The Six Year Local Plan Examination – A Cause for Concern

With a few very notable exceptions the key issue in the planning system is no longer getting local planning authorities to propose to allocate enough land, the key problem has become getting submitted plans to adoption.  It is an issue which needs to be front and centre of consideration in the forthcoming Green Paper on Speeding the Planning System.

Thew West Berks local plan a few years ago was the first Auger of a 6 year examination.  5-6 year examinations, mostly in Green Belt areas have become the norm, especially in high pressure Green Belt Areas.

The 2004 system had binding inspectors reports as a key principle.  The Coalition kept this as long as local authorities were seen to promote modifications.  As legally ‘main’ modifications required consultation anyway this wasn’t such a big deal however significant savings could be achieved if either inspectors could propose changes or their could be informal round table drafting sessions at examinations.

A key shift has been rolling examinations – ending a ‘report’ coming from the blue finding a plan unsound.  Rather we now have a practice whereby a plan has an opportunity to undergo profound change to achieve soundness. A key problem with rolling examinations is their almost impenetrable nature to those not directly involved in the examination, having to piece together many letters to find out  where a plan examination is.  A simple reform would be for inspector to keep up to date an executive summary document which states the current status and phase of the examination with hyperlinks to all key documents and decisions.

Long examinations are due to fundamental shifts in housing numbers, requiring extra work to be done on Green Belt Reviews, HELAAS, SEA etc.  So long examinations are in part a symptom not a cause.

A stable medium term position for housing numbers will help.  The botched attempt to create a standard OAN system, now held together with sticking plasters, didn’t help.  Even so agreement needs to be reached on the employment + element.  The increasing realisation that this can only be done at the functional economic region level, together with the need for statements of common ground and that many authorities are not able to resolve their housing needs alone has led to a slew of joint strategic plans.  But these are new, under-resourced, often underskilled and underscoped and without strong governance or programme management.   These require a different kind of high level EIP, more similar to structure plans.  So far their weakness has been  consideration of reasonable alternatives, also apparent in many traditional plan examinations.

If inspectors/panels were appointed earlier, prior to preferred options stages, there could be informal round tables with key stakeholders on scoping the key reasonable alternative options.  If you are late to this game tough.  I would also suggest SEA consultants are rigorously independent and report directly to the inspector/panel; to avoid insinuation of partiality or smoked room deals over preferred options, which have proven particularly troublesome in Green Belt areas.

Legal change is needed to get around the problem that plans cannot be part sound.  If you agree that we are moving to a zoning and subdivision system it seems crazy that you can zone strategic site A simply because you also need strategic site B which needs extra work and consultation.

More radically we could move to a zone first examine later when their is time system (as per New Zealand).  If their is no reasonable alternative to some policies and sites their is no reason these cannot come forward earlier and examinations focus solely on the choice of alternatives.  The aim should be to make it quick and easy to modify plans with ‘no choice’ changes, such as over changes to the NPPF.

Finally I would suggest there is standard NPPG on Green Belt reviews.  Of which the PAS guidance is a starting point.    I do have doubts however about whether assessment by Green Belt purpose is the best of all possible approaches.  I would suggest instead an ‘openness scorecard’ relying more on standard SPAN guide methods, which would much more scientific.  I’m fed up with horrible examples like Grenoble Road (Oxon) where three rival Green Belt Reviews gave three different subjective Green Belt purpose assessments depending on the scale of review etc.   The methodology also needs to take account of the best option for compensation/enhancement of green belt objectives as per the Feb 2019 NPPF.