London Green Belt Council

Copy of letter sent on 20 March 2002 to DLTR in response to their questionnaire

Planning Green Papers

1. The London Green Belt Council sent its comments to the DTLR on 9th and 13th March, but was not aware until early this week of the Select Committee's Press Notice 38 of 31st January. Our comments to its questions are below. We said in our submissions to the DTLR that we thought the proposals so damaging that we ought to comment as regards the planning system generally, not on green belt specifically. We hope that our comments are not too late to be considered.

Question I: The effectiveness of the present system and the plans to replace it

2. The existing system is effective in so far as

3. The Government's proposals are thoroughly objectionable in their approach to 2(a)(b)(c) and (d). Not only do we think that the planning Green paper makes no adequate case for change - it seems anxious only to pacify business and development pressures, come what may, - but its actual proposals fundamentally undermine what ought to be basic assumptions for the planning system in a democratic society. Taking the four points above separately our comments are :

a) stability: What people expect from a planning system Is not only a gradually improving environment but also some stability in their expectations for its future. In contrast the paper, if implemented, would provide far continuous frenetic change and 'renewal of vision', which would be the despair of residents and planning authorities alike and which would benefit only the development interests and the lawyers. A more uncertain and potentially damaging system would be difficult to imagine.

b) coverage: how can a system which would appear to create generalisations at regional level but no detailed coverage at either district or 'local development framework' level but only at some sub-sub-district level possibly be effective? It would leave huge gaps in the planning system which would be exploited by development interests, to the destruction of public confidence in what planning is for, and to endless argument and/or legal test cases on what degree of planning actually applies to what

c) Public participation: the proposal to remove the right of individuals to be heard at inquiries into plans is fundamentally wrong. To abandon in a democratic society what is a valued right for an individual to have his say, and to do so on the feeble grounds offered in the paper, is simply disgraceful, and we are astonished that it should ever have been contemplated. Some delay and expense on this account is simply a price that has to be paid. See also answer to Question VI.

d) The Role of Counties: we accept that the ordinary progress of national and international commerce, communications etc, has led to a position in which some counties may be too small to provide a sufficiently broad conspectus of parts of the country for planning purposes. But our members feel strongly that the answer is not to abolish the counties for those purposes but rather to give groups of counties a broader role without making them subordinate to regions. Counties have for a thousand years been a focus for history, loyalties, and traditions; and this must to a degree be reflected in planning for their areas. By contrast regions are viewed with suspicion as unelected bodies and as a focus only for large-scale commercial interests. So -

Question II. The Role of Regional Planning Bodies

4. If one accepts that there is a valid case for some planning on a regional level, it does not follow that counties must fit in with regional fiats. (We assume here that counties are retained: the resulting position if they are not and if nothing precise and site-specific emerges In plans short of sub-sub- district level, is too ludicrous to contemplate). It does not seem to us too outrageous a proposal to suggest that regions should present their ideas and proposals to counties. They should be ideas, not commands disguised as advice; and counties (or groups of counties when the particular issue seemed to make ad hoc grouping sensible) should consider how to move forward and incorporate it into their plans. The Secretary of State would still retain reserve powers.

5. A matter which has concerned our members since regional considerations since regional considerations form themselves in the planning system is the pattern of semi-overlapping bodies which is being set up and their relationship to each other. The RPAs and RDAs are the prime examples. We are clear that the scale and place of regional development must be subordinate to the overall regional planning just as it is at county and district levels at present. But the RDAs seem to have different ideas and to be jockeying for position, with the threat that development and expansion, if they might lead to wealth creation, could occur more or less regardless of environmental interests

The outcome would be that RDAs' aspirations would override RRAs planning considerations, not vice versa. This could be disastrous for sound planning; but needless to say Government guidance is ambiguous on the relative weight of planning and development at regional level.

6. We, therefore support a need for regional planning so long as the regional planning bodies are democratically accountable, and the RDAs' plans accord with regional planning concepts, not the other way round. We ask that consideration should be given to our suggestion in paragraph 4 that the outcome of the process should be advice to counties, not instructions to them.

Question III. Major Development Projects

7. Whilst accepting that it would be right for Parliament to express a view an early stage as to whether a major scheme in right in principle, it is imperative that Parliament should have enough, information before it to evaluate it correctly. By "evaluate' we do, not mean the minutiae of costing so much as a scheme's apparent desirability weighed against its technical feasibility and proponents financial, technical and operational competence. The inquiries which are necessary to establish this but which fall short of a lengthy and detailed investigation will need careful thought, but the experience of Central Railways has convinced us that they are necessary.

Question IV: Business Planning Zones:

8. Non-planning planning zones seem to us a contradiction in terms, and we deplore the concept. Our doubts are reinforced by the Green Paper's references to "safeguards that might be necessary". That really amounts to planning restrictions by another name, so why abandon ordinary planning rules?

Question V: Proposed Changes to Planning Obligations etc.

9. Another of the many ways in which the papers seem determined to tear up planning safeguards is the proposal to separate planning, obligations from the application whose defects give rise to the need for an obligation in the first place. This means that

a) a general stealth tax on development is being created;

b) such a tax could be used for politically-inspired planning purposes which may or may not be supported locally;

c) local people will feel not only that pressure is being put on them in this way but that developers will be able to put pressure on local authorities and in effect buy their way into getting approval to undesirable developments.

We therefore think that the whole idea should be dropped.

Question VI. Certainty, Public Participation, etc

10. We believe that the proposals will achieve the opposite of what is claimed for them. They will generate a sense of continuous revision, unstable principles and confusion in local authorities and public alike. Public participation will be reduced by denying individuals the right to be heard whilst at the same time incorporating so-called community representatives Into wide-ranging fora which are likely to be dominated by those primarily concerned with business interests. We cannot judge whether in the long run decisions will be faster but we have little doubt that from the point of view of those who want some stability in their environment they will give rise to more dissatisfaction. The answer to the question is therefore that the proposals will simultaneously introduce confusion and resentment in many areas of planning

Question VII. Urban Renaissance

11. We have no comments on this matter, which is covered by each of what we have already said.