6) Do you agree with the role, purpose and content of spatial development strategies set out in policy PM1? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI warmly endorses the reintroduction of a universal approach to strategic planning in England and its integration into national planning policy through the draft NPPF. The RTPI believes that to maximise the long-term growth and high quality placemaking derived from a new plan-led system, planners need to take a central, coordinating role in the planning and delivery of infrastructure. We greatly welcome the increased emphasis on infrastructure provision in the draft NPPF and would encourage strengthening of wording where possible. This would include reference to the potential role of Infrastructure Delivery Frameworks and Infrastructure Delivery Plans in preparing Spatial Development Strategies (SDSs).
We await the publication of related guidance and confirmation of SDS geographic boundaries, both of which will be fundamental to an efficient and orderly transition into the new plan-led system. In lieu of associated guidance, it is difficult to provide a fully informed comment on the form, role, purpose and content of SDSs. However, publication of such guidance, alongside a review of the proposed draft NPPF, should provide an opportunity to address feedback and ensure close alignment and reciprocity between the two.
To support the implementation of the new plan-led approach, a wide ranging and clear system of how Local Plans (LPs) and SDSs interact is needed. This includes a clear and unequivocal understanding of how the LP and SDS interface in terms of site allocation. Such site allocation needs to be considered across a range of development types, which would also include, for example, strategic infrastructure needs. As set out in response to Q2(b), the RTPI welcomes the clear separation between plan-making and decision-making policy in the draft NPPF, but note that harmonisation is still required, nonetheless. We advocate that a clear thread of planning and place-making be drawn through the spatial tiers of the new plan-led system into decision-making. The RTPI notes the provisions in the Planning and Infrastructure Act for SDSs to consider health inequalities and nature recovery and strongly recommends that the revised NPPF reflects this. This should include ensuring that the policy areas referenced by SDSs are aligned with the topic areas covered within NDMPs. For example, economic development, climate change, and minerals and waste. This would also serve to establish the flow of appropriate evidence bases through strategic and local plans into decision-making.
A key element of success for this new development plan system will be how SDSs interact with other SDSs, local plans and neighbourhood plans, either existing or emerging outside of their specific geographies and cross-boundary. We will discuss this further in relation to Q15(a).
Vital to implementation will be the delineation between what evidence is expected, at what spatial level. This will include consideration of corresponding time frames and how evidence bases can be shared. This will allow for interaction between spatial scales and the upwards or downwards transmission of information depending on the specific time and sequencing of plan preparations. Where possible, we should be looking to drive efficiencies and cost savings in plan preparation, with the collaboration of evidence building locally and strategically, as well as encouraging joint commissioning of relevant evidence across local and strategic authorities. Moving forward, the RTPI would welcome modern and innovative approaches to managing databases, including the use of live data where possible, and the creation of data feeds that relate to specific policy areas. Such data feeds can then be used in ongoing monitoring, review and preparation of plans. The RTPI wishes to see clarification of the role of The National Infrastructure and Service Transformation Authority (NISTA) in establishing evidence bases for SDSs, including use of the National Spatial Infrastructure Tool and development of place-based business cases.
The type, level and extent of what evidence bases are appropriately held at what spatial scale will depend on many factors. A balance needs to be struck between ensuring that SDSs are high-level, long-term and strategic in their nature, whilst also instructive and supportive enough to expedite local plan preparation and deliver strategic growth across boundaries. The RTPI would encourage particular focus on clarity of evidence over infrastructure requirements for large areas of growth. Approaches may have to vary depending on the policy and geographical area in question. For example, in some regions, strategic Green Belt reviews may be more appropriately undertaken by SDSs prior to being able to competently and robustly identify broad areas of growth. Other policy areas may benefit from a more universal approach, such as the provision of minerals and waste targets in SDSs.
The RTPI would encourage policy wording to support proactive and early engagement of statutory consultees and other key regulators within the SDS preparation process. To support this, a national list of all key statutory consultees and regulators could be provided, setting out additional information on all their prospective plans and time frames. Early engagement would allow statutory consultees and local planning authorities (LPAs) or combined authorities to work together more effectivity, ensuring that local plans and SDSs are drafted with appropriate consideration for matters that might otherwise arise later at the planning application stage. We feel this contribution will be particularly beneficial in terms of identifying strategic infrastructure need and subsequent delivery plans. It will also help improve the implementation of policy DM3(1)(d), by providing those early discussions to expedite engagement at the decision-making process. The RTPI would also promote a consistent approach to intervention powers for the Secretary of State with the inclusion of similar wording provided in PM2(4).
The RTPI would recommend clarification over PM1(f), as to whether this is intended to cover all energy infrastructure.
7) Do you agree that alterations should be made to spatial development strategies at least every 5 years to reflect any changes to housing requirements for the local planning authorities in the strategy area? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
a) If not, do you think there should be a different approach, for example, that alterations should only be made to spatial development strategies every five years where there are significant changes to housing need in the strategy area?
The RTPI wholly agrees with the need to have a mechanism to alter SDSs, recognising that significant changes to housing requirements would be an example of such a trigger. However, the need to create a flexible strategy that can respond to changing social and economic landscapes needs to be balanced against the drive to create stability and certainty in the new plan-led system. This is to allow for both expedient preparation of local plans, and to create suitable conditions for investment. Therefore, rather than set a mandatory five-year alteration period, the RTPI would encourage a more flexible approach to alterations whereby a strategic authority could conduct reviews and alterations after a minimum of five-years, where there is a significant change to housing or other factors deemed suitable. The nature of these reviews and alterations themselves could apply flexible approaches, allowing for partial reviews and alterations, seeking only to alter the strategy where strictly necessary.
Looking at the entire life cycle proposed for SDSs, as the RTPI understands, it is a 20-year SDS minimum time frame, with the five-year alteration provision and 10-year monitoring implementation and replacement requirement. This needs to be mapped across the plan-led system, including the proposed 15-year minimum time frame for local plans and corresponding five-year review process. The final proposed framework of plans will depend, to some degree, on the nature of the respected development plan review process, which if designed and implemented correctly will be key to successful plan delivery. Looking at the timing and frequency of SDS preparation and renewal in shorter timespans could create issues for LPs. The RTPI is concerned that such regular reviews of SDSs could create uncertainty and potentially lead to delays in local plan preparation or reviews and possibly dampen investor confidence. A 10-year review process of an SDS set at a 25 or 30-year period may prove more successful in this regard. A longer time frame may also better reflect some of the longer-term Government sectoral plans around health care and energy networks, for example. As mentioned in response to Q6(a) proposed time frames will also have significant consequences for what are considered appropriate in terms of evidence bases. Consideration of longer plan time frames may necessitate a review of whether current housing needs assessment calculations are appropriate when projecting into long periods of time. More broadly, the review of SDSs should also be combined with a monitoring and evaluation output that can be fed-back to both emerging combined authorities and local and central government. In order to conduct such a review, the RTPI would advocate for national outcomes for SDSs, similar to what has been provided in Scotland around the National Planning Framework 4 (NPF4).
Another concern related to proposals are around the resource implications of continual reviews, both for local planning policy teams, and strategic authorities. The resourcing context for SDSs is particularly unclear at this stage in time, with the Planning and Infrastructure Act’s initial impact assessment estimating the public cost of preparing SDSs between £62.7 - £147.2million. This funding has not yet been clearly assigned and does not appear to cover proposed reviews. On top of this is the workforce demand of SDS preparation which may be approximately 150 -175 planning policy officers. The RTPI would not wish to see this manifest a mass recruitment from local authority planning policy teams at the cost of local plan preparation. Proposals therefore need to be mindful of resourcing and workforce constraints alongside being workable and pragmatic.
Adoption of a longer plan period, with less regular reviews, will mean that reviews themselves will have to be more comprehensive, especially with changing arrangements around infrastructure funding. The singular focus of changing housing numbers for triggering review of the SDS may prove overly simplistic. Indeed, a variety of external factors may necessitate alterations in the SDS. This could include large scale macro-economic matters such as a global financial crisis, a global pandemic, geopolitical instabilities, or orient around national matters such as the adoption of key related sectoral and national strategies. This could include the publication of the revised 10-year Infrastructure Investment Plan, which as we understand are to include National Spatial Priorities (NSPs). Fundamental to the future success of NSPs, or a more fully developed version of NSPs in the form of a National Spatial Framework, will be how they are drawn down into SDSs. Therefore, provisions to allow for a more flexible approach to SDS review will hopefully futureproof for such possible scenarios. The broadening of review triggers would bring the SDS review in line with what has been proposed for LPs where PM2(3)b allows for change to include local circumstances, as well as changing housing requirements. However, whilst the RTPI would support the widened range of matters which may trigger the need to review or alter an SDS, these would have to be a clearly defined set of what should be considered significant factors. This will ensure that any review or alteration occurs out of essential need, not for example, a change in administration, encouraging stability and consistency.
To enable the planning system to utilise its critical role in coordinating land use and strategic infrastructure delivery, the status, timing, synchronicity, and geography needs to be considered across a range of sectoral plans and key supporting documents. For example, River Basin Management Plans are currently set at a six-year time frame and therefore may need amending to consider longer time frames in the hope of better supporting local and strategic cross-boundary matters relating to climate adaption and resilience. Alongside better alignment of time frames in the longer term, a rationalisation and alignment of geographic boundaries for other sectoral plans such as Strategic Transport Plans with strategic planning will improve delivery and implementation. In terms of status, given the critical role of infrastructure in coordinating land use and growth, the RTPI believes that Infrastructure Delivery Plans should be made statutory.
8) If spatial development strategies are not altered every five years, should related policy on the requirements used in five year housing land supply and housing delivery test policies, set out in Annex D of the draft Framework, be updated to allow housing requirement figures from spatial development strategies to continue to be applied after 5 years, so long as there has not been a significant change in that area’s local housing need? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
No further comment.
9) Do you agree with the role, purpose and content of local plans set out in policy PM2? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI supports the Government’s ambition to speed up plan preparation and achieve fuller plan coverage across the country. However, regardless of the proposed process changes to expedite plan preparation, the proposed 30-month time window will not be reached unless a significant and wide-ranging review of the resourcing of local plan teams is undertaken. Our State of the Profession 2025 research highlighted that planning policy teams have been exposed disproportionately to funding cuts in recent years when compared to the planning system as a whole, with a 28.8% reduction in planning policy funding since FYE 2010. In our submission to the Autumn Budget 2025, we called for funding in planning policy teams to be returned to a 2010 level, which we estimate as an additional £136.7million per year. Whilst we welcome the recent £14million funding announcement on top of last year’s £20million funding pot, we believe this to be far from where resourcing needs to be. This is especially true given that not all elements of plan preparation have been streamlined, for example relating to increasing the amount of upfront viability assessments and allocating for small and medium sites. The 30-month timeframe, should be kept in review through the monitoring and evaluation mechanism proposed in response to Q6.
The RTPI also notes that PM2(4) allows the Secretary of State to intervene when an LPA fails to make adequate progress with plan-making. We are mindful that any delay in the preparation of an SDS could subsequently delay local plans and impact on their ability to achieve the new time frame, if they have progressed through the new proposed gateway stage. The RTPI want to see thinking developed on how delays would be dealt with when an SDS and local plan are being prepared in a twin-track manner.
Clarity of the relationship between LPs identifying long-term growth expectations in PM2(1)(ii) and the SDSs identifying broad areas of growth in PM1(2)(b) would be welcome. Such clarification will need to take account of different scenarios such as LPs being either: adopted before SDSs; being taken forward in parallel, or prepared post SDS adoption. On adoption of an SDS, there needs to be a prioritisation mechanism to identify local plans requiring review as a result of significant changes in strategic growth and infrastructure strategy. This will help to create a clear and robust relationship between SDSs and LPs.
The RTPI believes that PM2(1) would be strengthened with the need for provisions for plan-making areas to protect and enhance the natural environment, increase the resilience of communities to the impacts of climate change and achieve radical reductions in greenhouse gas emissions. We would further welcome the specific reference to consideration of infrastructure development frameworks or strategies and any identified need to safeguard land for infrastructure when preparing local plans.
The RTPI notes confusion over the application of PM2(3), when factoring in the three-year preparation and adoption window, where the preparation of the next local plan must be no later than five years after adoption of the current plan. This could result in a local plan cycle of up to eight years, which is not consistent with the proposed time frames identified elsewhere.
10) Do you think that local plans should cover a period of at least 15 years from the point of adoption of the plan? Yes/No
No.
a) If not, do you think they should cover a period of at least 10 years, or a different period of time. Please explain why.
As set out in response to Q7(a), the appropriate minimum time frame is partly determined by what the minimum time frame will be for the SDSs. The RTPI appreciates the benefits of having longer than 10-year plans. This could provide longer term certainty, less overall plan preparation workloads, and a time frame that is more suitable to timescales that are commonly observed with major strategic development sites.
However, any longer plan period needs to be met with a robust consideration of how to develop an evidence base that can best forecast longer time periods or at least be easily reviewed and altered at appropriate points in time. This is currently especially difficult when projecting housing numbers or establishing elements of development viability, such as benchmark land values.
There are practical implications of a 15-year plan time frame. As discussed in relation to Q61(a), allocation of significantly higher volume of sites due to proposed changes around small/medium sites, is exacerbated by also having to meet greater housing need necessitated by longer time frames. This would constitute a significant immediate resource burden and would be particularly difficult for areas that have had significant recent upwards revisions of housing requirements. To achieve the new proposed 30-month time frame in these circumstances would necessitate a wholesale resourcing review of planning policy teams.
The appropriate timeframe may vary depending on the specific geographic location, with urban areas often having more difficulty identifying a deliverable housing land pipeline post-10 year due to the constrained nature of development. Other localities may have a considerable amount of large strategic sites which may take much longer than 10 years to come forward and be built out. This may also depend on the life cycle of the SDS, depending on the area of the country.
To balance the strengths and weaknesses the approaches outlined above, the RTPI suggests setting a 10-year minimum, accompanied by guidance on the factors LPAs may wish to consider when setting the time frame. This could also include the option of a blended approach to time frames, for example, setting plans at a 15-year time frame but with allocations limited to a 10-year period.
11) Do you agree with the principles set out in policy PM6(1c), including its provisions for preventing duplication of national decision-making policies? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
We agree with this approach although have concerns that some policy areas may exhibit policy vacuums in the short term. This would include areas such as minerals and waste which would greatly benefit from the expedient publication of revised national guidance.
12) Do you agree with the approach to initiating plan-making in PM7? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree
No further comment.
13) Do you agree with the approach to the preparation of plan evidence set out in policy PM8? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI believes that PM8(1) could be strengthened by acknowledging that, while evidence should be used to underpin decision making in plan preparation, plan makers should also plan positively for their areas, creating deliverable visions using creative placemaking skills and collaborative partnership approaches.
14) Do you agree with the approach to identifying land for development in PM9? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Neither agree nor disagree.
a) Please provide your reasons, particularly if you disagree.
The RTPI believes this section would benefit from further development. We understand much of this content has been pulled through from the relevant planning practice guidance (PPG). However, there is insufficient detail to meaningfully apply such policy. The resulting effect is that sections of the plan may set out insufficient detail, for example PM9(2)(d) does not enable plan-makers to take account of cumulative impact. The abridged policy leads to apparent inconsistencies with other policies in this framework, for example the lack of reference to sustainability which does not align with the plan-making policy requirements of CC1(1).
Noting the significant policy proposals set within this framework, such as targeting sustainable development towards well-located train stations, the RTPI welcomes the targeted approach from Government which hinges on the availability of transport infrastructure. However, such proposals currently sit disjointed with the rest of the framework, which fails to fully embed a vision-led approach to transport planning, which is currently set out in policy TR1. This is particularly in relation to PM9, PM8, PM2, and PM1.
15) Do you agree with the policies on maintaining and demonstrating cross-boundary cooperation set out in policy PM10 and policy PM11? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI believes that the reintroduction of strategic planning across England will make a significant and long-lasting improvement to cross-boundary cooperation between local authorities. However, there is a resulting need to ensure that SDSs capture the cross-boundary issues and work together at a sub-regional level to ensure the regional and national needs of England are taken account of. The RTPI strongly advocates for the future preparation of a National Spatial Framework to achieve this, and we await the future publication of National Spatial Priorities in the next iteration of the 10-year Infrastructure Strategy as the beginning of the journey towards this. We also recognise relevant elements within the English Devolution and Community Empowerment Bill in these regards, with provisions for a duty to collaborate between Mayoral Combined Authorities. As planning is a critical means of demonstrating collaboration through the development of spatial strategies, we have called for clearer alignment between legislative provisions and the planning system, as well as with other relevant national strategies, particularly those relating to infrastructure.
PM11, as currently drafted, puts the onus for engagement on plan-making authorities. We wish to see a full and robust mechanism that defines what is considered proactive and meaningful engagement by all parties. This should cover scenarios whereby adjoining strategic and local authorities are at different cycles of plan preparation, as discussed in Q6(a). A reassessment of operationalisation and effectiveness of compliance statements and statements of common ground, may prove useful to support this.
Furthermore, as also set out in Q6(a), the RTPI believes there should be a clear recognition of the role of statutory consultees in plan preparation, which includes cross-boundary matters. Therefore, the RTPI would welcome explicit reference to statutory consultees in PM10(1).
16) Do you agree that policy PM12 increases certainty at plan-making stage regarding the contributions expected from development proposals? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI welcomes the Government’s intention to integrate the viability guidance in Annex B. We note some of the proposals relating to development viability and are aware this is an ongoing workstream for Government including work on provision of standard inputs, we wait to be consulted more broadly on the details and will respond in due course. The institute recognises that developer contribution negotiations can add significant delay and complexity to the planning process, particularly with regards to development viability which can be dependent on a range of factors including construction costs and additional policy asks. We therefore understand the desire to provide a policy steer which promotes greater clarity over expected contributions at the plan-making stage. Such clarity would aim to reduce negotiation at the decision-making stage and hopefully speed up consenting and delivery of the development. This approach may also provide wider societal benefit in terms of managing land prices and securing necessary infrastructure to support quality placemaking. However, there are a number of considerations that need made in order to support the design of a new development plan system which can achieve these outcomes.
Firstly, the promotion of greater clarity at the plan-making stage on expected contributions can only occur if the country achieves fuller coverage of adopted and up-to-date development plans. Whilst we acknowledge the Government’s ambitions in these regards, it may take many years to start to improve plan coverage, especially without significant and sustained resourcing provision. The further upstreaming of viability requirements through plan preparation and examination, will increase the resource intensiveness of plan-making. This should be considered alongside other increasing workloads in the local plan preparation process highlighted elsewhere in our response. This includes small-medium site allocation, greater emphasis on defining settlement boundaries, Green Belt reviews and incorporating necessary details currently held in SPDs. This will require a significant increase in provision of resources to both local planning policy teams and strategic authorities as set out in our response to Q7(a) and Q9(a).
We note the proposals aim to standardise input and assumptions around viability in plan-making to ultimately reduce scope for variation and challenge at the planning application stage. However, the RTPI recognises that the role of viability assessments in local plans will be considerably distinct from those in development management. Developer contributions set out in local plans should aim to set a precautionary base, with the acknowledgement that there will always be a need for site appraisal. To enable this new system to work effectively will require a much fuller evaluation of the typology, site characteristics, levels of grant assistance, costs, and economic circumstances in plan preparation. Such matters may also be subject to regional and sub-regional variation, which should be picked up through SDS preparation, noting that SDSs will enable engagement of mayoral community infrastructure levy (CIL) which will impact upon development viability considerations in local plans and at decision-making stage. This proposal would also necessitate an expanded and more detailed approach to development plan examination. However, post-plan adoption, the consideration of viability is highly reactive to local market conditions, timing, and unexpected site-specific circumstances. This could be particularly problematic for areas with significant amounts of brownfield sites which are often vulnerable to abnormal costs. Viability is also highly sensitive to changes nationally, including for example, regulatory reform.
We welcome the proposed policy’s recognition that developer contributions should be seen as key aspect to support viable delivery of developments plans. The increased standardisation of assumptions places more emphasis on development plans to be monitored and reviewed, which itself comes with significant resourcing implications. This would have to occur with, for example, the underlying requirement for setting benchmark land values for strategic sites, needing to be reviewed every 5 years in order to remain viable and reflect real world conditions. We note that PM12(4) instructs plans to set out circumstances for review mechanisms for development proposals where contributions are proposed to be reduced below the requirements set out in plan policies. The RTPI queries whether such mechanism could be more usefully provided in guidance nationally. We would also welcome clarity over who would provide support for the reviewing of viability matters and whether external assessors, with collaborative input from all stakeholders involved in delivery, may be usefully included as part of this process. As set out elsewhere in this consultation, the RTPI would like to see a clearly defined role for statutory consultees in plan preparation, including a duty to engage with developer contributions as part of plan preparation. The RTPI would welcome a clearer understanding of how supplementary plans could be engaged in the new system of developer contributions, especially in regard to PM4(1)(b).
Other means of achieving the intended outcomes of streamlining developer contributions could be achieved, for example, by streamlining the examination of charging schedules, issuing clear guidelines for how local planning authorities engage in negotiations, and standardising templates to reduce the system’s complexity (a proposal we note that is being brought forward). Vital to improving the developer contribution process will be ensuring planning authorities have the appropriate skills and resources in these regards. This has been highlighted in the recently published Local Planning Authority Skills and Capacity Survey by the Ministry for Housing, Communities and Local Government (MHCLG) which reported 44% of planning authorities surveyed identifying skills gaps regarding CIL, Section 106 and viability. We note in our response to Q193 our proposal for Government to provide a central resource to support plan-making authorities, particularly in specialist areas. This would be particularly relevant in regards to developer contributions, with for example, support around schools forecasting helping LPAs more clearly identify triggers for school provision which would ultimately provide more certainty for developers. Please see response to Q205-212 for a more detailed appraisal of new approaches to viability assessments.
17) Do you agree that plans should set out the circumstances in which review mechanisms will be used, or should national policy set clearer expectations? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI broadly agrees that such circumstances should be set out nationally, and such circumstances should share broad alignment with what has been set out for review of SDSs.
18) Do you agree with policy PM13 on setting local standards, including the proposal to commence s.43 of the Deregulation Act 2015? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
b) Please provide your reasons, particularly if you disagree.
The RTPI understands there is a careful balancing act to be made between setting local standards where appropriate whilst also driving national consistency. We note that a number of local authorities are disappointed by proposals to limit their ability to set high standards of energy efficiency. In the event of such proposals being taken forward, the RTPI would recommend that such building regulations at a national level reflect the level of ambition needed to drive significant progress towards our net-zero targets across the nation, including encouraging innovation in this area.
The RTPI notes that elements of this policy would benefit from further clarification, in order to be implemented effectively. For example, PM13(1)’s reference to “parking and design and placemaking” may be considered very broad in their potential remit and create confusion and conflict with elements of PM13(1)(b) and PM13(1)(c). Furthermore, reference to density minimums elsewhere in the framework may provide some confusion too, with a clear overlap and inter-connection with design and place-making matters. A cross-reference mechanism, as applied with policies S1-S5, may provide a solution for this policy to be more readily applied.
19) Do you agree that the tests of soundness set out in policies PM14 and PM15 will allow for a proportionate assessment of spatial development strategies, local plans and minerals and waste plans at examination? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) If not, please explain how this could be improved to ensure a proportionate assessment, making it clear which type of plan you are commenting on?
The RTPI has previously published research on strategic planning which recommended clear examination protocol to inform the preparation of SDSs. Therefore, we greatly welcome the provisions included in PM14 and PM15. Given the significant difference between local plan and SDS preparation, including evidence base collection, time frames and level of appropriate detail, we believe that the examination processes also need to be distinct. As currently drafted, there is not enough clear delineation between each examination processes. We would encourage amendments to these policies to reflect the distinct purposes of each spatial scale. We also note potential issues relating to the application of PM15(1)(e) through the transition period if a LP and SDS are being prepared in a twin-track manner. Reference to LPs having regard to merging or adopted SDSs may account for these scenarios. The RTPI would recommend that both of these policies should be rooted in a clear link to the provisions set out in PM6 around general principles for plan-making.
20) Do you have any specific comments on the content of the plan-making chapter which are not already captured by the other questions in this section?
We note the omission of questions in the consultation document regarding supplementary plan related policies PM4 and PM16 and will comment regarding these policies in this section. The RTPI would highlight opportunities for further clarifications, for example, over the examining body relating to supplementary plans, as has been included for local plans and minerals and waste plans in PM15(1). We also recommend further clarification in relation to PM4(1)(b) and the associated examination PM16(1)(a) as to what is to be considered a reasonable conclusion on the proximity of sites. The RTPI believes that supplementary plans should be tested with similar principles as set out in PM15(1)(c) in that they should be realistic and deliverable. We also believe the test of soundness should be delivered in a proportionate way, as set out in PM15(2).
In terms of general comments on the plan-making chapter, there are a number of opportunities to provide more clarification on what is considered fair and proportionate in terms of preparing different parts of the development plan. For example, PM9 might appear excessive for the purposes of preparing a neighbourhood plan. Therefore, we would promote some guidance and clarification on which part of the development plan policies are to apply to and if so whether proportionality need be applied due to the nature of the plan being prepared in relation to the plan hierarchy set out.
Whilst the institute understands the Government’s desire to focus and expedite the plan-led system, where possible, we would support the increased use of more positive and affirmative language to better highlight the opportunities and benefits brought through a plan-led approach.
