Re: Progress with Core Strategy or Start Local Plan - Public forum - Planning Advisory Service (PAS)

My understanding of the Draft NPPF and the proposed revised plan making regulations is that a 'Local Plan' does not have to be one document it can be made up of say a Core Strategy and a site allocations DPD produced at different times but consistent with one another.

There are clearly pros and cons to progressing one or more documents, mainly around cost and organisation of one or more examinations. However, given where you are, I would suggest that carrying on would be the best option. As Julian has said, there is nothing to stop you from having more than one document. What will be most important are the policies themselves. When all's said and done, you need to make sure you have all the policies in place that Scarborough needs. Those policies will form your Local Plan. Whether they physically sit in one or more documents isn't an issue. Your current approach of 'Core Strategy plus sites and allocations DPD' is what will produce your 'Local Plan'.

Thanks for those replies. I understand that we can have 2 documents and obviously that means 2 inquiries. But I think we could have the 'completed plan' ready quicker than the 2 documents although not quicker than just having the Core Strategy in place, if that makes sense and obviously there should be savings in inquiry time. I am leaning towards the one plan approach probably also because I am pre 2004 and think people understand it more. Is anyone else considering that option?

We are in a very similar situation to Scarborough with a Core Strategy due for submission in the Spring. I was checking the PAS forum to see if anyone else had raised the issue of swtiching to a Local Plan. We had timetable our Site Allocations and Development Management Policies to follow 6 months behind our Core Strategy. However, I am now thinking along the same lines as David in that we could have a completed 'Local Plan' quicker than pushing through the three separate documents. With the NPPF due for adoption in the winter, and the revised Local Planning Regulations also out for consultation (http://www.communities.gov.uk/publications/planningandbuilding/localregulationsconsultation) which plan to remove references to the 'LDF', 'Core Strategy' and 'Area Action Plans' (although I appreciate there can still be more than one DPD), my feeling is that by early Spring the requirement will be for 'Local Plans'. Whilst yet to be decided, my instinct is to push forward with a Local Plan encompassing what would have previously been three documents, as I can't envisage an Inspector being too supportive of a separate examination on each once the NPPF is adopted. Realistically it will lead to minimal delay as the Core Strategy will be Part I, the Development Managment Policies will make up Part II and the Site Allocations will be the Proposals Schedule (much like our current UDP!) and much of this work is already underway. I too would appreciate any more thoughts on the matter.

I've been speaking to others about this today, and the best approach I heard was to move towards a single plan because: Incorporating DM policies will be relatively straightforward Incorporating some of the allocations will be straightforward (in particular employment, and retail as they are not big issues there) This means relatively little additional work, although there would clearly need to be further engagement. I appreciate that is a local assessment of the impact and it would be important to do your own to work out exactly what additional work will be needed, and therefore how much delay there may be (at the front end, acknowledging less delay/cost for a single examination). I'd just like to make a plea that we don't get hung up on titles (i'm not suggesting anyone here is, by the way). In discussion with DCLG recently, it was clear that the emphasis is on having the policies in place (as I said above), and therefore which documents they sit in, and what they are called, is up to you. I'm happy to be corrected, but I don't see why any core strategies currently being prepared can't be called 'X Borough Local Plan', with just a simple announcement on the website that the name is changing (along with the content). The requirement is for the policies to be in place, however presented. If changing the name (and adding content) the important thing would be: To make sure that people realise that no work/responses to date have been wasted, What is changing, and why, is clearly set out. Just my thoughts. PAS would obviously be happy to support any authority looking to review their approach, and can offer project management support to assist in making these decisions, and setting out the consequences, at no cost to the authority.

I note the comments on more than 1 document but this ignores paragraph 21 of the NPPF which states. Each local planning authority should produce a local plan fro its area. Any additional development plan documents should only be used where clearly justified. This strongly implies we should be working towards one document which can be reviewed in whole or part. Does this have a bearing on peoples thinking?

It needs to be remembered that to go back to Square 1 and rebadge the DPD as a traditional, single Local Plan - incorporating sites and DM policies - is likely to require Reg 25 consultation to be undertaken, Sustainability Appraisal of sites etc. There are pros and cons with the different approaches outlined in the messages above but I would hope that government recognises the work done to date and where local authorities wish to have their Core Strategies adopted - given the desire to have development plans in place, implications where plans are silent, out of date etc - this should be able to proceed. This would ideally involve sensible transitional arrangements or guidelines (not apparent in either the draft regs or NPPF...) but certainly where the (current) Reg 27/new draft Reg 21 stage have been met i.e. reps invited on submission document, the process should be able to proceed through to examination etc for Core Strategies. I note that on P.10 of the the current consultation, it refers to 'local plan documents', 'development plan', 'local plan', 'draft plan' and 'the plan'. Later on, on the same page, it refers to 'development plan document'. This is unhelpful and I do not know what local planning authorities are supposed to call Core Strategies once they have been submitted! Reverting to single Local Plans will not happen overnight - and matters have not exactly been helped by the vacuum and confusion created by drawn out planned revocation of RSSs. It would seem sensible to allow for an up-to-date plan to be in place at the earliest opportunity, regardless of its title or scope, rather than insisting that all Councils go back to the beginning and re-consult on a Local Plan.

The NPPF will be guidance. What will determine what LPAs can or cannot do will be the Local Plan Regulations. A draft of these is currently out on consultation and I have studied them to feed in a response through the RTPI. It is draft Regulation 7 which covers this and nowhere does it prevent the preparation of more than one DPD - and that terminology is still used, no reference to "the local plan". I suggest that it would be contrary to the localism agenda for Central Government to be prescriptive about the plan-making process. For example, the regs will no longer prescribe that you have to put a title on the document.

Thanks Mark and John for those comments. I think if consultation, and SA, has already happened on DM policies and sites, then I'm not sure that putting them in to another document would justify having to go to consultation again. If work on these has yet to be made public, then yes, consultation would of course be required. So I think it depends how far you have reached with the 'non core strategy' policies. I'm delighted to see the regs won't prescribe a title. Sticking with a positive frame of mind, David, I would rather hope that (potentially more than) 2-3 years of hard work, and the evidence that has produced, would represent 'clear justification' to continue with whatever current programme of plans you have set out and that you would not fall foul of the NPPF as a result. If pushed, I'm sure you could set out that you have committed significant resources to the documents as set out in the LDS/timetable, and once completed you will 'review the situation' to see how best you can proceed in future revisions to produce a single plan. As John has pointed out, the regs don't prevent more than one DPD. They can't, because it isn't written anywhere else that you have to have a single plan. If you can justify it, you can do it (a bit like having to justify each policy).

All that upheaval over the last 10 years and were back with Unitary Development Plans and selective reviews. At least it should be understandable to the public.

I wonder whether Peter's final sentence gets to the heart of this debate. If a single plan is produced there is an opportunity for all involved (public, members, developers, infrastrusture providers) to see how vision, strategy and implementation work together across the piece. One of the weaknesses/criticisms of the more fragmented 'LDF' approach is that a Core Strategy in isolation does not necessarily 'mean' anything - yes, it sets the direction and overall high level strategy - but if ultimately planning is about where change happens on the ground, its allocations/management policies that matter to most parties interested in the process. Perhaps we have slightly lost sight of that, and the decision as to whether to go a single or multiple plans should be based around which option best helps people be involved and fully understand the implications of the LDF/Local Plan in question.