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Core Strategies and What Goes Where
The LDF learning and dissemination project is working with ten pilot authorities
to capture what they learn from the preparation of their LDF and disseminate
that learning to practitioners. The reports of the learning from meetings of
the pilot authorities are to be found on the Society’s website.
The pilot authorities met again on 23 May 2005. This bulletin sets out what
came out of that meeting, and also draws on some of what has been learnt from
the Planning Advisory Service regional workshops held in May/June 2005. The
meeting took forward the discussion at the previous meeting on spatial planning,
to consider the content of DPDs and in particular -
HEALTH WARNING - The material here sets out the broad conclusions which
came out of discussion with the pilot authorities, and represents an early view
of what seems to be sensible practice. It is not presented as good practice
at this time, because the test of that will only come when it has been applied
in reality and can be seen to have worked.
Headlines
What should go where?
The project authorities discussed what kind of policy material should go into
the core strategy, and where different kinds of policy might go in a suite of
DPDs. Using example policies from the forthcoming POS guide “Writing Spatial
Policies”, they were surprised how often a logical case could be made
that a particular policy could go into alternative DPDs.
It was realised that the reason relates to the very flexibility offered by
the new system, including
- the possibility of allocations or development policies DPDs being prepared
before the core strategy
- the option of having both an allocations DPD and one or more area action
plans
- the alternatives of using an area action plan or SPD to set out detailed
local proposals
- choices as to where best to put implementation policies
It is suggested that in deciding where in the suite of DPDs to locate particular
aspects of policy, the following matters should be considered -
- the importance of the issue locally, eg if the need for affordable housing
is a key driver of the plan it will figure in the core strategy, whereas if
it is a secondary consideration it might be more suitably dealt with in a
development polices DPD
- the structure of the LDF and the order of DPD production, eg if the particular
situation in an area makes it more logical to begin with an allocations or
development policies DPD, it may make the document more coherent to include
certain policies which might otherwise have gone first into the core strategy
- similarly, if an area action plan is prepared before the allocations DPD,
it may be necessary to set out key allocations as proposals of the AAP which
would otherwise have been dealt with in the allocations DPD
- the pattern of development - eg an area where there will be one or more
urban extensions may call for area action plans to deal with the allocations,
whereas if most development will be on small brownfield sites within the urban
area an allocations DPD may be more appropriate
- the desirability of each individual DPD being coherent and comprehensible
in itself at the time it is prepared - this matter of coherence is addressed
next
Read on or return to Headlines
Principles of approach
In considering what policy material should be planned for inclusion in each
of the intended LDDs, some preliminary guidance can be offered.
Coherence and comprehensibility -One of the strengths
of the new system is that it provides for the LDF to be built up from several
different LDDs in the way which best suits the circumstances of the area. It
also enables future updating to be restricted to the LDD(s) which needs to be
revised, rather than having to review all elements of the LDF at once.
However, the loose leaf structure does present the possibility that at the
time an LDD is prepared it will not provide a coherent picture in the absence
of further LDDs. This could make it difficult for the general public and stakeholders
to understand, and problematical in use. The issue is partly one of style and
presentation, thinking about how best to present the LDD to make it easy to
grasp and use. This includes making it clear that other LDDs are planned and
will provide more detail about particular aspects of policy. But it is also
a matter of content, ie including within the LDD policy material which is necessary
for it to make sense and for users to understand clearly what is intended. Consideration
should be given to -
- how to make each individual LDD coherent in itself
- how they will fit together in aggregate
- how to make the LDF as a whole coherent as each new LDD comes forward
Prior planning for content - It is suggested that
a practical way to tackle the issue of coherence is to map out in advance what
each LDD will contain, in the form of a simple schedule. In some cases it will
be sufficient to use broad headings, while in others it may be desirable to
consider where specific polices will go. As part of the process attention should
be given to how saved polices will be progressively replaced by LDD policies.
Existing knowledge of the area will enable many of the headings to be identified,
but of course some policy issues will emerge from the process of spatial planning
which were are foreseeable in advance, so it will be necessary to review the
schedule from time to time.
Apart from acting as an aid to making the several LDDs coherent the mapping
process will offer other benefits, though reducing the risks of -
- failing to collect necessary evidence in a timely way
- having difficulty in demonstrating deliverability through not being able
to say with confidence where a particular policy of the core strategy, say,
will be developed in more detail
- missing the boat, ie realising a policy area should have been covered in
an earlier LDD
It is stressed that the advice here must not be construed
as suggesting that every existing local plan or UDP policy should be programmed
for inclusion in one LDD or another. That would be to see the new system as
the old one with new labels, and to seriously miss the point about spatial planning
and the radical change of approach required . Moreover, many existing policies
should be replaced within a small suite of generic development polices, and
will not therefore need to go forward individually into the LDF.
Expect pressure for more detail -The staged preparation
of LDDs will mean that proposals will be put forward for the location of development
without the detail of exactly where it will go and how it will be configured.
This will be particularly the case with the core strategy, which is intended
to deal with broad locations rather than allocations, but it could also arise
where an allocations DPD sets out the principles of allocations but leaves the
detailed articulation of proposals to an Area Action Plan or SPD. It is also
possible that some proposals will be further developed within a development
policies DPD.
It should be anticipated that there will be calls for more detail to be included,
whether from residents anxious to know how they may be affected, developers
seeking clarity as to how their land is affected and just what are the opportunities,
or elected members responding to residents’ concerns. In a sense there
is nothing new in the situation, since structure plans have dealt with broad
locations for development and left the detail to local plans. However, there
are differences from that position which may make the pressures more difficult
to resist -
- structure plans have generally either not referred to locations, or have
done so in such a generalised way that people would accept that the effective
decisions would be made by the local plan
- by contrast, core strategies will relate to smaller areas, and will be
expected to be sufficiently explicit about broad locations that they can be
assessed through sustainability appraisal, and a proper examination made of
their deliverability
- the fact that it is the same authority preparing all the elements of the
LDF, and therefore will be seen to have choices over their content
Apart from the external pressures, practitioners may feel that aspects of the
new system itself tend to create a case for more detail, notably the emphasis
on delivery and the fact that it will be a key issue at examination.
It must also be anticipated that could be suspicion on the part of some local
people as to just what is going on. They will have to get to grips with a new
system, and their uncertainty about the changes could easily turn to suspicion.
In particular, there are likely to be those who believe that the planning authority
is keeping back its true intentions until it has fixed the strategy, in an attempt
to deny them influence over development sites or other contentious issues. This
will tend to reinforce the pressure for more detail to be forthcoming.
Since the concerns and pressures can be foreseen, they can be planned for.
A number of suggestions are offered -
- be alert all the time to the potential for suspicion and be proactive and
honest in explaining the realities of the situation
- explain from the outset that staged preparation is a feature of the new
system, and that key decisions will be made in the
core strategy before the detail is painted in, and that people do need to
engage at that stage
- ensure that everyone associated with LDF production knows clearly where
and when the detail will be provided, so that credible answers can be given
- spell out in the core strategy how the production of other LDDs will contribute
to its delivery
- preparation of the allocations DPD alongside (but a little behind) the
core strategy will enable all interested parties to see what the detailed
proposals are at the same time as they consider their views on the core strategy
- consider engaging Planning Aid to work with local communities and groups
to help them understand the workings of the new system and the stages at which
they need to make their voice heard
- put key implementation policies into the same DPD as the primary policies
or proposals they support
- use the key diagram of the core strategy as a vehicle for communicating
the overall strategy, and consider carefully how it should be presented to
avoid misinterpretation - consider a “test drive” with non-planners
to bring out unintended readings of its meaning
- be prepared to resist calls for more detail, but be ready to promise when
the detail will be provided and explain the opportunities for influence which
will arise at that time
Read on or return to Headlines
Content of the core strategy
PPS 12 says that the core strategy should contain “a spatial vision and
strategic objectives for the area, a spatial strategy, core policies and a monitoring
and implementation framework with clear objectives for achieving delivery”
(PPS 12 para 2.9). The pilot authorities discussed what might be covered to
meet those requirements.
The broad principle is that the core strategy should be restricted to genuinely
strategic issues, which should be illustrated by a key diagram. It should not
normally contain detailed allocations or development policies which would need
to be shown on the proposals map. To do so would draw public and member attention
away from the consideration of real strategic choices to matters of detail,
and put the function of the core strategy at risk. (It is acknowledged that
there are particular circumstances in London in relation to some polices of
the Mayor’s Plan). If it is considered that allocations or development
policies need to be brought forward at the same time as the core strategy, this
can be achieved by producing the relevant DPD broadly in parallel or close behind.
In considering the specific content of the core strategy in terms of descriptive
as well as policy material, a number of matters are suggested for consideration
to assist in communicating the essential messages -
- whether all the material being considered for inclusion is of genuine strategic
significance - a possible question to ask is “Would the core strategy
be any the less complete and coherent without it?”
- the wider context of the area both in terms of the main factors affecting
its future and the effect of higher level policy or that of adjoining authorities
- the relationship between the various policies and strategic proposals (not
allocations), and how they support each other
- the roles of the main players who will shape the future of the area, and
any interdependencies between their intended actions
- how at a level of principle the strategy and key policies will be delivered,
and the associated risks
- an implementation strategy, to demonstrate in concise terms how the strategy
will be delivered - this is important because of the attention which the examination
will give to deliverability. It should be kept in mind that the other LDDs
and the strategies or programmes of other agencies are themselves significant
tools of delivery
- whether there are implementation polices which are so central to delivery
that there is a case for including them with the proposals or policies to
which they relate
- a brief summary of the key messages from community engagement at the issues
stage and (in the submission version) from engagement in relation to the preferred
options stage, and how they have influenced the choices made. This can be
brief because the authority will wish to provide separate reports on the results
of community and stakeholder engagement.
- similarly, a brief summary of the key messages from sustainability appraisal,
and how it has shaped the strategy
However, the temptation to include too much detail will need to be resisted.
Separate supporting documents can be produced to set out the evidence needed
by other parties and, in due course the Inspector, to help them see that the
strategy is soundly based and deliverable.
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Possible addition
Challenging options
Given that the core strategy will set the overall strategy for the area, it
is important that it considers the true key choices for the future, and that
there is a real challenge to established thinking in identifying those choices.
It is stressed that this is not about identifying radical alternatives which
fly in the face of government policy or regional guidance, and which could not
in fact be taken forward. Nor is it about presenting an option which is designed
to scare local people into supporting the option the authority wants. No option
should be put in front of communities which the authority could not deliver
because of higher policy constraints, or is not prepared to adopt even if there
proves to be a high level of public and stakeholder support.
Spatial planning calls for an approach to strategy which starts with the vision
and strategic objectives and asks how they might best be achieved, without any
presumption that the delivery mechanism will always be development control.
The bulletin of the 26 April 2005 meeting of the pilot authorities gave suggestions
on how to choose approaches which will ensure that planning is truly spatial.
A key message there is about working with partners and other agencies to harness
their different perspectives of the area, its needs, problems and possible solutions.
It is suggested that some challenging questions can be asked which will help
bring out the key choices -
- What are the main problems from a wide-angle perspective, and what are
the different ways in which they might be tackled?
- What are the main opportunities, and how might they be captured for the
benefit of the area? Could different approaches to the location and scale
of development offer greater opportunities for provision of community goods
through planning obligations?
- Are there opportunities which might become possible if the assumptions
behind current local strategy are challenged?
- Are there established disagreements between political parties or within
the officer corps which point to different approaches and prospective outcomes?
- sustainability appraisal could evaluate these and illuminate choices
- Could considering a longer timescale offer radical alternatives to incrementalism
which would present greater benefits? - this would necessarily lead into consideration
of deliverability, since more radical options often require new infrastructure
- Is the public perception of needs and problems different from what has
become conventional corporate thinking, and does that call for alternatives
to be considered which do not form part of the current mind-set?
- Do the current programmes of the various agencies fit coherently together,
or is there a case for one or more changing its approach so as to improve
the aggregate impact?
- Are there options in relation to commercial opportunities which could be
brought forward to offer new benefits?
The challenge process should bring out a range of real choices for the area.
They then need to be considered in terms of how they fit with what communities
have had to say about their needs, concerns and priorities; the support or otherwise
of key delivery agencies; the fit with national and regional planning policy;
and political acceptability. From that process it should be possible to identify
sets of alternatives which go well together and provide genuine options for
further development and appraisal.
Of course the role of the planner in this process should not be passive. There
is real scope for imaginative leadership and advocacy to persuade the various
interested parties of the merits of options and win their support. A lucid plan
which self-evidently tackles the key issues and seeks to harness opportunity
can be used build consensus and drive forward delivery.
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