Editing Local Plans Down to a Reasonable Length

Governments over many years have sought local plans to be shorter, sharper and more visual over many years; yet plans keep getting longer every year. Over 300 pages used to be the extreme, now it is the norm.

This week we have the preferred options version of the Bradford Local Plan. Thank god its out, it took a long time and the team at Bradford are to be congratulated. It is long. I dont know quite how long because there is no pdf version, but it is many hundreds of pages.

I remember the story of the Ealing UDP many years ago. 400 pages went to the Chief Executive. It came back the next day with two words in red pen on the front ‘too long’. 20 years later the Ealing Plan is shortest in London as it leaves out everything in NPPF and London Plan.

Lets use Bradford as a case study in editing a plan down. All plans need editing. Both by a lead office able to keep the plan under ruthless editorial control control and in addition by someone not too close to the plan, ideally a professional writer or journalist, who can ensure good sense, style, grammar and spelling.

From having pulled together several local plans here are some tips:

Get straight to the point – start the strategy no later than page 2

The regs allow background information to be submitted alongside a plan. Get into that habit at reg. 18. You dint need to describe what a local plan is the results of years of DTC and evidence gathering. All that matters is the shortest reasonable narrative of the outcome. Describe at preferred options reasonable alternatives and in a submitted plan only in the SEA.

If wording can be used to determine a planning application put it in a policy – otherwise leave it out

Say it once say it well. No need to repeat objectives endlessly in policy. Minimize cross references as plans should be read as a hole and be short enough to do so. This is particularly the case with crosscutting objectives such as sustainability and heathy living. You cant really map such to plan policies without endless repetition (as is the case with Bradford where only one sentence of its healthy living policy meets the test).

Don’t include stuff which should be in the evidence base only

Sections on place making following policy is a common plan structure, I mighht even go so far to say I invented it (no I think that was Cotswolds local plan) but you don’t need to repeat large amounts of deprivation statistics and the whole SHLAA site by site as here. A simple policy table of each sites with genuine site and locational policies not just a laundry list, is essential.

Kill all Acronyms

Otherwise only planners will understand it.

Make Clear What the Key Spatial Choices Were

This is where inspectors get their teeth into. We see it especially in terms of the justification of which Green Belt sites to include and which not. The strategy splits need down geographically, but isn’t clear where these local need figures where used to justify ‘exceptional circumstances’ – which would be odd as ‘spreading the pain’ isn’t really a material consideration in reviewing Green Belt purposes.

Set a Page Limit per section and ensure submissions meet it before being considered

Where is the magasine editors approach. It is much better that contributors self sub – then you arnt being the bad guy.

Dont Listen to Anyone telling you Councillors love long plans

As was told to me in Cambridge. Cllrs hate errors and objections against, the longer the plan the larger the attack surface.

Get the Policies Map Right First

Plans are increasingly map lead and if you get the map cartographically consistent an readable the writen test will be easier to write.

Dont rely on online only

Unless you create a visual PDF as well you will never realise what a monster you have made. If your system doesn’t allow DTP you have the wrong system.

Ensure the plan can be read at a single sitting

Plans are not bedtime storeys, unless they are so boring they send you to sleep, but no excuse for turgid technical prose.

If you cant instantly quote back the relevant Policy and Clause the plan is too long to remember, and use effectively

Have a folder called SPD to put edited out sections in

Cumbria County Council to reconsider West Cumbria coal mine

News and Star – the caselaw is is that if there s significant changes prior to S106 signage it can be reconsidered.

CONTROVERSIAL plans for a new coal mine in West Cumbria have been put on hold.

Cumbria County Council has announced it will reconsider the plans in light of “new information.” 

A spokesman for the county council said: “After the receipt and consideration of new information, Cumbria County Council’s Development Control and Regulation (DC&R) Committee will now reconsider the planning application by West Cumbria Mining to create a metallurgical coal mine off the coast near Whitehaven.

“This decision has been taken because in December 2020, the Government’s Climate Change Committee released its report on its recommendations for the Sixth Carbon Budget, a requirement under the Climate Change Act.

“The report, among other things, sets out the volume of greenhouse gases the UK aims to emit during 2033-2037.

“This new information has been received prior to the issue of the formal decision notice on the application.

“In light of this the Council has decided that the planning application should be reconsidered by DC&R.”