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Establishing the Town and Country Planning (Strategic Development Plan) (Wales) Regulations 2021

A response to the Welsh Government

The Welsh Government is bringing forward Regulations to implement Strategic Development Plans (SDPs) in Wales. RTPI Cymru responded to a consultation on the approach to establishing the SDP Regulations, and the main points for this are set out below and the response can be downloaded here

Do you agree the SDP Regulations should broadly mirror the key stages and plan preparation requirements set out in the LDP Regulations, subject to the exceptions referred too?

We broadly agree it would seem sensible for the Strategic Development Plan (SDP) Regulations to mirror the key stages of plan preparation, we have a number of comments to make in relation to this through our response. 

Firstly, we believe that the difference between an SDP and Local Development Plan (LDP) is much more than an issue of scale.  There will be a number of challenges that will arise including resourcing, logistics, governance, engagement etc that working across a region presents.  There will be a particular challenge around securing public engagement, political commitment and collaborative working at this level.  Adequate support and resources are vital in delivering this agenda.

Do you agree with the proposed approach to the Community Involvement Scheme (CIS) and Delivery Agreement (DA)?

Regarding the proposed time frame, we question if four years to prepare an SDP is realistic given the reality of preparing LDPs in Wales, this is particularly relevant to the first SDP.  The evidence gathering and consensus building and engagement alone, across multiple Local Authorities could prove considerably more difficult in comparison to one Local Authority preparing an LDP.  Similarly, the volume of representations, proposed sites etc could require additional time and resources to adequately address.

We understand that Local Authorities often have quite different ways of collecting and producing data which would be useful in the creation of SDPs but may require time to ensure it is consistent and comprehensive etc.

We do appreciate that in terms of the time period, this may become more efficient over time and with future SDP revisions, but we feel it is likely that the first revision of SDPs could take longer than the four years. However, we appreciate to build confidence in the new arrangements and SDPs, there should be an aim to adopt them as close to the four year timescale as possible. This could be achieved by providing an upfront investment in resources and drawing in expertise where appropriate.

SDPs must be prepared on a foundation of consensus and cooperation, with Local Authorities working together to build trust and enable difficult strategic decisions to be made.  Councils will need to form a strong relationship with Corporate Joint Committees (CJC) and consider and agree regional plans prior to agreement by CJCs.  This is important for ensuring appropriate buy-in from Councils and to avoid collaboration breaking down in the long-term.  (See our response to Regulations to Establish Corporate Joint Committees

Given the scale of an SDP, consideration should be given to ways of avoiding the Plan being found ‘unsound’ at the end of the process.  A proposal that has been put forward by the industry to overcome this, sets out a suggestion of a two-stage approach to examination for SDPs, so that the SDP Strategy could be tested for soundness at an earlier stage, through an examination, with the detailed plans, policies and proposals follow. 

Earlier security regarding soundness could also have the additional benefit of providing some degree of certainty to developers, investors, communities and those authorities preparing LDPs and LDP Lites in accordance with the SDP.

Clear guidance on SDP preparation is vital to ensure that the plans concentrate only on strategic level matters in both content and consultation.  This in turn requires further clarification on the relationship between SDPs and LDPs/LDP Lites to ensure that the right plans are addressing the issues appropriate to that level/tier and there are effective links between them.

Do you agree with the list of general and specific consultation bodies listed in Annex 1?

The following omissions are noted:

  • Cross border authorities, including English border authorities and equivalent consultation bodies in England, including the Environment Agency, etc) which should be usefully consulted, particularly given the strategic nature of the SDP;
  • Town Councils (only Community Councils noted);
  • Access groups;
  • Environmental groups;
  • MPs/MSs/Councillors.
  • Business interests such as house builders, the Confederation of British Industry (CBI), strategic scale enterprises such as British Aerospace etc.
  • Representatives of the tourism sector.

Do you agree with the proposed approach to monitoring, review and revision of an SDP?

Monitoring, review and revision will be as important for SDPs as they are for LDPs.

In any review process, there should be recognition that SDPs contain strategic projects that may take many years to come to fruition.  While a review should be prompted by the Annual Monitoring Report (AMR) if the Plan is demonstrably not working, a mandatory review should be long enough to take account of the strategic nature of the plan.

Changes to the NDF as a result of a review, could impact on SDPs.  Therefore further information on the relationship between the review cycle proposed for the National Development Framework (NDF) and the SDPs would be useful.

The monitoring process should recognise the importance of measuring outcomes and going beyond the standard indicators of AMRs.  Building this into the process from the outset will help monitor impact on the ground in the longer term.  The RTPI’s Measuring What Matters Planning Outcomes Research provides a toolkit that sets out a three stage process to measuring impact.  The levels set out a progression from understanding policy effectiveness in the decision making process (Level 1), to direct physical development outcomes on the ground (Level 2), to wider cumulative direct and indirect impacts of planning (Level 3).

Do you agree with the proposed approach for SDP withdrawal?

Further information and clarification is required regarding the ‘planning reasons’ for withdrawal and what this might include or exclude.

Further guidance on the impact and consequences of withdrawal on LDPs/LDP Lites would be useful.

Further point

The relationship between an emerging SDP and LDPs requires further clarification and understanding including policy gaps and the weight of emerging SDPs etc.

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