Proposed Reforms to the Development Consent Regime for Nationally Significant Infrastructure Projects

Questions

Improving the way key Infrastructure projects are dealt with and National Policy Statements

Action for Market Towns (AMT) has long been in favour of the introduction of measures to streamline the planning process for key infrastructure development. 

This is essential to the delivery of, for instance, the provision of the sustainable, cost effective public transportation which our members agree is an essential requirement for the continuation of our small rural towns as centre capitals of their rural hinterlands.

AMT is however deeply concerned that the proposed move to a framework of strategic policy statements runs counter to the government’s own position on the promotion of localism and the devolution of genuine decision making power.  It is our view that consultation on the shape of strategic policy statements will inevitably be skewed as a result of the complexity of the arguments involved and the depth of specialised knowledge required to shape the debate constructively.

We would therefore recommend that where a strategy proposal is likely to impact upon a rural area, either through it resulting in the location of a specific development in a rural area or through any development impacting on the existing economic and social structures of a town or towns, that the Commission for Rural Communities (CRC) and AMT be specifically consulted as key stakeholders speaking on behalf of the interests of such towns.  This would of course be in addition to seeking the views of any directly affected market town partnerships and local authorities.

In relation to strategic policy statements being required to indicate circumstances where it is important to address adverse consequences of development, it should be noted that the production of such a statement is likely, in itself, to have a negative impact in the form of planning blight.  Whole communities could be left in fear of large scale development on their doorstep from the moment of publication of a policy statement until the final decision on where a particular scheme will be situated.  A programme of social and economic support should be considered to help counteract this effect and funding should be devolved so that the benefits are delivered where they would actually be needed.  Directly funding at a sufficient level the role of Market Town Partnerships could offer a proven way of achieving this.

Consultation by Promoters

AMT agrees that promoters should be required to undertake consultation with the public before submitting any proposal to the proposed planning commission.  We would also take the view that a full environmental appraisal must be conducted and made available to the public before such consultation was undertaken so that local people were adequately informed as to the possible outcomes of a development.  Clearly there would need to be a requirement for independence in relation to the completion of such an environmental appraisal.  Based on the polluter pays principle it should be the responsibility of the promoter of any development to pay for the appraisal.

Consulting local Authorities

We agree that local authorities should be involved at an early stage in any development proposals.  We would also urge that it be made a requirement for those authorities to consult with interested stakeholders such as Local Strategic Partnerships (LSPs) and Market Town Partnerships (MTPs) so that both the traditional political and the emerging participatory democratic voices are heard.

Consulting Other Organisations and Preliminary Stages

Where proposed developments are either situated in a rural area or will have an impact on a rural area or its towns, the promoter should also consult with the Commission for Rural Communities.  This should also be the case for the preliminary stages of consideration by the planning commission.

Hard to Reach Groups

Within small rural towns (pop. 2,000 to 35,000) AMT champions market town partnerships (MTPs).  These groups have a specific role in engaging with all sections of their communities in relation to how their town should develop and grow.  Despite the obstacles they face in terms of limited financial support, such partnerships have a strong track record of success in this aspect of community-led place shaping.  With the commitment of funding support to continue and grow their work these partnerships could be the ideal mechanism to increase participation of hard to reach groups in the planning process.

Proposals to Reform the Town and Country Planning System

Questions

Joined up Community Engagement

Clarification must be provided as to what standards are to be adopted and whether these are to be backed by the support, incentives and capacity building measures required to deliver true involvement rather than a vague intension to reform.  AMT therefore requests clarification on this point before a full response can be provided.

Removing the requirement to list Supplementary Planning Documents in Local Development Schemes

AMT would welcome the introduction of greater flexibility into local development schemes and more specifically where this would allow for the inclusion and adoption of evidence-based local community plans and in particular MTP action plans.