with the planning system and thus welcome the opportunity to submit our response ... small businesses, namely: sustainab
CONSULTATION RESPONSE
Scottish Planning Policy – draft July 2013 Introduction The FSB is Scotland’s largest direct-member business organisation and represents around 19,000 members. The FSB campaigns for an economic and social environment which allows small businesses to grow and prosper. A planning system that has sustainable economic growth at its heart is a key part of this environment. The FSB has taken a close interest in the modernisation of the planning system and supports the Scottish Government’s moves to ensure it enables – and not inhibits – economic recovery. The FSB represents a number of small businesses who interact with the planning system and thus welcome the opportunity to submit our response to this consultation. This response draws on the 10% of FSB members who engage with the planning system. As a result, we have restricted our comments to areas that are of interest to small businesses, namely: sustainable economic growth, supporting business and employment and town centres.
Summary The FSB supports the direction of the draft SPP and notes that it chimes with many of the key points we have raised in recent years. In particular we welcome: 1. The Scottish Government’s desire to embed sustainable economic growth as a core value to further improve Scotland’s business environment. 2. Embraces an outcome based approach to planning, emphasising the key role it plays in economic development. 3. The need for decisions to be made in a transparent, accessible and timely manner. 4. The expectation of an efficient and effective planning system that promotes national consistency in the application of policy.
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Applying the town centre first policy to all significant footfall generating uses.
Supporting Business & Sustainable Economic Growth Policy Principles The FSB has consistently argued that the planning system in Scotland is a barrier to economic growth due to the time, complexity, cost and uncertainty associated with planning applications. The Scottish Government’s reform programme has helped tackle some of these problems as will the forthcoming Regulatory Reform (Scotland) Bill. It is our belief that the SPP marks a unique opportunity to embed the Scottish Government’s central purpose in a more business-friendly planning system. The SPP makes it clear that the planning system should foster a supportive business environment by attaching ‘significant weight to [the] economic benefit of proposed development as a material consideration.’ We endorse this approach but suggest that it may be worth considering whether a reference to requirements of the Regulatory Reform Bill (expected to be passed by the end of 2013) would be helpful. In addition, we believe that SPP could go further to encourage a system which is ‘open for business’ and make the following suggestions: 1. Create a more economic growth orientated planning system by introducing a defacto presumption in favour of small, local developments. Such a presumption could take many forms and would obviously have to comply with State Aid requirements. The FSB believe that the presumption should be targeted in favour of local micro and small businesses due to the disproportionate impact they have on the local economy. Recent research by the FSB, for example, found that every £1 spent by a council with a local small business generates 63p worth of additional benefit for their local economy. This compares to an equivalent 40p figure for large local firms.1 2. Linked to the above, the FSB believes there is scope for SPP to consider if it has the right policies in place to foster a vibrant business environment. If economic growth is the main objective, is there value in extending permitted development by taking small scale applications – change of use, shopfront replacements, physical extensions etc – out of the planning system? 3. In the current draft of economic benefit, we are concerned that emphasising job creation as a material consideration would undervalue and potentially disadvantage small scale applications – the foundation of sustainable, local economic development – compared to the more eye-catching large-scale developments.
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See - http://www.fsb.org.uk/scotland/specialreports
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Delivery The FSB endorses the need for development plans to be informed and led by a rigorous evidence base that details the key economic issues, challenges and opportunities within the area. This reinforces the importance of local authorities keeping up-to-date economic strategies that practically assist planners to understand the needs of the local economy, business base and labour market. Crucially, it also reiterates the need for a whole-council approach to economic development. The SPP also makes an important point about plans being deliverable and focusing on sites that can be developed within the duration of the plan. Too often the planning system is used as a repository for applications that seemingly go nowhere. Consequently, we would support the introduction of a ‘use it or lose it’ policy to tackle applications that do just enough to get planning consent granted time and time again.
Town Centres The FSB is heartened by the suggested planning policy for town centres and its complementary nature with the NPF3 analysis of towns and town centres as key ‘focal points for growth.’ SPP creates planning policy for town centres, perhaps for the first time, that is simpler to understand and underpinned by recognition of their key economic importance. What could be added, nonetheless, is a guiding principle that enables – and not controls – all forms of enterprise within town centres.2 In sum, a freeing up of planning policy. The growth of out-of-town developments has had a fundamental impact on the viability and vitality of town centres and SPP should go some way to ensuring that new developments are mixed use, in-town/edge of town, reuses previously developed land and makes best use of existing infrastructure. Quite clearly, the town centre first presumption (TCFP) advocated by the National Review of Town Centres3 should be a practical consideration that enables planning authorities to cement the primacy of towns and town centres in developmental terms. Town centre health checks and strategies, while good ideas in principle to fill the data gap and no doubt worthwhile exercises, would do nothing to prevent planning authorities from developing out-of-town and jeopardising the health of the town centre. The FSB fears that unless SPP emphasises TCFP as a material consideration or attaches significant weight to it, the key argument from the National Review would become meaningless. We also fear placing too much emphasis on a sequential approach to embed the primacy of town centres in development management given relative failure of such an approach in the retail sector. Lastly, the FSB is concerned that growing budgetary constraints on local authorities will see town centres (a nonstatutory issue) become even less of a priority than they are at present. 2
This notion is taken from an internal paper submitted by Nick Wright for the National Review of Town Centres. 33 See - http://www.scotland.gov.uk/Topics/Built-Environment/regeneration/town-centres/review
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Other matters we would like the SPP to include, as argued by Nick Wright elsewhere, are: relaxing planning policy around changes of use, the creation of a straight-forward ‘town centre use’ through local Supplementary Guidance, and addressing the complexity and risk that prevents many local authorities from using Compulsory Purchase Orders to tackle difficult sites.
Onshore Wind The FSB has no firm view on the location and scale of windfarms. Nevertheless, we broadly welcome the new approach set out in SPP and NPF3 and consider it sensible to prevent windfarms in key tourist locations like National Parks and National Scenic Areas.
Enabling Digital Communication As a proponent of joined-up policymaking, the FSB supports the proposal to promote provision for broadband infrastructure in the planning system for new developments. However, we are concerned that not all local authorities may have the technical knowledge and expertise to fully consider digital connectivity issues.
For further information on any of the points raised in this submission, please contact Barry McCulloch, Senior Policy Advisor. Email:
[email protected] or t: 0141 221 0775.
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