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Publication - Consultation Paper

Places, people and planning: consultation on the future of the Scottish planning system

Published: 10 Jan 2017
Part of:
Building, planning and design
ISBN:
9781786527363

We are seeking views on proposals to strengthen the planning system.

54 page PDF

333.9kB

54 page PDF

333.9kB

Contents
Places, people and planning: consultation on the future of the Scottish planning system
01 Making plans for the future

54 page PDF

333.9kB

01 Making plans for the future

We want Scotland's planning system to lead and inspire change by making clear plans for the future.

Proposal 1

Aligning community planning and spatial planning

Proposal 2

Regional partnership working

Proposal 3

Improving national spatial planning and policy

Proposal 4

Stronger local development plans

Proposal 5

Making plans that deliver

1.1 - Development plans should provide a clear vision of how a place can grow and flourish. They should be of interest to everyone and inspire the confidence of communities and investors alike. Change is needed to make that happen and ensure plans better reflect the needs and expectations of society now, and in the future.

1.2 - Plans should show where development will happen, and how our places may change over time. They should help us to design and deliver places where people can lead healthier lives, move around easily and have access to the homes, services, facilities, education and employment they need. They should set out a vision for places which are low carbon and resilient to the future impacts of climate change. Our planning system evolved to provide healthier places for people. We need to make sure that purpose continues to guide the plans we prepare today.

1.3 - At present development plans are often complex, focused on technical written policies and restricted by procedures, rather than being inspirational and creating confidence. It can be difficult for people to understand what change is proposed, why it is needed, and where, how and when it will happen. Developers and investors also need to have confidence in a plan. While there are examples of good practice around the country, there is also often frustration with the process required to prepare them. At present, many plans are considered to be out of date by the time they are adopted - we need plans that can keep pace with the way that society works today.

1.4 - Our proposals aim to simplify the existing system of development plans to make sure that planning authorities, and those they work with, focus on delivering outcomes rather than following lengthy and complicated procedures.

Proposal 1: Aligning community planning and spatial planning

1.5 - The independent panel found strong support for a plan-led system. We want to see plans that allow planners to lead and innovate, delivering priorities that have been agreed through an open and evidence-led process.

1.6 - Given the range of interests involved in planning, there should be an open and inclusive approach to understanding issues, considering options, defining priorities and agreeing proposals. People are at the heart of the system and our proposals seek to build more effective opportunities for people to influence their places. A much wider range of stakeholders, including all relevant local authority services, communities and developers, should share ownership and responsibility for preparing, promoting and delivering development plans. One of the keys to this is making sure that local authorities recognise the value of the development plan in realising their corporate objectives.

1.7 - We propose introducing a statutory link between the development plan and community planning. This link could be achieved by ensuring that development plans take account of the work of Community Planning Partnerships. We will also support this as we bring forward guidance on both community planning and spatial planning. Co-ordinated working and including planners as key community planning partners will be essential.

Aligning Community Planning and Spatial Planning - East Ayrshire

The East Ayrshire Community Plan 2015-2030 sets out aspirational outcomes for East Ayrshire in the coming years. There are three shared priority areas, led by different community planning partners: Economy and Skills (East Ayrshire Council); Safer Communities (Police Scotland); and Wellbeing (the Health and Social Care Partnership). The East Ayrshire local development plan reaffirms the shared vision - in particular, the drive to promote the economy and skills is fully embedded across all aspects of the plan. The plan was used to explore land use issues including strategic locations for development, infrastructure and town centres. Key to the success of this alignment were partnership working, a shared focus on outcomes, governance and dynamic leadership.

Proposal 2: Regional partnership working

1.8 - The Planning etc. (Scotland) Act 2006 reflected a two-tiered system of development plans, with strategic development plans covering our largest city regions (Glasgow, Edinburgh, Perth and Dundee, and Aberdeen) and local development plans for each local authority and the two national parks.

1.9 - At present, strategic development planning authorities are tasked with preparing a plan which is approved by Scottish Ministers after a comprehensive examination process. The procedures for preparing strategic development plans mean that there is little time to actively work on delivering them. Strategic development planning authorities have no duties or powers to make sure their plans have a strong influence, either nationally or locally.

1.10 - The independent panel recommended that strategic development plans are removed from the system and that we should focus instead on co-ordinating development and infrastructure at this scale. We agree, but we recognise that strategic planning has an important contribution to make to delivering a high performing planning system. Any changes to the system should support cross-boundary collaboration, and improve the co-ordination of strategic development and infrastructure priorities.

1.11 - Planners working at a regional scale should play an active role in partnership working. Strategic planners could add significant value by helping to shape future spatial priorities for investment and providing timely evidence to support stronger joint decision making. Planning should contribute to wider regional activities, including economic and social infrastructure delivery, as well as supporting a clear dialogue between national and local tiers of government. Working together at a regional level would also allow local authorities to combine resources and share potential risks.

1.12 - We agree that strategic development plans should be removed from the system, so that planners can better respond to and be involved in wider regional partnership working. Instead, we propose that the National Planning Framework ( NPF) sets out regional planning priorities. By incorporating regional strategies at a national scale we would remove the procedural requirements associated with preparing and adopting four stand-alone strategic development plans. This would also give more weight to the spatial strategies for the regions as the National Planning Framework ( NPF) is prepared and adopted by Scottish Ministers with input from the Scottish Parliament.

Regional working

1.13 - We propose to replace these plans with new duties or powers for local authorities to work together on defining regional priorities. Views on what needs to be done at this scale are invited, but we suggest that the following actions would be beneficial:

  • Helping to develop a strategy and delivery programme to be adopted as part of the National Planning Framework ( NPF). We would want to see regional partnerships working with the Scottish Government, agencies and local authorities to make sure there is evidence to support the National Planning Framework ( NPF) and then to implement their regional commitments through the delivery programme.
  • Co-ordinating the work of local authorities to support the aspirations for housing delivery, as set out in the National Planning Framework ( NPF).
  • Bringing together infrastructure investment programmes to promote an infrastructure first approach, provide a co-ordinated audit of economic and social regional infrastructure, identify the need for strategic investment and support necessary cross-boundary working.
  • Co-ordinating funding of infrastructure projects, potentially including an infrastructure levy, and working with others, in both the public and private sectors, to develop regional funding and finance packages that support their strategies for growth.
  • Acting as a 'bridge' between local and national levels by making sure that local development plans support the delivery of wider strategic priorities. Partnerships involving business representatives as well as the public sector could provide a forum where regionally significant matters and common goals can be discussed and used to inform local strategies and development planning.

1.14 - We would welcome views on the above actions. We believe they could form the basis of new duties to help planning authorities to be actively involved in regional partnership working. We are also open to considering making these actions discretionary powers which allow local authorities to decide whether this level of co-ordination would be of value. We would welcome views on working arrangements and governance. We are keen to avoid creating new partnerships where tasks can be achieved through existing arrangements.

1.15 - Within the above context, the ongoing review of the National Transport Strategy and the consideration of regional partnership working. We would also welcome views on the potential to reconsider the roles, responsibilities and areas of influence of regional transport partnerships in relation to land use planning and associated transport appraisals, prioritisation and delivery.

Regional geography

1.16 - The way in which local authorities and their partners are currently working together at a regional scale is dynamic, and this is relevant to the future of strategic spatial planning in Scotland.

1.17 - The emerging Tay Cities Deal (Perth and Dundee, together with Angus and the North of Fife) is bringing together economic development, planning and transport programmes to provide a joined up and branded approach to supporting future investment. In South East Scotland, regional planning and transport functions are increasingly aligning and linking with economic development and proposals for a city region deal. The three Ayrshire authorities are working together to prepare their own 'growth deal'. Joint working on the Glasgow and Clyde Valley City Region Deal, driven by economic development, is now established and moving forward. Aberdeen City and Shire have a long tradition of co-operation to provide a North East perspective on growth and development and their city deal supports taking this forward with strong private sector representation.

1.18 - There is also wider work across all seven cities, supported by the Scottish Cities Alliance. Regional land use partnerships, to help deliver the aims of the Land Use Strategy, will be explored further. Regional Marine Partnerships are being established to undertake marine planning. Our commitment to addressing climate change is also driving wider partnership working, for example in the Climate Ready Clyde Project. [1] The ongoing enterprise and skills review [2] has been exploring the regional geography of economic development and includes proposals that combine stronger national oversight with additional regional coverage for the South of Scotland and developing regional partnerships across Scotland. This could also connect with emerging work on the development of a Scottish Rural Infrastructure Plan.

1.19 - All of these arrangements are potentially relevant to the future of strategic planning. We need planning to respond to changing regional priorities and groups, rather than focusing on fixed boundaries. We propose that existing strategic development planning authorities form part of, or are replaced with, partnerships whose membership extends beyond planning to include all those with a role in planning, prioritising and delivering regional economic development and investment in infrastructure.

1.20 - We would welcome views on the following options for the scale and coverage of regional partnership working:

  • Rather than defining or fixing the boundaries of partnerships which may or may not reflect changing regional partnerships that emerge over time, local authorities could define the geography of their involvement in regional partnerships locally. This would allow, for example, strategic planning to better align with emerging city and growth deals.
  • We could link strategic planning with the ongoing Enterprise and Skills Review and its proposals for regional working covering the Highlands and Islands, South of Scotland and regional partnership network.
  • We could use the National Planning Framework ( NPF) to identify priority areas where future regional partnership working should take place.

The Tay Cities Region - Partnership for Growth

The opportunity to secure a City Region Deal has brought together the leaders and chief executives of local authorities across the region to work together as a strategic partnership. The four authorities (Angus, Dundee City, Fife and Perth and Kinross Councils) are collaborating with their Community Planning Partners, the private sector and voluntary organisations to develop and deliver on an agreed vision for the region as a distinctive place. The partnership has identified how the region's potential can be unlocked, including by supporting key growth sectors and fostering innovation and skills development. The need to address social and economic inequalities in both urban and rural areas and support transport and digital infrastructure investment are also identified as key regional priorities.

Proposal 3: Improving national spatial planning and policy

1.21 - The role of Scotland's National Planning Framework ( NPF) has developed and grown since the first, non-statutory NPF was adopted in 2004, and through its two versions as a statutory document in NPF2 (2009) and NPF3 (2014). [3] We want to build on the growing awareness of NPF, and support our proposals for stronger co-ordination of regional planning by producing a spatial strategy that is prepared following even more joint working and involvement.

Alignment with wider policy

1.22 - We have already announced in the Programme for Government [4] that the next Strategic Transport Projects Review ( STPR) will be in line with the next iteration of the National Planning Framework ( NPF) and a review of the National Transport Strategy is underway and will inform the next STPR. We recognise that we should consider spatial planning priorities as part of future reviews of the Infrastructure Investment Plan. This will allow for spending on infrastructure to be more clearly aligned with proposals for future growth, regeneration and development.

1.23 - We will continue to ensure that the National Planning Framework ( NPF) brings together wider Scottish Government policies and strategies across all sectors, including but not limited to the Scottish Planning Policy ( SPP), Energy Strategy, Climate Change Plan and Scottish Climate Change Adaptation Programme, Land Use Strategy, Digital Strategy, National Marine Plan and our national policy on architecture, Creating Places. We will also ensure that planning at this scale maintains its role as the spatial expression of Scotland's Economic Strategy.

1.24 - An enhanced national spatial strategy which provides greater clarity on regional priorities (informed by the work of regional partnerships) would have greater significance and relevance across Government policy areas. We therefore propose building on the provisions for the National Planning Framework ( NPF) introduced by the 2006 Act by:

  • Extending the review cycle to 10 years (with a 30-year vision), whilst making provision for interim updates to be made where necessary.
  • Extending the existing period of 60 days of Parliamentary consideration to 90 days to allow for enhanced transparency and national democratic engagement.
  • Giving the National Planning Framework ( NPF) (together with the Scottish Planning Policy ( SPP)) stronger status. Consistency of local development plans with the National Planning Framework ( NPF) should also be independently tested and confirmed.
  • Working closely with infrastructure providers to contribute to the delivery of the National Planning Framework ( NPF). This will require careful consideration owing to the varying roles, responsibilities, legal and regulatory context within which each infrastructure provider works. A delivery programme for the National Planning Framework ( NPF) should be developed in close collaboration with regional partnerships and there should be a strong sense of shared ownership of the actions it contains.

Streamlining planning policy

1.25 - Despite the aims of previous reforms for local development plans to be map-based, many are still lengthy and include a great deal of policy content. We believe this needs to change and that the National Planning Framework ( NPF) and Scottish Planning Policy ( SPP) could better support the planning system by having a stronger statutory status. This could be achieved by either making them part of the statutory development plan, or by ensuring that both are given due weight in decision making through their local implementation.

1.26 - Depending on the changes that are taken forward, we would consider whether the Scottish Planning Policy ( SPP) preparation process also needs to be updated. For example, if it is given statutory weight, the Scottish Planning Policy ( SPP) could be prepared alongside the National Planning Framework ( NPF) and given the same level of consultation and consideration by Parliament.

1.27 - Either option could allow local development plans to focus on providing a clear and engaging spatial strategy, rather than acting as a rule book for decision making with very detailed and repetitive policies. However, place-based planning must recognise and reflect the diversity of planning in different parts of the country. Local development plans could still include policies where they are required to identify departures from the Scottish Planning Policy ( SPP) that are justified on the basis of distinctive local circumstances.

Proposal 4: Stronger local development plans

1.28 - As well as being engaging, development plans need to be strong and practical. Building on previous reforms, our proposals aim to ensure local development plans can better respond to their changing context. We agree with the independent panel that the 'main issues report' has not been an effective way of involving people. For consultation to be more effective, planning authorities should produce draft plans which are easy to access and understand, and set out clear proposals for people to comment on. It is important that draft plans are fully informed by robust evidence from the outset. We also agree that the lifespan of plans should be longer, and the time it takes to prepare them should be reduced.

1.29 - We propose the following changes to local development plans:

  • Removing the requirement for a main issues report to be prepared and consulted on. We would replace this with a requirement for a draft plan to be published and fully consulted on, before it is finalised and adopted. This would mean responses to the draft plan could be used to guide changes, and these changes could be explained in feedback to those who have been involved.
  • Requiring local development plans to be reviewed every 10 years. We agree in principle with the independent panel that there should be a shorter plan preparation period to allow more time to focus on delivering the plan. However, we believe this could be better supported through guidance and training rather than by setting a fixed period.
  • Making provision for plans to be updated within the 10-year review cycle. This would allow plans to be more responsive to change, but care will be required to avoid confusion. Our view is that the 'triggers' for updating a plan could be outlined nationally and agreed locally to provide some stability and make sure that plans are flexible but not in a constant review cycle. This is intended to improve scope to focus on delivery.
  • Removing the provisions for statutory supplementary guidance to form part of the development plan so that people can find out everything they need to know about the future of their area in one place. This will mean that important content is included in the main body of the plan and therefore subjected to full consultation and scrutiny through the examination process.

1.30 - Alongside these changes, we propose working with local authorities to better define the relationship between development plans and development management, and the role of non-statutory supplementary guidance in informing decision making. At both the national and local level, there would be benefit in streamlining planning guidance on specific types of development, to provide a manual or set of advice that guides how applications for planning consents are considered. This would help to remove significant amounts of policy detail from the development plan.

Examinations

1.31 - We accept the independent panel's view that local ownership and responsibility for the development plan is undermined by current arrangements for a centrally administered examination of the plan, which is undertaken at the end of the preparation process. Current arrangements can be lengthy and result in a significant financial cost to local authorities. As the examination takes place late in the process, it is very difficult to address any significant issues that are outstanding at this stage.

1.32 - It is important that a clear national and regional picture of requirements informs local development plans. However, decisions on the future of a place, including where development should happen, should be made locally, and local people should be fully involved. We want to ensure that people have more meaningful opportunities to influence where development should take place. However, this needs good evidence and input from professionals, so that everyone involved can properly understand the level of development required and how an area can support it, before specific development sites and proposals are considered and agreed.

1.33 - Many people value the credibility that comes with a rigorous and independent process of scrutiny provided by examinations. Some planning issues can be very challenging and difficult decisions should not be avoided. Independent scrutiny can help to establish what is needed from a plan, that appropriate information has been gathered, that people will be properly involved and that, ultimately, developments will be delivered in line with the vision in the local development plan.

1.34 - We do not suggest removing examinations altogether but we agree with the independent panel that earlier scrutiny in the plan preparation process would be helpful. We propose that plans should be 'gatechecked' by an independent reporter at an early stage before the draft plan is prepared. Planning authorities would need to pass this stage before they can go ahead with developing and consulting on their draft plan. The gatecheck would establish whether the technical evidence is sufficiently sound to prepare a deliverable spatial strategy. We believe the following matters could usefully be assessed at this early but critical stage:

  • That the development plan scheme sets out how the local community will be involved in developing proposals for change and has been framed in consultation with the relevant community councils.
  • That the plan takes account of community planning.
  • That the key outcomes required from the plan have been clearly defined.
  • That the amount of land needed for housing over the plan period has been agreed.
  • That the required environmental assessment work, including a flood risk appraisal, is carried out.
  • That there has been an audit of existing infrastructure levels and necessary interventions have been prioritised, including the plan's transport appraisal and other types of infrastructure

1.35 - We propose that gatechecks are chaired by independent reporters from the Directorate for Planning and Environmental Appeals ( DPEA) and supported by relevant specialists. Including the views of a citizen's panel at this stage would also support our broader aim of empowering communities. If necessary and appropriate, consideration could be given to using professional mediation to further resolve any issues arising at this stage.

1.36 - We recognise that as the preparation stage of a plan progresses, there may still be some issues to deal with and that an examination towards the end of the process may still be needed. Before the plan is finalised, we propose that unresolved issues would still be dealt with by an examination. We expect that the earlier gatecheck would mean there is less scrutiny at this stage and that this would reduce costs and timescales.

1.37 - Alongside these proposals for change, we believe we can work with planning authorities to make sure that the evidence base for local development plans is more streamlined and effective. Research into the Strategic Environmental Assessment ( SEA) of development plans is underway, with a report due to be published later this year. We expect the findings of this research will help us to better understand how future assessment and reporting requirements could support and be proportionate to a new planning system. We have also made proposals on planning for housing in section 3 which aim to simplify requirements for defining housing figures within development plans.

1.38 - The whole local development plan process must be accompanied by strong project management and this should be a priority for further planning skills development.

South Ayrshire Local Development Plan ( LDP)

The 2016 overall winner of the Scottish Awards for Quality in Planning was South Ayrshire Council. Its South Ayrshire Local Development Story Map is an online, interactive LDP, designed to be in a user-friendly and non-technical format. Layers of information, reflective of the local area, and building on a solid approach to mapping, have led to transformational change across the authority.

Proposal 5: Making plans that deliver

1.39 - Decisions on planning applications should be made in accordance with a development plan which has been properly evidenced and prepared with the involvement of local people. However, at present some practices undermine the role of development plans. We want that to change, so that allocation of a site in a development plan gives more certainty that development will happen.

1.40 - Where a plan is prepared with the local community and developers, it should be accepted that other proposals, which could undermine the plan's aims, will only be supported following additional scrutiny. Local authorities and infrastructure providers should be clear that they have shared responsibility to fulfil the commitments set out in the plan.

1.41 - Proposed housing developments should be fully supported by the development plan. For developers and investors, an allocated housing site within a plan should bring certainty and confidence in the principle that development of the site will proceed in line with the delivery programme, providing more detailed considerations are addressed. Infrastructure providers also need to be convinced that allocated sites will be taken forward as programmed. Greater confidence in the deliverability of allocated sites should also mean there is greater confidence that other areas will be protected.

Planning permission in principle for allocated sites

1.42 - We commissioned research [5] to consider whether planning permission in principle should be attached to allocated sites within the development plan. The research has found that there is 'conditional support' for the proposed reform, but that this is 'complex and nuanced.' We have reservations about the amount of upfront work that would be needed to achieve this, and the implications arising for all those concerned as well as for development planning procedures. This would also need to be fully in line with and meet all European obligations for environmental assessment.

1.43 - Whilst we agree that this approach has potential benefits, we are concerned that it may provide limited benefits which do not outweigh the extra time and complexity it would add. We would like to hear people's views on whether this change would be either necessary or helpful, taking into account the research findings. We believe that a more strategic, zoning approach to housing allocations, such as improving the use of Simplified Planning Zones, could be a simpler way of strengthening the development plan and establishing the need for development at an early stage (see section 3).

A stronger commitment to delivery

1.44 - There are other ways in which plans can provide more certainty. We propose the following:

  • Setting out the minimum level of information needed to support allocations within the development plan. This will ensure consistent information is available and that there is enough detail to allow the planning authority to make an informed appraisal. It will also increase confidence that if a site is included in a plan, it can be delivered.
  • Information on site assessment to be submitted by the site proposer and appraised before any site is allocated in the plan. This would include economic and market appraisal information to provide greater confidence about the effectiveness of sites and when they can be delivered. This could also allow for closer monitoring of performance. We recognise that this could have implications for resources - we would consider the practicalities of this in more detail if it is agreed that it should be taken forward.
  • Encouraging a broader, zoned approach to meeting short and longer-term housing needs. Rather than piecing together individual sites promoted by developers, we want planners to have the confidence to guide how an area should grow over the long term. Priority sites should also be identified and enabled as far as possible.
  • Stronger measures for public involvement for sites that have not been included in the plan. There must be good involvement in the development plan, so that sites which are allocated are fully discussed with communities before they are confirmed as allocations. For sites where there has not been this involvement as part of the plan making process, we think it is reasonable to expect developers to engage more with communities. Our proposals for fees (section 4) and increased community involvement (section 2) support this. It could also be argued that there should be less consultation on allocated sites, for example by reducing or removing requirements for consultation before the application is made. We would welcome views on this.
  • Working with the statutory key agencies to make sure that their engagement at the development plan allocation stage is meaningful and informed by appropriate evidence. If they have agreed to a site being allocated in a plan, the key agencies and other infrastructure providers should not be in a position of advising against the principle of development on the site later on, unless there has been a clear and significant change in circumstances. Further front loading of engagement and evidence gathering in this way could have resource implications that will need to be considered further.

Programming delivery

1.45 - Plans must lead to development on the ground. In practice this has proved challenging. While planning can set out what should happen in the future, achieving this depends on partnership with and buy-in from a wide range of public and private sector bodies.

1.46 - We propose replacing 'action programmes' which support development plans with stronger 'delivery programmes' which have a clearer purpose. Delivery programmes would be a more major part of the development plan and we would want to see a stronger requirement for local authority-wide involvement in them, as well as other stakeholders with an interest in their delivery. We would expect delivery programmes to be detailed and practical. We would also expect planning authorities to monitor the programmes to identify whether commitments to deliver are being met. There may be scope for wider improvements to how information is managed to support delivery programmes. This will be considered further by the digital task force (section 4).

1.47 - A sharper focus on delivery could introduce extra demands on time and resources for local planning teams. The move towards a longer review period is also intended to enable a stronger focus on delivery to emerge. Wider expertise may be required to address matters such as development economics, programming and costing of infrastructure. However, this would be a worthwhile investment if it leads to a far more thorough assessment of how the plan performs and stronger evidence for action. It would also help to reduce the level of work required at the development management stage.

1.48 - We will therefore work with partners to support additional training and guidance to improve the preparation and monitoring of local development plan delivery programmes. We recognise that there are different delivery challenges in different parts of the country and will use pilot work to explore this further in collaboration with the Scottish Futures Trust. This will help to build skills and provide insights into how they can become more purposeful delivery programmes in the future system.

Making plans for the future - consultation questions:

Key question

A: Do you agree that our proposed package of reforms will improve development planning? Please explain your answer.

Optional technical questions

1. Do you agree that local development plans should be required to take account of community planning?

2. Do you agree that strategic development plans should be replaced by improved regional partnership working?

2(a) How can planning add greatest value at a regional scale?

2(b) Which activities should be carried out at the national and regional levels?

2(c) Should regional activities take the form of duties or discretionary powers?

2(d) What is your view on the scale and geography of regional partnerships?

2(e) What role and responsibilities should Scottish Government, agencies, partners and stakeholders have within regional partnership working?

3. Should the National Planning Framework ( NPF), Scottish Planning Policy ( SPP) or both be given more weight in decision making?

3(a) Do you agree with our proposals to update the way in which the National Planning Framework ( NPF) is prepared?

4. Do you agree with our proposals to simplify the preparation of development plans?

4(a) Should the plan review cycle be lengthened to 10 years?

4(b) Should there be scope to review the plan between review cycles?

4(c) Should we remove supplementary guidance?

5. Do you agree that local development plan examinations should be retained?

5(a) Should an early gatecheck be added to the process?

5(b) Who should be involved?

5(c) What matters should the gatecheck look at?

5(d) What matters should be the final examination look at?

5(e) Could professional mediation support the process of allocating land?

6. Do you agree that an allocated site in a local development plan should not be afforded planning permission in principle?

7. Do you agree that plans could be strengthened by the following measures:

7(a) Setting out the information required to accompany proposed allocations

7(b) Requiring information on the feasibility of the site to be provided

7(c) Increasing requirements for consultation for applications relating to non-allocated sites

7(d) Working with the key agencies so that where they agree to a site being included in the plan, they do not object to the principle of an application

8. Do you agree that stronger delivery programmes could be used to drive delivery of development? 8(a) What should they include?


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