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CfIT response to planning green paper

4. Comments on Green Paper Proposals

4.1 General

The Green Paper is very process-oriented, focusing strongly on adjusting the machinery of development plans and planning control. It lacks a clear stance on the objectives of the planning system. In relation to the transport concerns of CfIT a central purpose of the planning system should be to help deliver integrated transport. This might indeed be regarded as a test of whether the Government's aspiration for an RSS is being met. However, there are different perspectives about what integration actually means. Possible meanings, starting at a low level of integration and moving upwards are:

1. integration between transport modes: eg through easy physical interchange between routes and modes, through and intermodal ticketing, integrated planning processes, integrated investment planning;

2. integrating transport planning with land-use: planning transport provision in response to land-use plans (essentially the conventional 'predict and provide' approach that pre-dated the new realism);

3. integrating land-use planning with transport: locating new development where it places the transport system under least strain, regulating parking provision and securing links to public transport networks (this is essentially the approach that has been set out in PPG13);

4. integrating the management of demand on the transport network as a whole: securing prices and price structures that maximise economic and environmental efficiency (eg by internalising the costs that are currently borne outside the transport system);

5. integrating wider locational choices, and land-use and transport planning with demand management across all modes: this would include all the elements up to and including 4 above, but in addition would seek to influence currently separate locational decision-making by a wider range of agencies. (Examples include the balance of public expenditure between urban regeneration and serving areas of new development, and patterns of service provision by providers such as Health and Education Authorities where centralisation of facilities has sometimes left rural areas (particularly) and some parts of urban areas without local services, forcing long distance travel).

Experience of working on RTS in English regions suggests that resolution of their transport problems and achievement of the desired level of integration between regional planning, transport and economic strategies requires at least an aspiration to reach Level 5 of this scale. The reforms to the planning system should make this aim explicit.

4.2 Replacement of RPG with RSS

4.2.1 Delivery of integrated regional transport strategies

Research carried out for CfIT on European best practice in the delivery of integrated transport has concluded that the UK performs poorly on several aspects that are central to the 10YP - in particular car-dependency and mode share, reducing congestion, reducing environmental impact, accessibility and social inclusion[5]. Both this and later work suggests that some of the major barriers to better performance relate to differences in regional governance. Key features include:

  • greater emphasis on transport in all regional and local policy making;
  • 'compact city' strategies resulting from better integration of regional and sub-regional land-use and transport planning;
  • more investment in public transport infrastructure and revenue support to encourage sustainable patterns of transport use;
  • better coordination of public transport planning, services, fares and promotion.

The greatest institutional difference from the UK lies in the pattern of subsidiarity. A strong regional level of responsibility for transport policy, funding and service provision co-exists with defined (and complementary) national and locality roles. By comparison, decision-making in the UK is more highly centralised, militating against integration at regional scale and below where the potential for greatest benefits arises.

The RSS proposal could lead to the development of the region as a major arena for policy debate and resolution. If so, this would represent a significant step towards the European 'best practice' outlined above, and is to be welcomed. However this would require significant devolution of functions from central government and enhancement of institutional capacities to provide the missing 'teeth' at the regional level. This goes well beyond the scope of the Green Paper's exclusive focus on the planning system, which seems to envisage RSSs as a relatively modest further step in the direction already taken by PPG11.

The proposals for greater engagement by RDAs in RSS production should help to connect this important policy area and expenditure stream. However, it is also likely to expose tensions between achieving short- and medium-term economic targets and sustainable longer-term patterns of development and transport use. There will need to be strong regional mechanisms for resolving such differences. Choices about trade-offs of this sort are political as well as technical and will require robust political machinery at the regional level.

Public participation and consultation with interested parties may help (particularly if conducted early enough in the process to be seen to have a genuine influence on decisions) but do not remove the need for 'hard choices' (indeed may well raise their political profile).

Many other important areas of expenditure do not have an accountable regional agency, despite having a major bearing on the generation of transport supply and demand. This includes the whole of the private sector and many aspects of the public sector (eg the Highways Agency, Railtrack, the NHS and higher education). There will need to be capacity within the regional arrangements for identifying 'regionally relevant' expenditure[6] within mainstream programmes, so that the region can seek to influence the level and application of these funds. In the longer term, regions will need to have the powers to establish their own framework for raising and spending money on regional and sub-regional transport within the wider national strategy.

We suggest that these larger structural issues should be considered in the context of the forthcoming White Paper on Regional Government.

Pending more far-reaching structural changes, the performance of the proposed RSSs would be improved by strengthening institutional and technical capacity at regional level. This would help to address the specific transport problems identified in Section 2, which would also be helped by:

  • requiring SRA and the successor to Railtrack to participate in the development of RSSs;
  • absorbing PTA/PTEs and the passenger transport functions of non-Metropolitan local authorities into Regional Transport Authorities, linked to regional assemblies;
  • coordinating minor schemes in Local Transport Plans with major schemes financed from national resources;
  • setting the objective of achieving a balanced package of public and private transport provision year by year;
  • establishing the principle of additionality of local transport charges, setting baselines of conventional spending against which this can be measured.

4.2.2 Gaps between land-use and transport planning

The RSS should improve the level of integration in policy terms, but much will depend on whether this is followed through into practice. This raises similar issues between transport and planning agencies as have been discussed above in relation to central and local government. On the specific issues raised in Section 2:

  • It will be crucial to delivery of the 10YP that RSSs can deploy regional policies for transport charges across the whole range from the relationship between road and rail charging structures in inter-urban corridors to the incidence of congestion charging and parking taxes, charges and standards.
  • There are important policy areas - such as investment by the NHS - where the connection to the planning system at present is primarily reactive rather than pro-active. The measures for wider stakeholder involvement and consultation will need to address such areas.
  • The RSS must have sufficient teeth to ensure that Districts cannot undermine the regional strategy in pursuit of local vested interest, whether by omission (eg failure to impose sufficiently stringent parking standards or charges) or commission (eg permitting major traffic generators where they cause congestion of regionally important routes).

4.3 Abolition of Structure Plans

4.3.1 Delivery of integrated regional transport strategies and Gaps between land-use and transport planning

At present County Councils are responsible for land-use planning, highways and local public transport within their areas. Abolishing Structure Plans means that these links between the policy and expenditure programmes for transport and land-use are broken. Much will depend on whether they can be replaced by stronger links within the regional machinery around RSSs - and these links will also need to encompass Minerals and Waste planning (which are intended to remain at County level).

There is a need to clarify the Green Paper's proposals for handling sub-regional issues - the importance of which it explicitly recognises. While separate sub-regional strategies are generally (and rightly) ruled out, this means that the RSS itself will require sufficient sub-regional specificity to ensure that the sub-regional dimension is adequately handled. This has implications for the staffing of the regional planning machinery: research for CfIT suggests that the present voluntary collaborations are not good at overcoming local vested interests and tend to produce 'lowest common denominator' solutions.

4.4 New procedures for major infrastructure projects

4.4.1 Delays in delivery of major projects

There are significant drawbacks to the Green Paper proposals for speeding up the inquiry process:

  • it is not clear how many projects in practice would be brought within the arrangements, since the list in Annex C is limited;
  • there are major questions about how the Parliamentary process would operate in practice, including the capacity of Parliament to scrutinise proposals effectively;
  • the Statutory Order procedure proposed carries greater risk of judicial review than an Act of Parliament, and scheme promoters would have to carry the costs in advance of any form of government backing;
  • the time saving of allowing Parliament to decide on the principle so that the inquiry can concentrate on detail may be less significant than speeding up the process of getting a determination from the Secretary of State after the inquiry.

4.5 Other Green Paper proposals

4.5.1 Review of national planning policies

The proposal for national policy statements about infrastructure needs is welcome, but must form part of a coherent approach to national spatial development. A clear vision for regional development (in terms of economic growth, housing demand, environmental amenity, etc), whether market-led or some variation, which in turn drives decisions on issues such as division of public funding between regions, should be a key part of such an approach.

Integration between sectors (e.g. health and education planning in conjunction with transport and land-use), and their infrastructure requirements and locations should also be addressed as part of the national approach to spatial development.

4.5.2 Proposals for community participation

Concerns have been raised that the widespread use of parliamentary procedures would reduce the level of public involvement, damaging the democratic process.

The DTLR argues that people's involvement will not be reduced and will have an input into the process at three key stages:

  • the Parliamentary stage would be preceded by development of a national policy statement, the content of which would be open to public consultation;
  • the public will have a clear opportunity to make their views known before Parliament debates the issues; and
  • a public inquiry into more detailed aspects of the project will follow the Parliamentary process.

There is a concern that a Government with a large majority in Parliament could force through controversial schemes. For example, the East London River Crossing suffered from lengthy delays in the planning process and was rejected after unwavering public opposition. It has been stated[7] that it would have gone ahead under the new procedures, and would have caused serious environmental damage. The CPRE[8] also holds similar views calling the new procedures; 'a potential disaster for local people who care about their environment.A new road, an airport or even a power station - as long as Parliament has agreed it in principle, the best local people may be able to do is hope that they can influence the amount of pollution, waste and noise it will be allowed to create'.

This is an extreme perspective but it does seem likely that there will be sustained challenges by lobby groups to:

  • the adequacy of policy statements on which decisions are being based (particularly if there are alternative sites for major infrastructure proposals);
  • the definition of 'national interest' employed by promoters and the Government;
  • the limitations to rights of audience on issues of need in parliament and public Inquiries are likely to be challenged under the Human Rights Act.

Decisions are still likely to be challenged post Inquiry by Judicial Review which even if unsuccessful, will delay scheme progress.

We foresee very similar pressures arising with the revised Local Development Frameworks and these may well have to become more detailed compromises between the Government's intentions and existing Local Plans. The process of implementing the change to the system itself may well introduce further delay. In our view, the proposals in the Green Paper will not significantly reduce the range of objections (and time taken) to deal with major planning projects (including transport schemes) going through those local procedures.

4.5.3 Changes to planning obligations

The move towards tariffs for planning obligations is welcomed in terms of greater transparency and a stronger means of connecting development with transport infrastructure costs. However, this fails to address the problem that while development values may permit a substantial contribution to meeting such costs in high pressure areas, they are less likely to do so in areas where there is a greater need for development in terms of regional growth or urban regeneration. It is not clear whether the new system will deliver more or less resources than the existing arrangements, or whether those resources will necessarily be applied to transport improvements. There is also an obvious risk, despite the Green Paper' intentions, that tariffs on Greenfield developments might be used as a device for deterring development. Finally, if a substantial resource stream for transport investment is to be generated by the new system, it raises the same issue of additionality relative to conventional funding as discussed above when considering local transport charges.

Summary of Key Points

Our key concerns with the Planning Green Paper may be summarised as follows.

Replacement of RPG with RSS

  • The Green Paper does not address the issue of the institutional framework needed to underpin the planning process at regional level. Whilst this may be an issue for the forthcoming White Paper on Regional Governance, it is fundamental to delivery.
  • In advance of any changes to Regional Governance, the development and delivery of RSSs would be improved by strengthening institutional and technical capacity at the regional level.
  • The proposals are not clear on how Regional Assemblies and their strategies will interact with District Councils and their Local Development Frameworks; there is danger of a gap between rhetoric and practicality.

Abolition of Structure Plans

  • The present links between transport and land-use at a single level of the hierarchy will be broken. Much will depend upon whether those links can be strengthened effectively at the regional level, and we have already expressed our concerns that the Green Paper does not cover this issue.
  • The adequacy of the regional institutional framework, and its links to Districts will determine whether integrated planning can be realised through the new proposals.

New Procedures for Infrastructure Projects

  • Scheme promoters may be exposed to greater risk as a consequence of the statutory order procedure.
  • Whilst time savings may ensue from the Parliamentary 'in principle' decision, there may be scope for greater savings by speeding the process of determination from the Secretary of State following an inquiry.
  • The removal of the 'in principle' decision from the planning inquiry may result in greater dissatisfaction, protests and delays at the local level. Consultation must be (and be seen to be) comprehensive before the 'in principle' decision is taken. This may reduce the potential time savings.

Review of National Planning Policies

  • The proposal for national policy statements about infrastructure needs is welcome, but must form part of a coherent approach to national spatial development. A clear vision for regional development should be a key part of such an approach.
  • Integration between sectors (e.g. health and education planning in conjunction with transport and land-use), and their infrastructure requirements and locations should also be addressed as part of the national approach to spatial development.
5: W S Atkins (2001), 'European Best Practice in Delivery of Integrated Transport'.
6: expenditure in and for the benefit of the region.
7: Dr Hugh Ellis, Planning Advisor to Friends of the Earth.
8: Council for the Protection of Rural England, Director Kate Parminter.

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