Memorandum by the Royal Institute of British
Architects (PGP 40)
PLANNING: DELIVERING A FUNDAMENTAL CHANGE
The members of the Royal Institute of British
Architects and the Royal Institution of Chartered Surveyors are
major professional users of the planning system. Representatives
of these organisations have met to discuss the proposals contained
in the Green Paper and have agreed a joint response on a number
of issues for your consideration.
Each organisation will respond individually to
the DTLR on other detailed issues
The RIBA and RICS welcome the recognition by
Government of the need to provide a planning service that has
clarity, is accountable and is efficient. This memorandum takes
these three key points as its headings, and where appropriate,
refers to the points identified by the Select Committee as being
of particular interest.
It is appreciated that the Green Paper is concerned
with the planning system as process and not as product. The proposals
would have benefited from being set against a clearer outline
of the whole planning process and a core statement of the purpose
and principles of planning.
After 50 years of post-war Town and Country
Planning legislation and guidance it is not surprising that the
planning system has become complex to us and to execute. As they
stand the development and application of many of the proposals
set out in the Green paper do not impart confidence that they
will deliver the improved planning system that is needed.
Planning guidance and development plans have
the dual function of directing the form and nature of development
and providing a measure against which proposals for development
can be assessed and determined. To make the planning process more
effective it is vital that both guidance and plans offer clarity,
avoid duplication and are responsive to emerging social, economic
and environmental needs.
Effectiveness of system of local plans and Government's
proposals to replace them
The proposals setting out a new order and form
of development plans, ranging from Regional Spatial Strategies
and Local Development Frameworks to a range of Action Plans which
have to be allied to Community Strategies and Local Transport
Plans are, on the limited evidence offered in the Paper, seen
as a patchwork of plans rather than providers of clarity through
seamless sequence and content.
It is essential that these plans contain clear
and unambiguous policies and proposals reducing to a minimum the
level of discretion that is required for interpretation. It is
suggested that development plans are simplified and adopt, wherever
appropriate, model policies to do so will assist with the speed
of determining planning applications. There is also concern that
it may not always be practical to regularly update local plans
as Local Authorities may not have the resources to do this.
Role of regional planning bodies
If it is accepted that the planning system should
be conducted within the democratic process, and we firmly believe
that at every level democracy must be the rule so that decisions
about people's enjoyment of their property should not be made
by a higher authority, then the proposition of endorsing the principle
of Regional Spatial Strategies is premature until the democratic
arrangements for Regional Government in England have been agreed.
Procedures for scrutinising major development
The proposal that major projects in the national
interest should be determined by Parliament is supported, provided
they are done so in the context of a national statement of planning
Whether the Government's proposals will simultaneously
increase certainty, public participation and faster decisions,
particularly for business
The need to provide adequate resources for local
planning authorities is supported and to this end the proposals
to increase planning fees are endorsed, providing this extra income
is directed to improving resources.
The proposal that the time allowed for an applicant
to appeal a planning decision be reduced from six months to three
months is not supported; we feel that the six month period should
The proposal that the life time of a planning
consent be reduced from five years to three years is not supported;
we feel that the five year life time should remain but that it
should be made clear that a renewal of the consent at end of the
five year period is not automatic.
The range of fees proposed is complex and there
is concern that they will become a source of bureaucracy. By paying
fees the user is entitled to a service and there need to be fair
provisions for the user to invoke penalties if an agreed level
of service is not provided. In return the user as the planning
applicant should be required to make available a professional
quality of information responding to the proposed checklists,
not only to assist the planning process but also to achieve good
The proposal that local planning authorities
should engage the assistance of the private sector, both in the
preparation of plans and the determination of applications to
assist efficiency, is supported.
The proposal that Local Authorities should be
able to extend the range of Permitted Development is supported,
provided there is also a clear national policy.
Consultation can both assist and hinder development.
The principle of consultation is supported provided it is controlled
and responsible. A clearer framework and guidance for involving
third parties in the planning system is required. This involvement
should not extend to the right of appeal by third parties, which
would clog up the planning process. Similarly, other proposals
such as refusing repeat applications are supported.
This memorandum of necessity contains the "headline"
comments of two professional organisations that agree on some
of the issues by this Green Paper. We do not agree on every issue
as will be apparent from our individual submissions. We hope that
the appropriate parliamentary time will be accorded to allow for
the development and implementation of the responses to the Green
paper as soon as possible.
RIBA Planning Policy Group Administrator