One of the advantages of this blog, I hope, is that we can be a bit more straightforward with each other. Over on our main site, everything is mediated by the need to be professional and courteous. I wouldn’t have it any other way, but it does mean that we risk some of our most crucial bits of advice being missed by busy people because they are framed in such polite ways and hedged around with updates on planning fees, neighbourhood planning and all the rest of it. So, I’ll use this space to spell out what is by far the most important message of all: GET MOVING ON YOUR LOCAL PLAN.
Your toes are to the fire
Much has been said before about how long it has taken to take on the LDF system introduced in 2004. Some of the encouragement has been positive. PAS, for example, is funded to help places respond to it (and subsequent reforms). Increasingly, though, it feels like cooperation is being withdrawn from those places unwilling or unable to adopt a plan. Your toes are being put to the fire – if you don’t make a plan then you can expect a series of increasingly uncomfortable sensations.
The biggest and most obvious change agent is the localism bill, coupled with the NPPF and the budget statement. The chair of our environment board put it as plainly as he could :
getting your local plan in place […] is particularly important in light of the forthcoming presumption in favour of sustainable development. Having a robust local plan in place is the only way to be able to shape development locally.
You don’t need to pin down all the details to sense the forthcoming ‘rock’ and ‘hard place’. The rock is the national presumption in favour – unless you can prove the development does harm you must permit it. The ‘hard place’ is the potential for a patchwork of conflicting neighbourhood plans. Without an overarching local plan you will be unable to have a sensible discussion about the broader goals for your place, with the consequent risk of being pulled in many overly-local directions.
And yet, our work programme includes the names of just over 150 councils that we suspect will not have a local plan before the enactment of the localism bill. Perhaps this number should be higher, to include those who may have a sound core strategy under previous arrangements but might be patchy without RSS policy, unable to guide neighbourhoods or demonstrate sufficient commitment to the duty to cooperate. Still others may have a plan that no longer enjoys the confidence of the councillors who may have felt the housing targets were unfairly hoisted onto them.
There are yet more milestones – the removal of any remaining ‘saved’ policies, the constraints placed on Section 106 arrangements from April 2012. The recent consultation on planning for traveller sites follows this new hardline – its suggestion for transitional arrangements is that you have six months in which to demonstrate a 5-year supply. After which, you must “consider favourably” any such applications. This tells you how long government thinks a DPD should take*.
So what ?
When taken together, I don’t think there is anything new going on – just a ramping up of the pressure on three areas:
- Strategic decisions are difficult. Some places have chosen to leave the decisions for another day, feeling that the risk / reward doesn’t work politically. These policy changes I’ve outlined above mean that the “do nothing” cost becomes significant. Without making strategic decisions (including politically awkward ones like growth) you lose control and therefore credibility with the electorate.
- Change is the enemy. Planning has been a whirlwind. Local government more generally hasn’t exactly stood still. It is tempting to wait for the time that everything becomes clear. This isn’t going to happen. Just as the secretary of state refuses to define ‘localism’ many aspects of the new planning system are only going to become clear as people actually make local plans in a confident, less rule-based way.
- Planning is too important to be left to the planners. A local plan really needs to be driven by a powerhouse of CEx and leader. Both of whom should be able to create enough consensus that you don’t need to return to square 1 whenever there is an election or announcement. A worrying number of planners are left disenfranchised and unclear about whether they are sanctioned to make progress or not.
So what to do ? Don’t let the fire get to your toes. Plan-making is no longer an open-ended process, and you need to be make the best plan you can in the time available. You might surprise yourself.
* Or, possibly, the updating of a more strategic DPD with evidence and partial revision of policy. I haven’t quite worked it out under the old system, let alone under the new.