10. Additional issues and key themes
Additional issues raised
10.1 In addition to comments at specific questions, some respondents made more general comments about the context or challenges associated with developing LPPs. Please note that the relevant Scottish Government policy team has access to all responses, and the summary below is designed to give a brief overview of the type of issues raised.
The case for and status of Local Place Plans
10.2 There was a question as to whether the case for introducing LPPs has been made. This was connected to a concern that, without a clear purpose, they will not make a real, tangible difference to communities or result in significant change in terms of the local experience of the planning system. Rather LPPs will consume huge amounts of voluntary effort and time but ultimately result in more frustration with the planning system. There was a concern that community expectations could be raised by mandating regulations, but that it remains unclear to what extent and how these expectations could be met.
10.3 Respondents also commented on the role of LPPs and how they are expected to fit with the wider development planning landscape. There was support for increased integration between spatial and community planning at a local level, which was seen as paramount to the success of the LPP approach. A clear understanding and articulation of how spatial, community planning and community led planning should interact was seen as critical, and there was a call for the Scottish Government to provide a clear steer through both legislation and guidance on the links and interactions for LPPs with community planning.
10.4 In relation to the status of LPPs one suggestion was that, once agreed by the community, they should be given due priority and weight as a material consideration and should have meaningful influence on decision-making. This was associated with a concern that the 2019 Act requires LDPs to take a registered LPP into account but provides no guarantee that the LPP will affect the development plan or act as a significant material consideration in planning decisions. There was a query as to whether it is right to encourage communities to embark on a process if they have no recourse to decisions or plans that do not accord with their LPP.
10.5 In relation to the timing of LPPs, it was suggested that if LPPs are to inform LDPs, they will need to be prepared in advance of, at the latest, the Proposed Plan stage of LDP preparation. A concern was that:
- This places a time pressure on the preparation of LPPs by community bodies, particularly in areas where the Local Authority may begin preparation of a new LDP as soon as the relevant regulations come into force, expected to be spring/summer 2022; and
- There could then be a danger that there could be delays to the LDP process, creating a 'bottleneck' in the system.
10.6 It was suggested that the legislation and subsequent guidance should also provide some further clarity on the different scenarios allowed for depending on the timing of a community body preparing a LPP – for example when it is intended to amend an adopted LDP or when it is intended to inform an emerging LDP at the outset of the preparation process of an LDP.
10.7 It was also suggested that where community led plans already exist but do not meet the requirements for an LPP, some form of plan conversion or retrofitting is established and available to community bodies, to help avoid duplication and ensure the work undertaken by a community to establish these plans is not lost or undermined with the introduction of LPPs.
10.8 A small number of key themes emerged from across the consultation responses. These are summarised briefly below.
Fit with other plans
10.9 It was seen as important to be clear about how LPPs relate to other national and local plans, and especially to the LDP. In particular, there needs to be clarity around whether the priorities set out in an LPP and the relevant LDP can differ, and if so, how the planning authority can or should respond to any differences. Issues relating to the timing of LPP development, relative to the timescales for LDPs, also need to be considered.
Statutory or guidance led approach
10.10 A statutory based approach was seen as having its advantages, for example in terms of ensuring that a consistent and robust approach is taken to LPP development. However, to avoid community bodies being unable or unwilling to develop an LPP, any requirements should not be excessively onerous or prescriptive. There may be a case for taking a guidance-led approach wherever possible.
Transparent and inclusive approaches
10.11 It was considered important that the process for developing LPPs is both transparent and inclusive. It will be important for the community body to be clear about the evidence that informs the LPP. The whole community should have opportunities to be involved, and the approach to engagement and consultation should consider the needs of those who can sometimes be excluded. However, it also needs to be recognised that engagement and consultation can be both challenging and resource intensive.
10.12 It was noted that community bodies have limited resources and will not all have the capacity to ensure compliance with significant regulatory requirements. They will need support, both in terms of funding and access to expertise. Some communities will require more support than others.
10.13 Local authorities may need to provide guidance and support to community bodies, and this will have implications in terms of the number and skills of staff required. It cannot be assumed that local authorities will be in a position to provide funding for community bodies. Establishing a register and map of LPPs, and the assessment of LPPs will also have resource implications.