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PAS response to Scottish Planning Policy consultation

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spp-cover-wIn July 2013, PAS submitted a response to the Scottish Government’s public consultation on Scottish Planning Policy (SPP). SPP sets out national planning priorities and land use policies; it is primarily influential in guiding the preparation of development plans, the design of development and the determination of planning applications and appeals.

PAS is suggested that the Principal Policy section on Engagement should convey a stronger and more aspirational message on the importance of engagement within the planning system. The overall impression is that engagement is of less importance than the other principal polices, when in fact an inclusive planning system was one of the dual aims of planning reform. The draft should set out roles and responsibilities with regard to engagement in the planning system, refer to the basic minimum level of consultation required, and convey that engagement beyond the legal minimum is beneficial to all parties. Furthermore, definition of key terms and diagrammatic representations should be employed to facilitate public understanding of the avenues and benefits of engagement within the planning system.

Given the negative and adversarial way in which members of the public sometimes engage with and experience the planning system, PAS believes that a key aim of the revised SPP must be to provide sufficient contextual information to inform stakeholders adequately about key aspects of planning decision making, and thus provide them with a realistic expectation of what their engagement with planning can achieve. The requirement of the planning system to make land-use decisions in the public good and the inherent discretionary nature of the Scottish planning system should be clearly explained.

PAS regularly deal with enquiries and complaints from members of the public who feel aggrieved about planning decisions and are effectively seeking recourse to appeal. Essential contextual information in the draft SPP would make it easier to explain to members of the public and other stakeholders the statutory and policy context within which planning decisions are made.

PAS also commented that the policies on sustainable development/economic growth and engagement should be presented within the draft SPP as “underlying principles” of the whole planning system. Referring to these policies separately creates confusion; the natural response as presented currently is to try and cross-reference between the two policies and work out where they align and diverge.

Other issues addressed in the response include community planning and specialist housing requirements, particularly for gypsy/traveller communities.
The response in its full entirety can be viewed here (hyperlink here). If you or your organization have questions or comments, please get in touch with David Wood at 0131 659 9774 or david@pas.org.uk

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