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
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 Papersustainable development, strategic planning,
regional and sub-regional planning, and Local Development Frameworks.
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
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
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.
Chair of Link's Land Use Planning Group
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