POSITIVE ABOUT PLANNING

By Craig McLaren, National Director, Royal Town Planning Institute Scotland

Planning is all about creating great places for people. It does this through providing vision on how best to shape our communities over the short, medium and long term. The ‘customers’ of the planning system are not only those applying for planning permission but also broader society at large, given the system’s role in helping to shape our built and natural environment, which we all use and appreciate.

The Scottish Government has already set out how it sees planning, planners and the planning system as key ‘tools in the box’ that can help to achieve its aspirations such as sustainable economic growth, sustainable development, climate change and great places. RTPI Scotland are positively engaged in work to develop approaches to ensuring we have a plan-led approach to planning and development; to streamlining those parts of the planning process that do not add value; to promoting better approaches to placemaking; and to improving planning performance. Scottish Government has demonstrated its continued commitment through recently publishing a new draft Scottish Planning Policy document and a draft National Planning Framework. It has just published a new Architecture and Placemaking policy which outlines the value of planning. And the Town Centres Advisory Group led by Malcolm Fraser is about to publish its report which, by all accounts, sees a key role for planning in supporting our town centres. We are delighted that the Government has shown belief in, and respect for, the different roles that planning can play.

The issue which is perhaps our biggest challenge is performance. RTPI Scotland shares the aspirations of Scottish Government, and others, for the improved performance and resourcing of the planning system. The mission of RTPI is to ‘promote the art and science of planning for the benefit of the public’ which inherently means that we aim to ensure that the performance of planners is exemplary. We believe that a properly resourced planning system, working within the right framework, is key to achieving ambitions for sustainable development, economic growth and successful places across Scotland.

The Scottish Government has already set out how it sees planning, planners and the planning system as key ‘tools in the box’ that can help to achieve its aspirations such as sustainable economic growth, sustainable development, climate change and great places.

Scottish Government has every right to challenge planning authorities to improve but we feel that the approach they are taking is neither needed, nor effective. We are disappointed that, through the Regulatory Reform Bill, they intend to pursue a statutory mechanism to penalise authorities who they consider under perform in the longer term. This could lead to those planning authorities who don’t’ make the grade having the income from their planning fees reduced.

We do not think that the proposal will work. A consistently excellent planning system can only be delivered through continuous improvement which, amongst other things, involves support for poorer performing planning authorities to learn from those that are performing well.

So why do we say this? Firstly, we think it will be counterproductive to withdraw funding from planning authorities that need to improve. We feel that Scottish Government should seek to incentivise rather than penalise and look to reward good performance. It would be unthinkable that an education service, for example, would have its budget cut because of failure to meet national standards of educational attainment.

In fact we feel that it is essential that income from planning fees should be ring-fenced, used only to fund the planning service or functions supporting it. It would be perverse if any uplift in fees was not passed onto the planning service, since this could hinder the goal of performance improvement.

Our second argument is that it is currently unclear how Scottish Ministers will assess how they judge when they “are satisfied that the functions of the authority are not being, or have not been, performed satisfactorily” to quote the Regulatory Reform Bill. There is a danger that the lowest common denominator of measures will be given most attention, namely speed of decision making. Speed is an important aspect of performance but it is not the only one. The Planning Performance Framework developed by Heads of Planning Scotland takes a broader and holistic approach to assessing performance. It’s criteria focus on planning authorities being open for business; supporting high quality development on the ground; providing certainty; ensuring they have good communications, engagement and customer service; having efficient and effective decision-making processes; having effective management structures; providing good financial management and local governance; and embedding a culture of continuous improvement. This approach should influence any performance measures chosen by Scottish Government.

The issue which is perhaps our biggest challenge is performance.

Our third point is that assessing planning authorities’ performance is not simple. Performance is dependent upon others, including planning applicants, Statutory Consultees and other parts of local authorities. Also, any assessment of planning authorities’ performance must be looked at in the context of a reduction in planners in post in local authorities. The most recent figures available on staffing levels in planning departments are from the Scottish Government Planning Workforce Survey 2010 and show that the number of Full Time Equivalent planning staff in local planning fell by over 10% between 2006 and 2010 (from around 1700 to 1575). It is likely that staff levels have decreased further, and probably faster, since then given continued redundancy programmes.

And finally, the proposal may lead to different planning authorities having different fees for planning applications. This would run counter to any move to simplify and unify and could potentially cause huge confusion across the industry. Applicants often cite the need for the planning service to provide certainty and predictability. This proposal, if implemented, may make this more difficult.

We feel that the planning proposals contained in the Regulatory Reform Bill are not necessary. However, if Ministers are still minded to take them forward they should ensure that the criteria which establish whether a planning authority has ‘passed’ or ‘failed’ are clear, measurable, evidence-based and outcome-focused and examined within the context of the Planning Performance Framework. They should also make sure that the assessment of a planning authority’s performance is independent and professional and undertaken by a capable organisation with individuals that have an in-depth knowledge of planning and the planning system. And any process adopted must involve an assessment that works towards constructive and continuous improvement.

By Craig McLaren, National Director, Royal Town Planning Institute Scotland

Issue 6