TAG - Local Government Technical Advisors Group

TAG News

Planning for Sustainable Economic Development PPS 4 Consultation

28th Apr 2008

Technical Advisors Group (TAG), has made the following comments TAG represents a large number of local authorities in the country at the highest technical level, these authorities include those with highway and transport responsibilities; such as Transport for London, most London boroughs, Metropolitan authorities, Unitary authorities and also many of the districts and towns in two tier authorities - where the county is responsible for Transport Issues and the district is responsible for planning and related transport policy issues. Typical responsibilities of TAG officers are Engineering, Highways, Transport, Waste, Recreation, Building and often Planning and Property. We have close working relationships with other associations representing local authority officers including the County Surveyors Society and the Planning Officers Society. In our consultation with our members and associated groups we have become aware that the Planning Officers Society (POS) have done a very succinct and comprehensive response. We confirm we are fully supportive of the contents of that submission but would like to take the opportunity in our submission to elaborate or stress some specific issues. To ensure that their response is fully integrated into our response we have included the POS evidence in its entirety. Our response is now structured under 5 general headings: • General thrust and content • Economic growth, market forces and developments • General Transport Issues • Parking standards • Full Planning Officers Society response as supported by TAG On the questions and answers we fully agree with all those answers given by our POS colleagues but would refer to the additional views expressed in our note to support those comments. General thrust and content Like POS we support an updating of PPS 4. We have similar major reservations that the general thrust of the document is likely to be read as giving preference to, sometimes short term, business interests over long term environmental or sustainability issues. We would also suggest that where the document refers generally to another PPS the link and essence of what is contained in that other document should be made much clearer. Economic growth, market forces and developments We understand the importance of ensuring that the UK has a sound economy which can compete on world markets but it must be recognised that an individual developer or company will certainly want to optimise his own business interests and is often not really concerned over wider issues. It is the proper role of government and local government to look after the wider interests. The UK is a very crowded land compared with most countries and despite this we have been able to generally maintain a high environmental quality -significantly through planning controls over a long period. Without this quality of our environment being maintained in the past, our economy would be very much less successful today. Looking forward Stern has pointed out that we cannot afford not to reduce our carbon footprint if we are to have any hope of maintaining the world economy. We therefore need to be even more careful in the future over developments. We must ensure that:- • Redevelopment is not confused with Regeneration – demolition and rebuilding as opposed to refurbishment and reuse uses much more carbon (apart from possible damage to the overall environment and townscape) • The design of new buildings is to the highest standard to also contribute to the environment and street scene and use the minimum of energy • The location and planning of developments minimises the need to travel especially by non-sustainable means. As local authority Engineers and Planners we know at first hand the pressures that can be applied by a developer to grant permission - they will often threaten to take their development elsewhere. We recognise that this is can also happen at a national level. However if we are to achieve long term economic success, regenerate run down areas, and reduce our carbon footprint we need to resist certain developer pressures. We do not think the draft PPS4 as presently written will achieve that. General Transport issues In paragraph 5 of the draft PPS4 it refers to well planned infrastructure cutting journey times and creating environments where people want to live and work. While each developer may want a new Greenfield site connected by good roads, from our experience over the last few decades this general strategy has resulted in worse congestion and a worse environment with people travelling further to work or for other needs by car. The whole approach of planning should be to ensure accessibility (as opposed to mobility) to homes, jobs and services by the most sustainable means. In the list of Governments desired objectives in paragraph 12 it is notable that ‘making the best use of existing infrastructure’ is missing – a very important part of future planning. We note that the last item in the list of paragraph 18 allows offices ‘ancillary to other forms of development’ outside towns. While small scale offices supporting other uses may be appropriate this could give licence to large ‘science’ parks close to say an out of town University. Such a science/business park would be very difficult to access by sustainable transport and would therefore not be appropriate. On page 6 under the heading ‘Efficient and Effective use of land’ a category of land that could usefully be used is that developed as large surface car parks for out of town offices or shopping centres. Any encouragement to redevelop these for more efficient use of land and to reduce trip ends could usefully be given encouragement. Parking standards Under paragraph 25, the last item listed refers to developing parking policies and standards and suggesting that these be developed at a local level. We are very concerned about this potential softening of the much delayed national standards. Buchanan as long ago as 1963 said:- “ the question of how much parking space should be provided in new buildings needs to be considered from two points of view, namely Liability and Convenience of access and circulation….” “The application of arbitrary parking standards to new buildings may produce an accumulation of parking space which the network cannot deal with ….” “To summarise we think the parking policies need re-examination to ensure that traffic difficulties are not being built in by the provision of too much parking space in the wrong position----,” ( paras 454, 455 456 of Buchanan report) It unfortunately took another 6 years before central London changed to a restrictive maximum standard and over 30 years until nationally we adopted more restrictive standards. Even today many local authority planners and engineers are not rigorously following the national standards especially when developers threaten to take their developments elsewhere. TAG views with great concern anything which may weaken the resolve to resist extra parking. While we agree in principle that standards should to some extent reflect local situations any setting of appropriate standards is most effectively done at the minimum of sub- regional level. It is perhaps unfortunate that there are such limited incentives for a developer not to provide parking to allow extensive use of cars for commuting and the only real restraint are new planning permissions. The market seems to show that premises with ‘good’ parking facilities command much higher rents than those with limited parking so the present incentive on a developer is usually to try and maximise parking provision. Within Communities Department there is a potential alternative mechanism to try and minimise parking provision and traffic - through the business rates system. TAG has produced a discussion document on this subject and we are presently planning a meeting with the DfT and Communities on this subject. Full Planning Officers Society response as supported by TAG Introduction 1. The Planning Officers Society represents the most senior professionals and managers of planning functions in the English local authorities. We set out to: • Act as an advocate and promoter of Local Government planning; • Assist and advise the Government and the Local Government Association on planning matters and related issues; • Act as a centre of excellence, undertake research and promote best practice in planning matters; • Promote all aspects of the built and green environment by working closely with other organisations and professions. 2. The Society’s aim is to ensure that planning makes a major contribution to achieving sustainable developments, from national to local level, in ways which are fair and equitable and achieve the social, economic and environmental aspirations of all sectors of the community. Comments on draft PPS4 3. The Society welcomes the publication of a draft replacement for the outdated 1992 policy guidance on economic development. However, we have a number of suggestions which we believe would improve the final version. 4. Our impression is that the emphasis of the Statement is very much on the less favoured parts of the country, and it fails to address the rather different challenges that face the more successful parts of the economy. Little attention seems to be given to the tensions between the pursuit of continued economic growth in these areas and things like congestion, pressure on infrastructure, the quality of the environment and quality of life. The question of how these tensions are to be reconciled is critical to setting policy in some of the parts of the country that contribute most to the economy, and the failure to address them seems to us a major omission from the Statement. We note in this connection that the Statement is to be read in conjunction with the new annex to PPS1 on climate change, but feel that this cross-reference is not strong or explicit enough. 5. We welcome the principle of planning being built on a sound evidence base, but believe the time has come to take overall stock of the wide range of evidence requirements that have been introduced through various government initiatives in recent years. We have listed some of these below. They now represent a substantial cost and workload for both planning authorities and other key players in the planning system, and we need to satisfy ourselves that the requirements – both in terms of the range of information and the level of detail required - are in every case proportional to the value they add to the planning process. We suggest that case studies might be used to see how the evidence that is being gathered is being used and the extent to which it is influencing the outcomes from the planning process. This may suggest a need, either for changes to the evidence base, or to planning processes, to allow greater regard to be had to the evidence base. Examples of evidence requirements PPS3 para. 11 and Annex C: Strategic Housing Market Assessments PPS3 para. 11 and Annex C: Strategic Housing Land Availability Assessments PPS3 para. 29: Assessments of the economic viability of thresholds and proportions of affordable housing, including the impact on housing delivery and mixed communities PPS6 para. 2.32-2.33: Retail and Leisure Needs assessments PPS7 para. 24: Landscape Character Assessments PPS1 para. 27: refers also to Townscape Character PPS25 para. 6 and Annex E E5: Strategic Flood Risk Assessments ODPM Guidance Note Dec 2004: Employment Land Reviews. Draft PPS4: para 18: A wide range of measures to monitor the local economy Other components of the evidence base mentioned by our members include those in PPG17, PPS9 (Appropriate Assessment), the Habitat Regulations, Sustainability Assessments, Strategic Environmental Assessments and Statements of Community Involvement. 6. Turning to the monitoring of employment land, we believe that this raises far more complex and subtle relationships than is the case with the supply of housing land. We are anxious that we should not move towards some kind of target-driven policy on employment land that fails to take account of these complexities. For example, in parts of the South East we have seen steady increases in employment provision over the years, at the same time as the supply of employment land has steadily decreased. Much of this employment growth results from the intensification of use of the existing stock of employment land. Nor is it possible to draw simple conclusions about what constitutes an appropriate level of employment land provision at the level of an individual local authority. Areas differ in character, some being more residential in nature and others with greater concentrations of employment, and the balance between jobs and resident labour force will vary correspondingly. There is also an important qualitative element to employment land, and what may be far more critical than overall supply is the availability of land or premises that meet the needs of particular sectors of the economy. The most that can be said about employment land supply is that: (a) the information supplies some context about what is happening in an authority over time and (b) that in aggregate form it may give a clue as to any major imbalances that are arising at a sub-regional or wider level. The relative importance of gathering and using employment land information at the individual local authority level needs to be set in this context. 7. More generally, joint working is likely to be of greater importance in developing an understanding of the local economy, given that important parts of the information base are unlikely to be sufficiently robust for use at the level of the individual planning authority. Whilst draft PPS4 makes reference to joint working, it may be that this needs reinforcing in the final version. It may in some cases be that even the principal authorities (in particular, many of the smaller unitary authorities) are too small a unit for sensible monitoring. This raises difficult questions about what the appropriate unit for economic monitoring is. Travel To Work Areas are the nearest thing we have to self-contained economic units, but even they may be as little as 75% self-contained. In addition, they tend to change over time (reflecting, for example, longer commuting patterns) and may bear little relationship to other sub-regional geographies (such as housing markets). If we are to achieve local monitoring of economies that is consistent and of a high quality, it would be useful for the Government to commission and share technical advice on matters such as these. More generally, we would hope that those drafting PPS4 and any accompanying guidance are working closely with those working on the Sub-National Review and its proposed statutory duty to keep the local economy under review. The aim should be to ensure as far as possible that the evidence base requirements are common to both and that the overall workload is not increased unnecessarily. 8. Whilst we understand the importance the Government attaches to the market, it is important not to forget that, in some cases, they are asking us to work against market forces. For example, in regeneration areas we are looking to transform and create value on sites in which the market is not interested. Also, the climate change agenda may involve us in running directly counter to what the market might want (for example, in terms of the location of employment land or the pattern and mode of commuting). The Government might want to qualify its support for market forces in such circumstances. 9. Related to the previous point, some of our membership have read the draft PPS as setting up an argument that economic development can claim an overriding justification as being in the national interest, and have expressed a concern about it. We do not believe that this was the Government’s intention, and you may wish to consider whether the final version can better reflect their position on this. 10. Turning to some points of relative detail: (i) Sport should be listed as an economic activity, being an important part of some local economies; (ii) Whilst we understand the case for flexibility that underpins the support for multiple or mixed uses, they are not invariably appropriate or helpful and the final version should avoid giving an impression to the contrary; (iii) We suggest there should be greater reference to the interaction between employment, transport issues generally and with car parking in particular; 11. Turning to the specific questions you asked on pages 31-32 of the draft PPS: 1. See paragraphs 4, 8 and 9 (above). 2. See paragraphs 5 and 6 (above). 3. See paragraph 7. We would see the evidence base for local planning authorities and the new duty for economic assessment emerging from the same process. Every effort should be made to minimise the workload and to avoid duplication. 4. Our experience is that Simplified Planning Zones have a relatively limited application and have probably already been used in most of the areas to which they are applicable. Having said that, the existing guidance in PPG5 appears to have worked successfully and the Government may wish to consider preserving that in some form. 5. See paragraph 7. 6. See our comments in paragraphs 8 and 9 about the potential tensions between the local planning authority being more responsive to the market, and our duty to combat climate change. A more flexible approach to the location of B1 may in some cases exacerbate environmental problems. 7. See our comments in paragraphs 8 and 9 about the potential tensions between the local planning authority being more responsive to the market, and our duty to combat climate change. Less prescription on non-residential car parking may encourage car-borne commuting, to the detriment of the environment. 8. See our comments about the complexities of employment land supply in paragraph 6. Whilst we agree with the proposition that employment land should not be unreasonably retained if there is no realistic prospect of it ever coming forward for such a use, we would be opposed to any rigid prescription that left planning authorities no leeway to take account of local circumstances. In practice, the pressure to release more land for housing should ensure that most authorities do not unreasonably retain employment land, without the need for further prescription. 9. No comment. 10. No comment. --- We hope these comments will be useful in producing a more robust final version of PPS4. In our discussions with various local authorities at officer level our concerns, as expressed in this evidence, are strongly supported - we therefore earnestly hope that the final version of PPS4 will be markedly different. We would be pleased to take part in discussions with relevant people in the Planning Economic and Social Policy Division of the Communities department and/or with other groups. We confirm these comments have been circulated amongst the membership of TAG and reflect the technical views of the organisation.

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