GENERIC POLICIES

28. We have the impression that thinking is still evolving here, and has yet to firm up.  There is no reference to them in Section 2.2 of the draft PPS, but they then receive a whole section at 2.5, are covered (rather differently) in paragraph 1.1.7 of Annex A, and are not referred to at all in the draft Guide to Procedures, which merely refers to policies for the control of development.  Moreover, the draft PPS puts them after the section on supplementary planning documents, which is both illogical and potentially confusing.  The Society is an advocate of the use of generic policies, and considers that it would be wrong, for lack of anywhere else to put them to lump them into the core policies, since that would mix strategic and detailed material to the detriment of the clarity of the core policies.  We would therefore welcome consistent explicit advice that a DPD of generic policies will be good practice.

DETAILED COMMENTS

29. We have a number of detailed comments on the drafting and, in places, the principles behind the two draft documents.  We shall deal with the draft PPS first, picking up any further issues of inconsistency with the draft Guide to Procedures and Code of Practice.

THE DRAFT PPS

30. Section 1.3, spatial strategy content - this should be part of a wider exposition of the new system and its key features.
    
    
31. 1.3.2 - The clear link made here between the LDF and the community strategy is welcomed.
    
    
32. 1.3.3 iii - It is delusory to suggest that the community and stakeholders will agree and sign up to the vision for the plan.  Planning is about the resolution of competing interests, which will include differences of vision for the area.  All that can be aspired to is that the planning authority will develop its vision after thoroughgoing consultation and dialogue, but recognise and respect that some interests will disagree passionately, especially where substantial growth is provided for in the RSS.  Paragraph c.10 of the Code of Practice covers the related point about consensus on strategy more realistically.
    
    
33. Chapter 2 - We have made the point earlier that it is essential that the PPS sets out clearly at the outset the principles behind the new system and the key implications for practice.  This should come before Chapter 2.  Moreover, as argued earlier, it would make the PPS much clearer if the sections on the LDS and the SCI came before material on DPDs.
    
    
34. 2.2.3 - While it is right that the core strategy should take on board the range of relevant strategies, there should be explicit reference here to the requirement for conformity with the RSS.
    
    
35. Avoidance of blight - While we do not quarrel with the advice under this heading, it jars here, and would be better located later, after the main elements of the LDF have been covered.