As part of the ongoing review of the Scottish planning system RTPI Scotland has produced a series of thinkpieces aimed at providing workable solutions to supplement the proposals made by Scottish Government in its consultation paper, Places, People and Planning. A thinkpiece by Pam Ewen and Robbie Calvert synthesises a new Local Development Plan process that will help to simplify and strengthen the planning system.
The changes proposed to the LDP process in Places, People and Planning are extending the cycle to 10 years, removing the Main Issues Report and Supplementary Guidance and introducing an early ‘gatecheck’.
The restructured LDP preparation process that will be required to accommodate these changes must be underpinned by project management principles. This will ensure that the plan is led, managed and risk assessed to provide stakeholders with more confidence.
The New LDP Preparation Process
Alignment with Community Planning
This stage provides the opportunity to integrate spatial outputs from the Community Planning process such as Local Outcome Improvement Plans and Locality Plans. This should be seen as part of an on-going feedback loop ensuring that spatial planning reflects Community Planning priorities, and vice versa.
Call for Issues and Promoter Engagement with Communities
Early engagement between promoters of sites and communities would improve transparency and public trust. A broader “Call for Assets and Ideas” could be incorporated at this stage, further improving the link between community planning and spatial planning. Here communities and public agencies could identify buildings and land suitable for transfer to community ownership, promoting retention, development or investment of unused assets.
The thinkpiece proposes a two-tiered gatecheck process, discharged by a small panel with a balanced composition of key stakeholders operating under a peer review system. The first gatecheck would be for evidence gathering, to enable preparation of a robust plan. Evidence to be considered by the panel would include:
- National requirements
- Audit of existing infrastructure including transport capacity
- Housing land requirements
- Employment land requirements
- Spatial outcomes from Community Planning including Local Place Plans
- Flood risk data
- Utilities data
- Economic projections
- Air quality
Once the panel is satisfied that the evidence is in place it would be the responsibility of the relevant development planning team to scope the plan based on this evidence.
The second gatecheck would then involve the panel reconvening to ensure the scope of the plan reflects the evidence base assembled under gatecheck one. At this stage, key agencies should also be obligated to support or object to the principle of any proposed development site.
Inputs and checks should include:
- Mandatory input from key agencies
- Conformity with national planning policy
- Links to Community Planning
- Local government corporate policy
- Identification of areas of agreement, disagreement and risk between the local authority and panel members
Costs associated with the gatecheck stages should be absorbed by the Scottish Government as part of its contribution to frontloaded plans.
To ensure that the final examination by the DPEA is fast and cost effective, focus should be restricted to:
- Non-compliance with national and regional policies only
- Major developments e.g. housing sites more than 50 units
- A maximum timescale for DPEA to consider examinations
Adoption and Updates
Considering the shorter preparation time and lengthier implementation period, RTPI Scotland believes that there will be a role for non-statutory supplementary guidance in order to keep LDPs flexible and up-to-date. Triggers for updates will be restricted to major changes in circumstance and context, which could be defined in legislation or guidance.
Resource and Skills Implications
Given the proposed extended life of the plan it will be crucial to ensure that the necessary development planning skills are retained between plan cycles. After plan adoption, planners should be focused on plan delivery, assisting in implementing proposals and sharing and utilising skills across planning authorities. Moving towards full cost recovery of the development management process through the ring-fencing of planning application fees will allow resourcing in the planning system to be reallocated towards development planning and the costs associated with frontloaded plan preparation.