UNISON Scotland's response to the White Paper: Modernising
the Planning System
Modernising the Planning System
UNISON is Scotland's largest trade union representing
over 150,000 members working in the public sector. We are the
largest trade union in local government and represent local authority
planning staff. Other members have a direct interest in the system
such as infrastructure providers in water and energy as well as
a wider citizenship interest in promoting economic development
and protecting the environment
UNISON Scotland broadly welcomes the proposals in
the White Paper: Modernising the Planning System. Our detailed
approach to planning reform is set out in our submission to the
original consultation. This can be viewed on our website (http://www.unison-scotland.org.uk/response/plandev.html)
together with our initial briefing on the Planning White Paper
This response is therefore limited to specific proposals
in the White Paper.
Making the Planning System Fit for Purpose
UNSON Scotland broadly supports the proposed hierarchy
Further clarification is needed on how applications
will be classified under this system to avoid the centralisation
of planning and a loss of local participation. Even strategic
national developments have local implications. There is also a
need for a clearer criterion for calling in major developments.
It is not the role of the Scottish Executive to ‘supervise' decisions
taken by democratically elected councils except when the authority
has a significant vested interest.
The National Planning Framework has to be about
more than land use. It must incorporate wider public policy issues
and reflect the need for long term development - beyond the normal
political time scales.
We welcome the new appeal arrangements including
local review of local developments. We would however urge a more
radical step to limit the right of appeal to un-elected Reporters
of decisions taken by elected local authorities as set out in
our submission to the original consultation.
We agree that more householder developments could
be covered by permitted developments and excluded from the requirement
for planning permission. However, it has to be recognised that
many of these issues are the cause of neighbour disputes and inappropriate
deregulation could cause problems for other agencies.
UNISON Scotland welcomes the primacy given to development
plans in the White Paper. We also support the statutory requirement
to update development plans every five years. However, this and
many other aspects of the proposals will be meaningless unless
planning departments are properly resourced.
Simpler plans and model policies are also welcome
although these should still enable plans to reflect local needs
and aspirations and not impose a ‘one size fits all' approach
across Scotland. They must be flexible and more clearly link in
with community planning and other local policies. It has to be
recognised that simpler plans may create more scope for conflict
and involve planners in significant workload.
Whilst a single tier of development plans is welcome
these still require considerable cross boundary working even outwith
the city regions.
Planners will welcome the recognition that their
role is primarily visionary and enabling. Unfortunately the pressure
on under resourced departments means that many are forced to concentrate
on their regulatory role. We are disappointed that the White Paper
concentrates its comments on culture change almost exclusively
on planners and local authorities. If culture change is to succeed
applicants, particularly those in the commercial sector also need
to respond to the need for culture change.
UNISON Scotland supports the White Paper's aims
of widening public involvement at an earlier stage in the process
without the introduction of Third Party Right of Appeal (TPRA).
We are however concerned over the absence of detail
on how parliamentary scrutiny will be undertaken on the National
Planning Framework. It is essential that proposals be robustly
tested given the implications for local communities. There should
be clear statutory procedures for the involvement of local planning
Equality of access will only be achieved if scrutiny
is properly resourced. This includes the role of community councils.
It has to be recognised that development plans, particularly simplified
versions, will always be viewed as more abstract than specific
We support the strengthening of enforcement powers.
All too often the powers and penalties are insufficient to deter
developers and appeal mechanisms are used to delay enforcement
Supporting Planning Authorities
Whilst UNISON welcomes the allocation of resources
to the Planning Development Budget this does not address the need
to adequately fund the core functions of planning departments.
The key to modernising the planning system is a
properly resourced and well-trained planning service that has
political support at national and local level. Staffing numbers
have remained largely unchanged for a decade despite a 20% increase
in the number of planning applications and many departments are
reporting staffing shortages.
The White Paper proposals will place significant
new demands on planning authorities. Neighbour notification, tree
preservation orders, hearings, pre-application consultation and
broader public involvement all have significant resource implications.
The White Paper is strong on demands placed on planning authorities
but noticeably weak on supporting change with real resources.
Whilst it is the responsibility of the Scottish
Executive to oversee the effective functioning of the planning
system it is not their role to interfere with the decisions of
democratically elected local authorities. Powers of intervention
must genuinely be powers of last resort.
For further information please contact:
Matt Smith, Scottish Secretary
14, West Campbell Street,
Glasgow G2 6RX
Tel 0141-332 0006 Fax 0141 342 2835
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