Royal Commission on Environmental Pollution

I refer to your letter of 27 March 2000. This letter sets out the evidence of the Environment Director of Lancashire County Council.

Theme 3(a)
The town and country planning system serves the specific purpose of controlling development and land use. The imperative of sustainable development requires broader considerations and the integration of economic, social and environmental policy, and in the absence of alternative frameworks, people look to the development plan system to deliver this integrated approach. The planning system is not geared, in terms of its legislative base, to this broader activity. In some areas of policy this produces gaps, in other duplication.

An overarching single spatial development strategy is required that would set the "joined-up" framework for other types of plans, including development plans and local transport plans. This type of model is emerging in the European Spatial Development Perspective. Such strategies could then weld together the spatial dimensions of land use and non-land use policies and bring together consideration of education, training, housing, public transport, traffic management and the organisation and management of those activities having a major impact on travel patterns and local economies, such as town centres, employment areas, colleges and hospitals.

National planning policy guidance should either be focused solely on land use or be clearly addressing wider spatial and sustainability issues with the mechanisms for implementation clearly identified. At the moment the national RPG, PPG and MPG regimes provide a confusing mixture - part guidance for land use planners but partly addressing wider social, economic and environmental agendas.

Theme 3(b)
A hierarchy of environmental plans has emerged 'de facto'. There would be advantages in establishing a clearer hierarchy if, as a result, the purpose and function of each rung in the hierarchy were clearly understood by plan makes and plan users.

At the moment there is overlap in plan content. David Lock, Vice-Chairman of the Town and Country Planning Association, described this as the "chaotic cascade" in the April 2000 Edition of Town and Country Planning Journal. The introduction of other types of plans has increased this confusion and overlap. Non-statutory plans such as Local Agenda 21 strategies and Local Environment Agency Plans (LEAPs) have a less clear hierarchy. Their integration or co-ordination with other plans is often problematic. LEAPs are a case in point. In Lancashire their primary role appears to be as 'programmes of work' for the Agency, rather than strategies based on public consensus and the priorities of other agencies.

The emerging duty for local authorities to prepare a Community Plan will enable them to develop an overarching vision for their area and translate this into a policy framework into which other strategies and plans can fit. However, this is yet another type of plan and raises the familiar issues of resourcing their preparation, plan overlap and confusion among plan users. There is a need for a fresh look at each plan.

A re-appraisal of what each type of plan is meant to deliver would require either each having to give up some of its content and have a narrower focus (because other aspects are better dealt with at another level) or some types of plans being abandoned or combined with another.

A narrower focus and shorter list of contents needs to be agreed for each level of the hierarchy. This could then lead to quicker plan production and allow some resources to be transferred to more effective consultation. DETR could help by modernising and clarifying what is required of each level of the hierarchy. At present, Planning Policy Guidance Notes often require policies on particular subjects to be included in both structure plans and local plans and there is also a growing tendency for similar material to be included in Regional Planning Guidance, when often a policy at one level would suffice.

Lancashire County Council, Blackpool Borough Council and Blackburn with Darwen Borough Council recently conducted a survey of uses of the County Structure Plan. Part of the purpose was to discover the extent to which the policies of the Plan are actually used. Many were widely used by the public, private and voluntary sectors. These can be interpreted as 'core topics' for strategic plans dealing with matters such as green belts, urban and rural development patterns, housing and employment provision, retail policy, the road network and strategic transport corridors. Other policies have been used much less frequently. Some of these policies were included in the Plan to accord with Government guidance set out in PPGs.

Theme 3(d)
It is doubtful whether present arrangements are efficient and cost-effective, not least because of the multiplicity of plans and the amount of content and level of detail that each contains. The observations made of 3(b) are relevant here.

The overriding consideration should be to keep the size and complexity of plans manageable. If, at Theme 2(c), it were concluded that the land use planning system should help deliver other policy targets, then, in the plan-led system, this would require appropriate policies in development plans. Plans would become more complex, unless there were trade-offs with some areas of policy deleted from particular levels of plan-making.

Theme 3(g)
Planning regulation alone cannot deliver environmentally sustainable solutions. Economic instruments need to be applied in tandem. The potential use of economic instruments was signposted in "Modernising Planning", the Policy Statement by the Minister for the Regions, Regeneration and Planning in January 1998. Economic instruments need to be applied with more vigour so as to secure urban regeneration, increased re-use of brownfield sites and improved environmental quality in urban areas.

The County Council, Blackpool Borough Council and Blackburn with Darwen Borough Council conducted a survey of more than 1,100 businesses as to their future land and building requirements and their degree of satisfaction with their present location. Among those firms considering moving there was considerable dissatisfaction with their present general surroundings (which included issues such as the surrounding physical environment, litter and crime) (Table 1). The regulatory aspects of the planning system cannot remedy such deficiencies on its own.

Source:   Lancashire CC, Blackpool BC, Blackburn with Darwen BC, 2000.

The same survey also asked companies about their attitude to possible policy tools designed to encourage greater use of brownfield sites (Table 2). A clear majority of companies said they would be influenced by financial incentives, improved site access and general environmental improvements. A much smaller percentage would be influenced by restrictions on greenfield development.

Source:   Lancashire CC, Blackpool BC, Blackburn with Darwen BC, 2000.

I hope the Royal Commission finds this contribution helpful.

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