In January 2017, the Scottish Government published a consultation paper (“Places People and Planning”) which provided details of the proposed changes to the planning system in Scotland. This was in response to an independent review of the Scottish planning system in May 2016, “Empowering Planning to Deliver Great Places”.
NTBCC submitted comments to the initial independent review in August 2016 (which can be viewed here) as well as responding to these latest Scottish Government (SG) proposals, titled “Places People and Planning“ ; this April 2017 NTBCC submission can be viewed here.
Overall, NTBCC were disappointed in the SG response to the Independent review’s recommendations. Planning should and can provide a long-term perspective, tackling important issues such as development delivery, health, inclusion, environmental quality and climate change. But the SG response is too vague; containing too many aspirational proposals and too much “sloganeering” with too few practical detailed actions. The importance of creating “place” is barely touched on. Despite statements about increasing “people” involvement, too many of the suggestions imply drawing control into the centre. We believe that considerably more work is required to redress these issues and we hope that following further consultation, a more meaningful proposal will emerge.
Key NTBCC comments to the latest SG proposal include :
- Questioning the lack of defined role for Community Councils in “Community Partnerships” (which are aimed at aligning community planning and spatial planning) and further examination of Community Councils’ status within the formal planning process.
- Concern over the very limited statements covering the role of planning in achieving high quality place making, urban design, landscape and architecture. We believe that the aims should be rewritten to include protection and enhancement of our distinctive places and high quality environment; ensuring that changes are in keeping with and of comparable quality with the established townscape.
- The real or perceived effectiveness of the Pre-application consultation process and the need to lower the threshold for what constitutes a “major development”.
- Raising many concerns with the current planning process which undermine public trust e.g. questionable decisions following appeals ; accountability of Councillor’s decisions (no record of individual votes) ; attritional approach to gaining approval by some developers by resubmitting almost identical applications; lack of enforcement (adequate powers exist but local authorities frequently too timid or risk-averse to exercise them) ; concern over the decision-making process where the local authority is also party to the development.
- Questioning the absence of proposals to extend the right of appeal to objectors in certain cases e.g. when an application has been approved (often on appeal) contrary to the officials’ recommendations and to the council’s own adopted policies ; or where the local authority has a financial or other interest.
- Support in principle for an infrastructure levy for specific developments but with some caveats.
- Support for increasing planning fees for larger developments to reflect the added complexity but noting that this needs to provide a more dedicated service.
- Ensuring that the planning service is properly trained and resourced to deliver good planning.
Thanks to Stephen Hajducki for drafting this response for NTBCC.