Royal Commission on Environmental Pollution

Thank you for the invitation to respond to the issue set out in the Annexe to your letter of 27th March. David Stathers (of Boots The Chemists), a Forum member, sent you comments following the seminar on 3rd February, which I was unable to attend.

The Forum does not wish to respond to all the issues raised; but to make two key points only. One concerns the extent to which the existing structure of the planning system fails to meet the needs of planning at the sub-regional, and regional level. The experience of planning for retail development illustrates this clearly; but it is only one instance, though an important one.

The system does not at present sufficiently recognise the impossibility of managing the environment without an understanding of the dynamics of urban change, their effect on the sub-region (at least); and the capacity to respond to those dynamics. Changing patterns of retailing, with consequential demands for mobility and accessibility, is one example of what we have in mind. Waste disposal is another. I attach a short memorandum by Geoff Steeley that develops this point.

The second point is the concern that Forum members have about the lack of expertise in retailing matters which local authorities now have at their disposal. We are sure that the lack is not in the retailing field alone. But the consequence of shortage of strategic and analytic capacity to deal with retailing and its consequences is in delay and - is still more serious - perverse decisions, whether on individual cases or plans.

The submission also comprised a short memorandum from the Chairman NRPF Research Group on Retail Planning and an article from Issue 1 of Retail Forum (April 2002). A copy of this is available on request from the Royal Commission Secretariat.

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