Planning and Compulsory Purchase Bill - This Bill is currently being considered by Parliament ...

The views of the Branch were expressed in this letter which was sent to MPs about the Green Paper which led to the Bill ...

Dear Sir/Madam,

The Commons Transport Local Government & Regions Committee's Report on the Government Green Paper on Planning The Warwickshire Branch of the CPRE was very critical of the proposed radical reform of the planning system put forward in the Planning Green Paper, not least because of its business and economic focus at the expense of the environmental and social planks of sustainable development to which the Government claims to be committed.

So we are extremely pleased, and relieved, to learn that the House of Commons Transport, Local Government & Regions Committee chaired by Andrew Bennett MP agrees with us. "The Government's proposals are unworkable as a whole," the Committee says and it is equally critical about many of them individually. Its report was published on 3 July.

Thus, the Business Planning Zones appear "to be based on the misconceived idea that the planning system is stopping desirable development rather than helping to enable it. There is no evidence of this." As regards the Major Infrastructure Projects, the Committee thinks that Parliament should not decide on the principle, need for and location of these projects. On the contentious proposal to abandon Structure Plans and effectively county planning, the Committee thinks that the county planning function in many cases, and county structure plans, should be retained. We believe that the Warwickshire Structure Plan should one of these, and that Solihull and Coventry could be usefully brought into a joint Structure Plan next time. Whatever happens, planning should not be handed over to unelected, and therefore unaccountable, bodies. The West Midlands Local Government Association is not directly elected and not accountable.

"The proposals for Local Development Frameworks have many failings and lack many of the advantages of Unitary Development and Local Plans." We agree wholeheartedly, for this is probably the most contentious idea in the entire Green Paper and would lead to less certainty and more challenges on appeal. However, we do support the need for clearer and more simple Local Plans and Unitary Development Plans, with detailed map coverage as now.

"Statutory consultees have an important role in contributing specialist advice to local authorities" says the Committee. This is very true, but the Committee did not stress that there is one class of statutory consultee whose demise is implied in the Green Paper, though it is never spelt out. This is the proposal to remove the duty to consult Parish and Town Councils on applications in their areas. Yet they are at the most important level, where the results of decisions made will be evident for many years to come. It is extremely important to foster and value their contribution to the planning process if Government wants the planning system to be held in high regard by everyone. Valuing the role of Parish and Town Councils is also essential to achieving the Government's goal of inclusive and responsible citizenship.

"The 90% target" (for planning applications -to be delegated to planning officers), "is arbitrary and no justification was given for it." No justification other than speed - in the interests of business. However, speed does not equate to quality and where development is concerned quality of the end result must surely be the whole purpose of the planning system. If it goes wrong the results are there for many years to come.

"PPGs play an essential role in defining national policy." Planning Policy Guidance is very important and the Committee warned against whittling them away. Brevity they found would risk creating uncertainty about what is and is not planning policy.

"The Green Paper does not adequately consider the need for third party rights of appeal." Indeed, it does not; it dismisses it. We believe it should be a right in certain situations, principally where a development is a Departure from a Plan but the local authority seeks to permit it. The case for Third Party Rights of Appeal has been advocated to you in the environmental groups' joint publication last year - "Third Party Rights of Appeal in Planning." This would do much to restore public trust in the planning system.

We are delighted that the Committee recommends that "the planning system requires significantly more staff and resources than are currently available" and says that the Green Paper does not properly stress the need for councils to retain and recruit good planning staff and to set higher budgets for their development control functions. Our planning volunteers have reported serious concern about the parlous state of many planning departments in our area - in Districts, in Boroughs and in the two City Councils of Coventry and Birmingham - where staff are overstretched, undervalued, demoralised and thin on the ground. One essential way of recruiting and retaining good planning officers is to raise salaries and this must surely happen.

There are fourteen references to business contained in this paper. The Select Committee has noticed this: "There is a 'business' agenda running through much of the Green Paper. It largely ignores the environment while supporting business development. The planning system is the key bulwark in preventing urban sprawl and restraining unsustainable development and should not be subservient to the requirements of business." We agree.

We understand that the new Minister for Planning and Housing, Lord Rooker, is likely to make a policy statement before the Summer Recess. We sincerely hope that this statement accepts the conclusions and recommendations made by your colleagues on the Transport Local Government & Regions Committee. I am writing to you, on behalf of the CPRE Warwickshire Branch, to ask you to support the Committee recommendations and to press Ministers to withdraw the Green Paper proposals - replacing them with what the Committee recommends in its final paragraph (213): "gradual modernization", improving the present planning system, "working with the grain over 50 years of experience " since the landmark 1947 Town & Country Planning Act.

Yours sincerely, BRIAN DOUTHWAITE Chairman, CPRE Warwickshire Branch