparation
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- The Process Diagram - We are concerned that the process diagram at Figure 4 of the Draft PPS and under paragraph C1 of the Code of Practice is both unclear and does not accurately reflect the process of DPD preparation. Practitioners will put considerable importance on the diagram to assist them in understanding the relationship between the various stages in the preparation process, and it is therefore essential that it is both clear and accurate. We have identified the following concerns with the current version of the diagram -
- It shows different elements of the process within the same stage as if they were in parallel, when in fact one comes after another. This is particularly the case with the examination and adoption stages. If the objective of this form of presentation was to save space we suggest that it was misguided. It would be better to present the diagram in landscape format so that successive stages can be clearly presented as such.
- Sustainability appraisal is shown as if it was restricted to the production stage, whereas it will run all the way through the process of DPD production from inception to adoption. Indeed, we would suggest that because of the time that will be involved in establishing the base position for SEA and SA, it would be better to show sustainability appraisal as already being under way when DPD preparation commences. This also needs to be dealt with in the ordering of Section 4 of the draft PPS.
- There is stage missing from the diagram. The draft PPS says at paragraph 4.4.2 that following the submission of the DPD to the Secretary of State and the representation period, representations including proposals should be published with an invitation to submit representations upon them. We have particular observations on this stage which we shall return to later.
- Evidence gathering is shown as an input to the LDS, but not to plan production. The reality is that while some information will be collected to inform LDS preparation and review, notably monitoring information, most evidence gathering will take place within the production stage, in the form of technical studies such as the capacity study.
- We do not understand the two way arrow between pre-submission community involvement and submission to the SoS. How can pre-submission consultation apply after submission?
- The version of the diagram in the draft PPS does not show annual monitoring in the way that the Code of Practice version does. Monitoring does not just feed back into the beginning of the process, but should be shown as an input at each stage of DPD preparation.
- Engaging Partner Organisations - The change to spatial plans will mean that delivery will not rest simply with the planning authority through its development control powers, but some key elements will depend on other agencies for delivery. This suggests a shift from simply consulting such agencies to engaging them more closely, as effectively partners in delivering the plan. It can also be expected that where proposals or policy go to the heart of the plan, or are contentious, the relevant agencies will need to support the planning authority at the examination into the plan. None of this comes across in the drafts, and really ought to.
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