Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by the Wildlife and Countryside Link (PGP 50)

  Re: Wildlife and Countryside Link's Response to the Planning Green Paper Planning: delivering a fundamental change.

  I have pleasure in enclosing the submission from Wildlife and Countryside Link (Link) on Planning: delivering a fundamental change. Our response consists of a summary statement and four papers on the key issues that we identify arising from the Green Paper—sustainable development, strategic planning, regional and sub-regional planning, and Local Development Frameworks.[30] We include recommendations on each issue that are intended to provide workable solutions to the problems highlighted in the Paper. This submission is supported by 17 organisations.

  Link brings together environmental voluntary organisations united by their common interest in the conservation and enjoyment of the natural and historic environment. Link considers that the planning system has a major role to play in protecting, conserving and enhancing our quality of life and our environment. A number of Link members are very active in land use planning policy issues. Planning emerged as a priority for Link members in 2002.

  Link recognise the need for change in parts of the planning system. However, we believe that some of the wholesale changes proposed may have the opposite effect to that intended. They could reduce certainty and increase delay. Although some proposals are welcome, for instance some recommendations relating to development control, others cause us considerable concern.

  We believe that sustainable development must be at the heart of the new planning system. Despite making the right noises in the objectives section, we believe the proposals that follow in the Green Paper will not deliver a "planning system with sustainability at its heart" (Sally Keeble, 31 January 2002). We believe this could be achieved by a duty to further the achievement of sustainable development in a new Planning Act.

  We are deeply concerned by the proposal to abolish democratically accountable strategic planning. If strategic planning is abolished at the county level, it seems clear that something similar will be needed in its place. We do not believe that convincing evidence has yet been advanced to justify this proposal. If a reformed model for sub-regional strategic planning is pursued, it must comply with the criteria that we set out in our submission.

  We are concerned that the Regional Spatial Strategies will lack democratic accountability. This will undermine the public's faith in the planning system. The democratic deficit must be resolved at both regional and sub-regional level. We also believe that sub-regional planning needs to be more comprehensive than envisaged in the Green Paper. Regional Sustainable Development Frameworks and the Regional Spatial Strategy should provide the overarching policy framework for all other regional strategies.

  We are concerned that the Local Development Frameworks lack comprehensive map-based coverage. Their constant updating and the lack of full map-based coverage will, we believe, create uncertainty and increase the burden on business, householders and other "users" of the system, the LDF model could be so vague as to render this principle almost meaningless.

  We would be happy to discuss our concerns about the Green Paper and ideas for planning reform.

Mark Southgate

Chair of Link's Land Use Planning Group

March 2002

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