The Development Control Topic Group considered the draft at its meeting in Newcastle on 2 April 2004. The following provides a summary of the comments made.

It was acknowledged that whilst the draft encapsulates the government's vision for planning, it is disappointing in that it is far from radical and fails to deliver the 'brave new world' that the green paper suggested. It was noted that the paper is open to wide interpretation with surprise as to how little is said about design and sustainability, with not much about raising quality. The paper fails to acknowledge the objective of planning in terms of providing high quality and sustainable buildings, spaces and places for all. References to sustainability are only token comments, and provide no better understanding of this issue. The paper is too simplistic on community involvement, and fails to acknowledge that given the resources, which are available, there is unlikely to be any significant change in how the community is engaged in the process. Consultation at every stage in the process may not be cost-effective. It was noted that all development control issues are confined to the annexes, and that annex C has an 'architecture' bias.

The following specific points may also be helpful to include in your response:

• Paragraph 1.13 – it is helpful that sustainable development is firmly placed at the centre of planning’s purpose, and that the four aspects concerning the economy, social inclusion, environmental protection, and prudent use of resources are articulated.  However, as the PPS acknowledges, there will inevitably be a balance to be struck between these aims on occasions and it is hoped that subsequent more topic specific PPSs will provide clearer guidance on where that balance is expected to lie.  Moreover most Planning Authorities would believe that they had already been pursuing these objectives and while it is helpful to have them articulated it does not signal a great change of direction for planning.
  
  
• While it is difficult to argue with many of the sentiments expressed in the PPS, there are some inherent contradictions, which need resolution.  For example in paragraph 1.2. quite clearly simplicity, flexibility, predictability and an efficient and effective planning system may all in themselves be desirable qualities, but a system which is more predictable from the point of view of the resident is probably one which is inflexible from the point of view of the developer.  Likewise, a system, which is responsive to, and heavily biased towards, community involvement, is unlikely to be simpler.  The fact that there appears to be no acknowledgement of some inherent contradictions in otherwise worthy aims does nothing to add to the credibility of the PPS as constructive guidance.
  
  
• Again, accepting the PPS is not topic specific, and will be augmented by good practice guidance, may account for the use of vague phrases which border on platitudes.  Everyone would support good design as a matter of principle, but there is a degree of subjectivity in making such judgements, and indeed it is not long since planning authorities were advised not to interfere excessively in detailed design.  Clearer guidance is needed, and the mere repetition of the mantra is not enough.  Likewise, paragraph 1.21, what does “policies should reflect a preference for minimising …….” Mean?  Any policy phrased in such an ambiguous way would be likely to be struck out of an LDF.  How strong a preference?  Would there be support for the refusal of individual developments, which could not demonstrate maximising the re-use of existing resources?  Similarly, in the final sentence “consideration should be given to encouraging energy efficient buildings……”.  What does “consideration” mean?  What does “encouraging," mean?  Would there be support for refusal of planning permission for buildings, which were not energy efficient?  Elsewhere the PPS suggests that planning should not be used as a proxy for the building regulations or other legislation.  On the same theme paragraph 1.22 “planning policy should seek to achieve where appropriate the following specific objectives for sustainable development and sustainable communities”.  Could some guidance be given as to where this would not be appropriate?  Also 1.22 “bring forward sufficient land…. to provide for growth and consumer choice”.  How significant is consumer choice?  If consumers choose to live in low density housing, how does this square with other policies?  Similarly, if consumers choose to live in a development consisting entirely of owner occupied properties or have a preference for a low-density car dependent way of life.  The PPS needs to be much clearer about what balance is to be struck between consumer choice and other government policies.  Again, 1.22 refers to the need to address waste and resource management impacts for example, through design.  This appears to be very close to saying that planning policies can require more than the building regulations.  The point is epitomised in the first bullet point of 1.25, which states “recognise the needs and broader interests of the community to secure a better quality of life for the community as a whole”.  While it would be impossible to argue for the opposite, the phrase is so vague and meaningless as to be of no practical value.  Regrettably too much of the PPS falls into this trap.
  
  
• Paragraph 1.27 may signal a major change which should be made explicit, it states “there should be no acceptance of ill conceived designs which do not contribute positively to making places better for people and that design policies should encourage developments which secure positive improvement to the streetscape or the place where they are located”.  On the face of it this would indicate that no detriment is not sufficient to justify new development.  This appears to be a higher threshold than was traditionally applied to conservation areas where no detriment was deemed to be sufficient.  If this is to be the case it needs to be made explicit.  Phrases like “design policies should encourage” do not help in clarity. However, subsequent detailed guidance as well as the support of the Inspectorate will be needed to encourage local planning authorities to require the highest standards of design.
  
  Spatial Planning
  
  
• There is a need for a clear, succinct definition of spatial planning.  No doubt this will emerge from good practice guidance, but should be in the PPS.  It is acknowledged that paragraph 1.29 goes some way towards this.  The difficulty with a strategy which brings together other policies and programmes which influence the nature of places, however, is that these are likely to be the responsibility of other agencies and may well be reviewed or adapted on a completely different timescale from the LDF.  Equally, the failure to deliver by any of these other agencies could undermine the credibility of the LDF as a whole.
  
  Community Involvement
  
  
• The objectives and principles are unobjectionable.  The difficulty will arise in the drafting of regulations (other consultation documents such as draft PPS12 and the draft regulations indicate this) and while inefficiency should not be condoned, it does need to be recognised that extensive community involvement will limit the speed with which LDFs can be produced.
  
  
• A word of caution should be expressed about the emphasis on front loading.  Again, while involving the community at the outset is laudable, it will not necessarily bring about consensus.   Admittedly it is more likely to do this in the case of a derelict site within an urban area for example, where the community as a whole may at least support the principle of redevelopment even if they disagree about the appropriate mix of uses design etc.  In the case of greenfield sites which will be necessary to meet intense pressures for housing growth in parts of the country, the existing community is very likely to have a strong preference for the status quo and no amount of discussion of meeting wider housing needs or the details of the layout, design, sustainability etc. is likely to shift this fundamental opposition.  This clearly raises the question of how one defines the community, but if it is defined in terms of a geographical locality there would be plenty of instances where the community as a whole is fundamentally opposed to development in principle.
  
  
• While it is true, as stated in para 1.7, that the planning system gives communities a real opportunity to participate, very often their views run counter to national or regional guidance and it is not possible for the local planning authority to meet them. This could lead to disillusionment, and this fact should be explicitly acknowledged.

The sentiments in draft PPS1 and the explicit statement of the purpose of planning are supported.  There is very little in the draft PPS with which one would take exception.  Its main shortcoming, however, is that it says very little which is not open to interpretation or could be argued in a number of different directions.