To be successful, Place Plans will need to link carefully into the preparation and review cycle of Local Development Plans (LDPs). Timing of a Place Plan will therefore be an important consideration for a local planning authority.
Most Place Plans are therefore expected to be prepared with the aim of becoming Supplementary Planning Guidance (SPG). As SPG, a Place Plan can only be adopted once a LDP has been adopted. The temptation then may be to have a LDP in place before following up with a series of Place Plans. In instances where a LDP has recently been adopted that can give a general or specific policy hook to a Place Plan, it may be the ideal time to start work on Place Plans.
However this model of plan-making may unnecessarily narrow the potential benefits that Place Plans can offer to LDP plan-making, especially in light of the number of LDPs that are already being Revised or will be Revised shortly.
There is great potential in preparing Place Plans in parallel with the LDP. Welsh Government acknowledges that LPAs may want to consider producing succinct LDPs, meaning that new SPGs may be necessary to support the plan strategy or policies, or to provide more detailed guidance on major site allocations.
This presents a potential role for Place Plans to be prepared in parallel with the emerging LDP, offering a mechanism for local participation, information and evidence gathering to shape relevant policy development in the emerging LDP. This could be the case in terms of sites allocated in an LDP. Some LDPs may only identify the larger sites, yet there can still be many more small sites potentially available and appropriate. Although a Place Plan as SPG could not allocate such sites, they could usefully be identified and assessed at Place Plan level. For a good example, Bath and North Somerset Council are engaging communities in the evidence collection process for site allocations in the Local Plan.
At the same time, where a Place Plan is being prepared in parallel with LDPs it gives a local community the chance to develop or strengthen organisational capacity and know-how to prepare a Place Plan for their area linked to the discussions and decisions directly informing the LDP.
In cases where a Place Plan is being prepared in parallel with LDPs this may mean that they too are consulted on in parallel with the LDP. However, as SPG, a Place Plan would not be subject to examination.
SA & SEA?
SPG is non-statutory and does not require a Sustainability Appraisal (SA) but the requirement for a Strategic Environmental Assessment (SEA) may apply to SPG even though it is non-statutory, if judged to have significant environmental effects not already considered and dealt with through the SA of the LDP, for example some site briefs / masterplans / Place Plans. It is the local planning authority that will need to determine whether an SEA is required before adopting the SPG but preparing Place Plans in parallel with the LDP may negate the potential need for a separate SEA.