Observations of the Policy Group of the Scottish Region of the Institute of Logistics and Transport (ILT)
The institute is naturally concerned most with those aspects of planning which relate to logistics and transport. Whilst almost all areas of planning have some impact in this field the comments below are made in general terms relative to those aspects of the proposals where there is a likely significant impact on logistics and transport activities and developments.
There have been a large number of planning initiatives by the Scottish Parliament and Executive in recent years. Many of these have mirrored developments in England and Wales but there have also been significant differences reflecting Scotland's devolved powers. A new Planning Bill which draws together the planning process and clarifies the present position as well as incorporating beneficial changes which properly reflect the situation which now applies in Scotland would be of considerable benefit. To assist in this there should be cross-reference with all relevant documentation and we would specifically highlight SPP 17 "Planning for Transport" in respect of which the Institute is about to submit observations.
"Options for Change" quite rightly sets out the "key components" which might be appropriate for consideration in a Bill but even so the proposals are very wide ranging and there is a danger that the main elements could be denuded in trying to embrace all aspects. There is an emphasis on the processes involved in planning and whilst this does of course require considerable attention there is a danger that the products and outcome are not given sufficient relative attention. The approach followed could also be interpreted as being too defensive and reactive rather than being outgoing and proactive in a manner which would best enable Scotland to meet its potential. The contents and subsequent Bill could benefit from guidelines explaining how developers might best realise their aspirations.
To assist in this there would be merit in a formal overview of the mechanisms already in place to assist proactive planning. This should include the statutory consultation processes required for the development of Structure Plans and the process, which might be made mandatory whereby most Councils also invite early "pre-application" discussions with developers. There could also be formal encouragement for developers to utilise planning consultants, as many now do to review structure plans and engage with councils as they formulate policies to meet their development strategies.
The aim for sustainability is admirable but it is questionable if this would be assisted by all of the proposed processes. It is appropriate for the National Planning Framework to embrace all "family of plans" but this might be assisted by more specific reference to the different types of infrastructure provision and the aspirations advice and restraints which relate to each of them. In our particular case we are most concerned about the various modes of transport and related terminals and interchange points but there is little specific reference to this in the text.
Since the demise of Regional Councils the experience of Structure Plans has not been good. In principle we support their removal and replacement by four city/region plans with local development plans replacing local plans throughout Scotland. This should enable more strategic consideration of major development aspirations and to assist in this it is important that the boundaries, participants and decision making processes relate as closely as practicable to the proposals which emerge for "Transport Scotland" and Regional Transport Bodies.
Re-affirmation of the necessity for all public agencies to have regard to development plans is welcomed and this adds weight to the need for common boundaries and easy communication procedures. Direct notification of development plans to interested persons as proposed would also assist the planning process and promote public goodwill and is supported in principle subject to satisfactory procedures and processes being developed in respect of the additional administrative demands.
The proposals to simplify the consent procedures would be beneficial as would the aim to provide "approval in principle" prior to detailed submissions if the developer would find this advantageous. The suggested "Infrastructure Trusts" to capture development gain and developer contributions would appear to have considerable potential. It is felt this matter deserves further attention to ensure the likely benefits would be significant and widespread bearing in mind the potential for additional administration and delay in reaching decisions. To assist in this it would be helpful for more reference to be made to the Executive's thoughts and proposals for land value uplift.
It is hoped that these comments are considered to be helpful.
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