Allocations DPDs - Public forum - Planning Advisory Service (PAS)
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En cours - juillet 2012
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Dernière modification - May
Allocations DPDs
At the recent Wigan seminar it was mentioned by the CLG representative that it may no longer be necessary for authorities to produce Allocations DPDs as the Core Strategy and SHLAA could possibly be used. However, another delegate pointed out PPS3 specifies that DPDs should identify specific sites (paras 53-55). Whilst a CS can identify strategic sites on the Prop Map it is only expected that there will be one or two such sites within any local authority area. Given the need to also reassess employment land sites for housing I cannot see how we can avoid an Allocations DPD to specify Housing/Employment/Open Space/Gypsy & Traveller sites. Any views welcome. In my view, as you have to be able to demonstrate how settlements can take certain proportions of development (especially housing) in the CS, and that to do this you must have to know that the sites are available to meet targets, it would be far better to join together the CS and allocations dpd as one document. This would save time overall (one document instead of two), as you have to do all the evidence base work together anyway. I know that we are advised that the CS and Allocations DPDs are not to be submitted together, but if your CS goes ahead first and is found unsound then you would be surely back to the drawing board anyway on the Allocations DPD? I'm sure the general public would find this more understandable - they only really get engaged when they see what policies mean in terms of allocations on the ground - and by the time the CS is adopted many of the decisions on this will be fixed and people have effectively missed the boat to comment.
Whatever Government says, a Core Strategy which only identifies strategic sites cannot in my view be PPS3 compliant and would not provide any kind of certainty. I recall that at the time of the Planning Green Paper, Lord Falconer (remember him?) once argued that an LDF could be a flexible statement of general principles and criteria against which planning applications could be considered and that proposals maps were unnecessary. Perhaps this profoundly non-spatial notion is being revived. An alternative explanation is that the LDF system is now so bogged down that Government is attaching as much as possible to Core Strategies as a face saving exercise. A Core Strategy combined with full allocations begins to look uncannily like a Local Plan. I wonder if a pragmatic approach might be to prepare CS and allocation documents in parallel in the early stages but allow them to pull apart later on, delaying submission of Allocations until reciept of the CS binding report, thereby allowing full discussion of all issues early on but avoiding abortive work in the event of an unsoundness finding.
Just to make it clear it was not the CLG rep who suggested that allocations should go into the CS, it seemed to be suggested that you did not need allocations at all, as the CS, through its policy direction would mean that you did not need allocations at all and you could rely on the SHLAA. I just can't see how this accords with PPS3 as stated in my first post. My thoughts entirely on combining CS and allocations - if it looks like a local plan in this respect....so what! We need to make clear allocations as soon as possible to give certainty to the housebiolders and to stop inappropriately located development from ad hoc appeal decisions. I still feel that you will have done most of the 'abortive work' anyway in arriving at your spatial strategy for the CS, as this has to be based on whether sites are available or not in your urban areas. The time it takes to do both a CS and Alloc DPD, especially if not in parallel, adds up to more than the time to do an old style local plan, that contained all the policies with no need for extra DPDs. I struggle to see how this complex and bureacratic LDF system can be described as streamlined, and these latest changes to the system just seem to have taken out the options stage, but we are still being told to do this as good practice and we may be found unsound if we don't. This only serves to make the process less clear and hardly more streamlined. I still feel there are good things, however, about the new system, as Dan has said in posts elsewhere - if we could combine the best of the new and old we would have a cracking planning system.