Planning policy consultation begins on Greater Exeter Strategic Plan
Friday, 3rd March 2017
Four local authorities have joined together to progress a 'Greater Exeter Strategic Plan'. It is in its early stages, but outline details of the intentions behind the plan, what it will cover, and the various stages it needs to go through before adoption are included on the website set up to inform the public about the plan.
As explained in the consultation document issued at the end of last month (available here) the strategic plan encompasses the areas of Exeter City Council, Mid Devon District Council, East Devon District Council, and Teignbridge District Council, but excludes Dartmoor National Park. It will not replace the four district local plans, a good thing given the efforts that have gone into those plans, but as the consultation document explains it is intended to sit above them to set out 'the overall spatial strategy and level of housing and employment land to be provided in the period to 2040. The document will provide high level strategic planning policy framework for the area'.
Preparing the strategic plan is undoubtedly going to be an enormous challenge. The reasons behind it however are readily understandable, and the intention is highly admirable. Planning policy even at the local level should not be a slave to artificial boundaries that delineate local authorities. This is (one of) the criticisms of previous local plan/core strategy preparation, hence the introduction of the duty to co-operate via section 110 of the Localism Act 2011, and its inclusion in the National Planning Policy Framework. Further, one of the chief arguments in favour of replacing regional bodies with local enterprise partnerships ("LEPs") was that those latter bodies would better reflect and address the real and natural economic areas in England, rather than the established administrative/regional areas. The strategic plan can therefore knit together this wider area in policy terms (and may reflect perhaps the dominance and influence of Exeter), most likely tick the box of the duty to co-operate, and also take some of the argument about housing need and supply out of the arena of the district level local plans.
Even during writing this however, the potential for confusion is readily apparent. The strategic plan is at 'Regulation 18' stage - a reference to Regulation 18 of the Town and Country Planning (Local Planning)(England) Regulations 2012. These Regulations govern how to bring forward 'local plans'. Do we now need to start distinguishing between 'strategic' local plans, and 'district level' local plans? Do we need more acronyms in planning, and is this a return of Regional/County/Structure Plans by the back door? God forbid we start to slide back towards Local Development Frameworks as originally envisaged in the Planning and Compulsory Purchase Order Act 2004 - i.e. a suite of numerous planning policy documents that need to be separately read and understood (for 'suite' read 'proliferation'). Fine in principle if that suite of documents arrives roughly at the same time. Highly confusing if drip fed into the system, or never arriving, or having to be read alongside saved policies in previous 'old style' local plans.
The strategic plan therefore is going to have to work hard to be preferential to being able to pick up a single local plan, and understand where or how your development might sit within it. It also must be consistent with the four separate district level local plans, and vice versa. No mean feat when each separate plan is of a different age, and potentially of differing status depending on planned reviews, and if the full objectively assessed need for housing is met. Whether this is achieved will become clear once the full draft strategic plan is published.
The current consultation (options and call for sites) opened on 27 February 2017 and closes on 10 April 2017. As always, it is better to be involved than be a bystander.