This was supposed to be the model.
As I long ago argued and the panel now agree
we are not persuaded that there is evidence to demonstrate that the Strategic Development Locations, and thus the overall spatial strategy, have been selected for inclusion in the plan, against reasonable alternatives, on a robust, consistent and objective basis. We therefore cannot conclude that these fundamental aspects of the plan are sound
Sadly though they go down a totally impractical soft planning route where it will be impossible to test SEA wise vague non specific areas
it might be appropriate to consider developing a high-level strategy
for the plan area which, not based on specific SDLs, identifies how housing, employment and other development should be broadly distributed. Proposals for specific strategic development locations would then follow on from this.
Obviously such a strategy would need to be tested against reasonable
alternatives. This approach would also potentially provide the plan, and the follow-on local plans, with the flexibility to select lternative/additional SDLs should this be necessary if one were to “fall away” or if the quantum of development needs were to change over time.
Bearing in mind the amount of additional evidence which has already
been prepared since the plan was submitted for examination in respect of the SDLs and the spatial strategy, we seriously question whether the production of even more evidence, as opposed to going back several stages in the plan making process, would be likely to address our soundness concerns. Importantly, we also question whether such work could be seen as genuinely having been carried out with the necessary objectivity, rather than being an exercise to justify a predetermined spatial strategy.
The predetermined strategy being in this case to deliberately allocate as little in the Green Belt as possible without causing impossible congestion.
The panels suggested approach – not following on from anything in national policy or guidance, would require communities to accept vague structure plan/RSS like locations like ‘5000 houses South West of Thornbury’ without any idea of the extent or supporting infrastructure for that community or the availability, viability or deliverability of the site. For anyone involved in developing such plans will know this is simply politically impractical, and as experience of such plans such as in South Hampshire over a generation they simply result in non master planned sprawl, planning by numbers without any design., and very often complete lack of delivery where local communities are hostile and local plans arn’t delivered. It would also be impossible for such a non map base plan to delete Green Belt sites – exactly the alternative the panel want considered – as Greater Manchester has found. It would also delay the first spade in the ground for strategic sites by a decade or more – the worst of planning in the 80s and 90s. Lets not go pack to a time when strategic planning was a process a thing but slow and delivering poor quality results. We know that strategic plans that are high level and still define strategic locations can and do work (North Northamptonshire for example), with a local tier below, or not (North Devon, Plymouth and South West Devon). So why not go with what works rather than the out of date PAG styles plans the panel yearn for from what they were taught at planning school.
The local authorities should use their powers to demand recommendations to make the plan sound (as often mentioned on here – under Section 20(7C) of the PCPA) and consult on real options, as successfully pursued in NEGC. The panel cant legally refuse this.
It also raises severe questions about whether Anchorman, PINS and Home England have any clue or degree of coordination about what a new style strategic plan promoting new communities looks like and what form and procedures (complying with the SEA directive) should apply. Is it every authority and panel make it up as they go along until the egg hits the fan. At this rate new style strategic planning is going nowhere.
3 thoughts on “West of England Joint Plan Found Unsound for not examining Alternatives, But Want Strategic Planning to Go Back to Dark Ages”
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I too am concerned that the new NPPF is weak on clarifying what statutory spatial plans should do and what should be left to supporting local plans. Footnote 15 to para. 23 of the NPPF 2019 does say that spatial development strategies can allocate strategic sites where these powers have been conferred, but it appears that the powers to do this haven’t been conferred anywhere yet. The reason is local politics. I think most constituent local authorities are very nervous about surrendering key plan-making powers to a metro mayor who might have a power-base in the core city – by which I mean a larger working class who may favour dispersal into the hinterland when the only other alternative is an aggressive programme of ‘regeneration’ in the core city.
The consequence is likely to be sub-optimal planning as you suggest, but the alternative is fragmented planning on the basis of 330 odd local authorities acting in isolation. The old government has decided to take baby steps. Whether the new government thinks a different approach is needed remains to be seen.
I found that para. deeply puzzling as they are on a non map base, so secondary legislation is required to rectify this which has not been confirmed yet anywhere. Same problem with Green Belt designations, where for Greater Manchester it was confirmed the change would be made but then the Mayor nand Minister fell out.