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1 Taylor Review of Planning Practice Guidance Briefing Note by UDL January 2013 DCLG Published the Review and the Government s response on 21 st Dec 2012 for comment. The consultation ends on 15 th Feb Details available at This note includes: Summary of Review Recommendations Design Related Guidance in Review Annexes Observations on the Review Suggestions for a Revised Design Guidance Suite Annex 1. Consultation Questions with draft answers from UDL Annex 2. NPPF Design Related Content Annex 3. Public Comments on the Review made by others Summary of Review Recommendations 1. Planning Practice Guidance owned either by DCLG or jointly by DCLG and other government departments or agencies should support effective planning. It must be clear and up-to-date, having only essential information, and should not repeat statutes and regulation. It should not include best practice examples, which are better provided by practitioner bodies. 2. Guidance should be a web-based, live resource, on a single site structured around the NPPF text. 3. The web based guidance suite should be kept up to date by DCLG and users should be able to recommend changes at any time. An annual review would be valuable. 4. The Chief Planner should sign off any content or changes to the site and, therefore, all official planning guidance.

2 5. As the site will change over time, all content should be printable and date stamped so users can evidence that it was current when used. 6. PINs guidance should be included on the site and PINs should be involved in its maintenance. 7. Whatever guidance other Government Departments produce, it will only constitutes formal Government Planning Practice Guidance once it is admitted to this website by the Chief Planner 8. The website could signpost organisations providing best practice guidance and other advice in relevant areas (e.g. links to heritage organisations associated with the NPPF section on heritage) but not endorse specific documents. Links to award schemes could provide an ever evolving body of best practice examples. 9. The report lists guidance that is not fit-for-purpose. Where it will be necessary to create new material, the vital elements from existing guidance should be drawn out (in consultation with practitioners) for the web-based resource. This should be done by July 2013, by which time all existing guidance should be cancelled. 10. Government should consult on the Review s proposals as soon as possible. 11. By 28 March 2013, the first anniversary of the publication of the NPPF, immediate cancellations should have be made, work should be in progress on the new guidance site and the most urgent updating of guidance should be complete. 12. Once the new web resource is fully established, it should be open to crowd-sourced checks online, but because of amount of change proposed there should be formal consultation on initial site and the way it will be managed. 13. Documents in Annex A should be cancelled by 28 March Material in Annex B should be withdrawn but useful bits incorporated into revised guidance. They cover important issues but are not immediately needed. 15. Guidance in Annex C should be retained until replaced by revised guidance. It should be edited and focused on NPPF structure and policies. 16. New guidance on subjects in Annex D should be created. 17. The priority is the new website: a single coherent suite of guidance. But editing/drafting should first look at: Duty to Cooperate, Viability, SHMA and SHLAA, Climate Change and Renewable Energy, Flooding, Environmental Impact Assessment, Sustainability Appraisal Biodiversity, and Development Management issues of prematurity and propriety,

3 Design Related Guidance in Review Annexes Annex A to be cancelled Going to Town: Improving Town Centre Access (produced by Llewelyn-Davis for DTLR and the National Retail Planning Forum in 2002). o Reason for cancelation - out of date and the issues set out are well understood by planners. o UDL comment - includes good advice, very visual, lots of examples maybe not best as Govt guidance but material may not be easy to find elsewhere. Planning and development briefs: a guide to better practice (1998) o Reason for cancelation - No need for this type of best practice advice from Government o UDL comment not particularly helpful, but does not exist elsewhere unless produced by individual local authorities. Annex B to be cancelled, and relevant material incorporated into guidance in the future. Good Practice Guidelines: Delivering Travel Plans through the Planning Process (2009) and summary doc o Reason for cancelation Guidance needed on this issue but should be streamlined. Cancel existing advice and prepare new guidance. o UDL comment - Useful and important issue, not clear why should be cancelled before replacement in place. Plan-making manual (2009, web-based, hosted by LGA / PAS) o Reason for cancelation Outdated, based on old regulations and policy, repeats policy. Could be replaced with concise advice on the basics of the process in the interim, before new content produced on how duty to co-operate, local plans and neighbourhood planning fit together. o UDL comment - Hasn t been updated post-nppf so out of date, which is presumably why it s on this list. Preparing design codes: a practice manual (2006, written by CABE/UCL/Tibbalds for DCLG) o Reason for cancelation The guidance provides advice on design codes which are promoted in the NPPF. This guidance should be streamlined as part of the shortened guidance suite o UDL comment - Again not clear why it should be cancelled before a replacement is coming forward. A comment from one of the original authors is that it is very specific, and streamlining would be difficult. Understanding of how to apply codes must have moved on in last 8 years. Planning for town centres: guidance on design and implementation tools (2005) o Reason for cancelation The guidance contains principles of good town centre design, but these aspects are considered to be well understood and mainstreamed in planning work. Key aspects should form part of a shortened guidance suite. o UDL comment - This short document included info that did not make it into PPS6 and looked to support issues which might actually be seen as more important today than in 2005 such as dealing with edge of centre buildings and uses. May only be mainstreamed and well understood because of the document and all the training, discussing, thinking, sharing of best practice etc that it formed a catalyst for over the

4 years. Probably correct that this does not need to be Govt guidance, but we do need some fresh thinking on design for town centres. Diversity and Equality in Planning (2005) written by Heriot-Watt University for ODPM o Reason for cancelation Pre-dates Equalities Act 2010, so could be cancelled, but need to consider new advice on this issue in line with new legislation. o UDL comment - It is not always easy to understand how the built environment can support these objectives, so any new thinking on the subjects, in light of the 2010 Act could be helpful. Safer Places, The Planning System and Crime Prevention (2004) o Reason for cancelation The essential principle of this guidance is contained within the NPPF. Its guidance is now considered to be understood and mainstreamed in planning work. Key aspects should form part of a shortened guidance suite. o UDLcomment - 9 years old so could do with checking advice is still relevant and reflects best practice. Again concern about mainstreaming argument: how important is the presence of the guidance in achieving this? Better Places to Live By Design (2001) o Reason for cancelation contains principles of good design, but these are considered to be well understood and mainstreamed in planning work. Key aspects should form part of a shortened guidance suite. o UDL comment - Building for Life is not mentioned, but its 2012 version probably provides the most up to date guidance on this subject. By Design, Urban Design in the Planning System towards better practice (2000) o Reason for cancelation contains principles of good urban design, but these are considered to be well understood and mainstreamed in planning work. Key aspects should form part of a shortened guidance suite. o UDL comment - Has needed an update for at least 6 years now. But it is referred to in many local plans and other documents and decisions so may be worth considering keeping the name within a design section on the new web based suite. Annex C to be retained, edited/reformatted and included in new web based resource. An Introduction to Neighbourhood Planning (2011) o Reason for retention - This is the only advice issued by DCLG, still helpful in setting neighbourhood planning advice. o UDL comment A subject which would benefit from learning from Frontrunners and emerging practice, so needs more work than a quick rewrite for the new web resource. Manual for Streets (2007) o Reason for retention - Some good advice, but not needed in this format. Keep for now, but review what is planning advice, and what is outside planning and can be provided elsewhere. o Comment true some of this is not relevant to planning, but some is, particularly regarding the layout and design of large housing developments. Manual for Streets 2 has some useful content for town centre plans/briefs and developments which should be considered for the new web resource.

5 Observations on the Review The general thrust of the review seems eminently sensible; having out of date, confusing guidance is of no benefit to anyone. The opportunity for DCLG to create a coordinated and up to date guidance suite with clear links to NPPF policies is very welcome. However there are a number of issues and ideas in the review which are unclear or worrying including: o o o o o Justifying cancelation of guidance because its content is well understood and common practice seems slightly perverse logic. In many ways this circumstance shows that the guidance is working well and is useful and there is no guarantee that its content will remain common practice if it is no longer around, even if the NPPF has top-level policies on the issue. Documents in annexes B and C are generally described as having useful content. There may be good logical reasons why some should be removed before their replacement is published (annex B) but others retained until replaced (annex c). The logic is not clearly apparent, particularly where the documents relate to policy areas not procedural issues. For example why is Manual for Streets in Annex C and Better Places to Live in Annex B is the design of residential streets more important than the design of residential buildings? Considering content from both are recommended for inclusion in a new more succinct suite, why keep one and remove the other first? Resources are an obvious problem at present, and it is not clear who will draft and pay for the new web resource. There is also no mention of whether research will be undertaken to support the new resource rather than simply an edit, précis and reformat exercise. Some of the most successful guidance over the last 10 years or so has been based on good research justifying their content and proving their practicality Manual for Streets 1 and 2 are good examples. At the very least could the new web based resource include a crowd sourced research wish list and support coordination between any organisation that may be able to do relevant research to help prevent duplication? Existing guidance documents, whether looked at by the review or not, may be referred to in local plans, appeal decisions, conditions etc following advice not to duplicate national guidance. Removing the names of these documents from the lexicon, even if some of their content remains, could cause confusion and passes on the need for urgent review to hardpressed local authorities. Therefore would it be useful for the web resource to include a cross-reference list at least for the interim, explaining where, for example, content in By Design on the qualities of well designed places can be found in the new guidance suite. The review makes recommendations about the relationship between the web resource and guidance and best practice produced by others. A consistent approach would be useful, but it would be useful for DCLG to publish criteria they will use to decide which external documents they will provide links to from the guidance site.

6 A Revised Design Guidance Suite The review provides an excellent opportunity to consolidate the best existing design related guidance and fill any gaps relating to NPPF policy. There is certainly quite a lot of duplication between existing documents, which were drafted by different people over around 10 years and related to PPGs and PPS policies. Therefore it would be beneficial to the success of the NPPF itself for existing design related guidance to be consolidated and refreshed, focusing on NPPF policies and pulled into one place. The NPPF includes a significant amount of design related content, (reproduced at the end of this note) within the following policy areas: Sustainable development Town centres Transport and highways Housing and residential environments Requiring good design Health It is suggested that the drafting of new succinct national design guidance should relate to these headings, rather than existing guidance documents. This would allow for elements of any existing guidance to be considered, irrespective of who produced it and which annex the Taylor Review has placed it in. For example, some material from Going to Town: Improving Town Centre Access and and Manual for Streets 2 might be useful in guidance, alongside learning from Portas Pilots as they relate to NPPF town centre policies. Not only content from annex B or C documents could be considered. The following is a first suggestion as to what consolidated design guidance could include: Topic Covering From Sustainable development Town centres The role of built environment in achieving this mixed use, density, functionality etc. How to consider moving from poor design to better design what does this actually mean in terms of characteristics of place and qualities of proposals What makes for a successful town centre environment as called for in NPPF, e.g. quality of public realm; ability to get to, spend time in, move through area; balance given to different transport and place based By Design Urban Design Compendium Other non-dclg documents that are in common use. Going to Town: Improving Town Centre Access Planning for town centres By Design

7 Transport and highways Housing and residential environments Requiring good design uses etc. Options for the position and design of parking facilities such as pavement level parking pads. Designing development layouts, infrastructure and spaces that support NPPF policies including: Designing for freight/home deliveries Designing for cyclists and pedestrians Design of transport interchanges and stations Designing safe and secure places which minimise conflicts between users Minimising street clutter Design of layout of large scale developments including placement of non-residential uses. What constitutes high quality homes as required through the NPPF and how design can support the needs of different groups. What exceptional quality or innovative nature of the design for rural exemption houses means. What constitutes good design e.g. the qualities of well designed places their relationship to development characteristics, architectural quality and the difference between aesthetics and function, how to consider local character, distinctiveness and innovation, optimising site opportunities and mixing uses, designing inclusive environments, crime prevention, Manual for Streets 2 Current best practice Manual For Streets 1 and 2. Cross reference/links to DfT TALs and other relevant documents. Good Practice Guidelines: Delivering Travel Plans through the Planning Process Best practice learning from programmes like TfLs Better Streets work, emerging designing for cycling thinking and Crossrail stations and their surrounds. Planning and development briefs: a guide to better practice Preparing design codes: a practice manual Better Places to Live By Design Building for Life 12 Links to Housing Design Awards By Design family of documents Safer Places, The Planning System and Crime Prevention Diversity and Equality in Planning Preparing design codes: a practice manual An Introduction to Neighbourhood Planning

8 using design codes, masterplanning and big scheme layout designs, using design reviews, involving communities in design issues, drafting local and neighbourhood level design polices, CABE s most useful documents on masterplanning best practice, using design and access statements, writing design policies etc. Urban Design Compendium and links to design awards. What does this policy mean in practice - Permission should be refused for development of poor design that fails to take the opportunities available for improving the character and quality of an area and the way it functions. Health Policy in NNPF calls for creating places for people to meet, strong neighbourhood centres with active street frontages, safe and accessible environments Safer Places, The Planning System and Crime Prevention Diversity and Equality in Planning By Design The following is a suggestion for the content of design related guidance for the new web resource it would draw from documents within Annexes B and C and also documents not considered by the review, such as Building For Life and Manual for Streets 2.

9 Annex 1. Consultation Questions with draft answers from UDL 1. Do you agree with the recommendations of the Review Group overall? Yes in terms of the need to consolidate and review content of government guidance, the idea of creating a web based, well managed single resource. However suggest it would have been beneficial to look at what should be kept, removed or newly written with reference first to NPPF content, rather than to a list of existing documents to help support the creation of practical and valued national guidance. 2. Do you agree with the proposed recommendations for a much reduced set of essential practice guidance in the format recommended? (Recommendations 1, 2, 3, 5, 6) Yes these seem sensible as long as resources can be found to implement them. 3. Do you agree that standards for future Government Planning Practice Guidance should be implemented by the Chief Planner in DCLG, but with decisions on what to include within guidance still taken by Ministers? (Recommendation 4) Yes, it would be useful for DCLG to publish criteria by which the chief planner will decide what guidance will be included or signposted. If ministers make the decisions they should be required to justify them against the published criteria. 4. While access to all planning guidance online will be free of charge, do you think it would be appropriate to offer planning professionals an additional service involving immediate notification of every revision to the guidance, and to make a small charge for this service? (Recommendation 6) No this could mean that developers are better informed than community groups or local authorities. 5. Do you agree that the new web based resource should be clearly identified as the unique source of Government Planning Practice Guidance? (Recommendations 7-9) Yes one resource site seems a sensible idea. 6. Do you agree with the recommended timescales for cancellation of guidance and new/revised guidance being put in place? (Recommendations 10-13) No. There seems little justification for placing some documents in Annex B and some in C even if some of the policy areas they relate to are seen as more important than others at the present time, documents in both annexes relate to NPPF policies and there seems no benefit in cancelling annex B guidance before its useful parts have been included in the new suite. 7. Do you agree with the recommendations for cancellation of existing guidance documents? Are there specific, essential elements of current guidance material that should in your view be retained and considered for inclusion in the revised guidance set? (Recommendations 14-16)

10 The justification that guidance is not needed because its content is now common practice seems counter-intuitive surely this shows the guidance is working well. There is no guarantee that it will remain common practice if the guidance is withdrawn. It would be useful to cross-check that the elements of existing guidance that relate to NPPF policies will remain, and that any gaps in such guidance is filled. Suggestions regarding design related guidance are given above. 8. Do you agree with the recommended priority list for new/revised guidance? (Recommendations 17-18) These seem sensible areas to priorities for new guidance, but as said above an exercise to consider what other elements of the NPPF require new guidance, potentially through comments made on the new web resource, and a published timetable for this work would be of benefit. 9. Are there any further points you would like to make in response to the Review Group s Report? Do you have additional ideas to improve and/or streamline planning practice guidance? Criteria for agreeing links to guidance, awards and best practice produced by others should be provided. Much existing guidance is based on research. There is no mention in the review of options to refresh such research or undertake new research to help with the refresh of existing guidance or drafting or new content.

11 Annex 2 NPPF Design Related Content The following are extracts to help consider possible content and format for design guidance if you are using the NPPF it is best to read the full version. Sustainable development 9. Pursuing sustainable development involves seeking positive improvements in the quality of the built, natural and historic environment, as well as in people s quality of life, including (but not limited to): making it easier for jobs to be created in cities, towns and villages; moving from a net loss of bio-diversity to achieving net gains for nature replacing poor design with better design; improving the conditions in which people live, work, travel and take leisure; and widening the choice of high quality homes. 17 Always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings; take account of the different roles and character of different areas, promoting the vitality of our main urban areas, promote mixed use developments, and encourage multiple benefits from the use of land in urban and rural areas, recognising that some open land can perform many functions (such as for wildlife, recreation, flood risk mitigation, carbon storage, or food production); Town centres 23 Planning policies should be positive, promote competitive town centre environments and set out policies for the management and growth of centres over the plan period. In drawing up Local Plans, local planning authorities should: (long list follows) 40 Local authorities should seek to improve the quality of parking in town centres so that it is convenient, safe and secure, including appropriate provision for motorcycles. Transport and highways

12 35 Plans should protect and exploit opportunities for the use of sustainable transport modes for the movement of goods or people. Therefore, developments should be located and designed where practical to accommodate the efficient delivery of goods and supplies; give priority to pedestrian and cycle movements, and have access to high quality public transport facilities; create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians, avoiding street clutter and where appropriate establishing home zones; incorporate facilities for charging plug-in and other ultra-low emission vehicles; and consider the needs of people with disabilities by all modes of transport. 37 Planning policies should aim for a balance of land uses within their area so that people can be encouraged to minimise journey lengths for employment, shopping, leisure, education and other activities. Housing and residential environments 38 For larger scale residential developments in particular, planning policies should promote a mix of uses in order to provide opportunities to undertake day-to-day activities including work on site. Where practical, particularly within large-scale developments, key facilities such as primary schools and local shops should be located within walking distance of most properties. 50 To deliver a wide choice of high quality homes, widen opportunities for home ownership and create sustainable, inclusive and mixed communities, local planning authorities should: plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities, service families and people wishing to build their own homes); identify the size, type, tenure and range of housing that is required in particular locations, reflecting local demand; and 55 Local planning authorities should avoid new isolated homes in the countryside unless there are special circumstances such as: the exceptional quality or innovative nature of the design of the dwelling. Such a design should:

13 be truly outstanding or innovative, helping to raise standards of design more generally in rural areas; reflect the highest standards in architecture; significantly enhance its immediate setting; and be sensitive to the defining characteristics of the local area. Requiring good design 56. The Government attaches great importance to the design of the built environment. Good design is a key aspect of sustainable development, is indivisible from good planning, and should contribute positively to making places better for people. 57. It is important to plan positively for the achievement of high quality and inclusive design for all development, including individual buildings, public and private spaces and wider area development schemes. 58. Local and neighbourhood plans should develop robust and comprehensive policies that set out the quality of development that will be expected for the area. Such policies should be based on stated objectives for the future of the area and an understanding and evaluation of its defining characteristics. Planning policies and decisions should aim to ensure that developments: will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development; establish a strong sense of place, using streetscapes and buildings to create attractive and comfortable places to live, work and visit; optimise the potential of the site to accommodate development, create and sustain an appropriate mix of uses (including incorporation of green and other public space as part of developments) and support local facilities and transport networks; respond to local character and history, and reflect the identity of local surroundings and materials, while not preventing or discouraging appropriate innovation; create safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion; and are visually attractive as a result of good architecture and appropriate landscaping. 59. Local planning authorities should consider using design codes where they could help deliver high quality outcomes. However, design policies should avoid unnecessary prescription or

14 detail and should concentrate on guiding the overall scale, density, massing, height, landscape, layout, materials and access of new development in relation to neighbouring buildings and the local area more generally. 60. Planning policies and decisions should not attempt to impose architectural styles or particular tastes and they should not stifle innovation, originality or initiative through unsubstantiated requirements to conform to certain development forms or styles. It is, however, proper to seek to promote or reinforce local distinctiveness. 61. Although visual appearance and the architecture of individual buildings are very important factors, securing high quality and inclusive design goes beyond aesthetic considerations. Therefore, planning policies and decisions should address the connections between people and places and the integration of new development into the natural, built and historic environment. 62. Local planning authorities should have local design review arrangements in place to provide assessment and support to ensure high standards of design. They should also when appropriate refer major projects for a national design review. In general, early engagement on design produces the greatest benefits. In assessing applications, local planning authorities should have regard to the recommendations from the design review panel. 63. In determining applications, great weight should be given to outstanding or innovative designs which help raise the standard of design more generally in the area. 64. Permission should be refused for development of poor design that fails to take the opportunities available for improving the character and quality of an area and the way it functions. 65. Local planning authorities should not refuse planning permission for buildings or infrastructure which promote high levels of sustainability because of concerns about incompatibility with an existing townscape, if those concerns have been mitigated by good design (unless the concern relates to a designated heritage asset and the impact would cause material harm to the asset or its setting which is not outweighed by the proposal s economic, social and environmental benefits).

15 66. Applicants will be expected to work closely with those directly affected by their proposals to evolve designs that take account of the views of the community. Proposals that can demonstrate this in developing the design of the new development should be looked on more favourably. Health 69. The planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities. Planning policies and decisions, in turn, should aim to achieve places which promote: opportunities for meetings between members of the community who might not otherwise come into contact with each other, including through mixed-use developments, strong neighbourhood centres and active street frontages which bring together those who work, live and play in the vicinity; safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion; and safe and accessible developments, containing clear and legible pedestrian routes, and high quality public space, which encourage the active and continual use of public areas.

16 Annex 3 Public Comments on the Taylor Review made by others The RTPI has said: Government should be clear what is government planning guidance, and what is not. The RTPI has consistently called for a (limited) government role in planning guidance and we would take this as being an implicit recognition that there should be some. The RTPI agrees guidance should provide essential information and exclude best practice. It should not repeat statutes and regulations. We called for this in 2011 and are pleased to see this recommended. There should be a web-based live resource hosted on a single site, accessed via links within the NPPF, kept under annual review and free of charge. We welcome this suggestion, and indeed there is a small precedent in the form of the Plan Making Manual hosted by the Planning Advisory Service. On charging we are concerned at the apparently increasing amount of planning data - even data pertinent to Parliamentary discussions - which is no longer collected by the public sector and which therefore is charged for. At least planning guidance should be exempted from this. The Taylor review was not charged with reviewing guidance badged by departments other than CLG (unless jointly badged), However the Taylor review sensibly suggests that the only government planning guidance to be afforded that title must be on the single website. We wholeheartedly support a recommendation that it should be the government's Chief Planner who manages a sign-off process for any guidance badged as government planning guidance, and therefore, we would hope, constitutes a material consideration in planning. The Taylor Review was tasked with considering the scope of the "planning sector" to produce appropriate guidance. The Review recommends that the guidance website could signpost best practice guidance produced outside government, stopping short of endorsing it. Many organisations are eager to produce advice on planning matters. There was a risk at one point that there could be a proliferation of (maybe even conflicting) "guidance". We are concerned that signposting to best practice risks being seen as a kind of low-level Government endorsement. The amount of time and effort CLG would need to commit to maintaining signposting and deciding which material merits sign posting should not be underestimated, and we would not wish to see resources unduly diverted from the more important task of updating Government guidance.

17 The Review contains four annexes covering guidance to be cancelled, revised, retained temporarily, and actually created afresh to respond to current conditions such as the NPPF. The RTPI sent a list to Greg Clark, former planning minister on behalf of six leading organisations in the sector in May. We are pleased to see some of that list appearing in the Taylor Review list such as flood risk, updating housing assessments (SHMAA and SHLAA) and creating viability guidance. The Taylor Review recommends an urgent consultation on the planning guidance question. We would welcome the opportunity to respond to a consultation on the work of the review. We continue to promote the very best in planning practice and look forward to continuing to work with other organisations to achieve this. The National Housing Federation said: Responding to Lord Taylor s review of planning guidance, assistant director Helen Williams said: Lord Taylor s planning guidance review comes at a timely and crucial moment, and his recommendations will enable England to have a simpler, speedier and more positive planning system. The scale of the existing guidance, much of which is out of date, is confusing for developers, local authorities and the public. Simplifying and putting it online together with examples of best practice will make it easier to find and understand and will save time. We support the panel s call to prioritise housing market and land assessments, and to update environmental guidance. This is critical in ensuring we get the homes we need, and not at the expense of the environment. We hope the conclusions reached by the panel are properly considered by the Government. A more efficient planning system can address our housing crisis by providing homes for people on all incomes, and boost the economy by creating jobs. Charted Institute Highways and Transportation said: CIHT welcomes the opportunity to respond to the recently released report by Lord Taylor of Goss Moor into the revision of Government Planning Practice Guidance. The report states that the system itself is no longer fit for purpose and recommends that guidance should be cut to that which is essential and clearly defined. The report goes on to suggest that much of the new and revised guidance should be sector led. The report also advises that in future Government Planning Practice Guidance should be a web-based

18 live resource, hosted on a single sit as a coherent up-to-date guidance suite. The guidance suite must also be actively managed to keep it current and that it would be valuable if it was subject to an annual review. CIHT welcome the recommendation to prepare new streamlined guidance to replace Good Practice Guidelines: Delivering Travel Plans through the Planning Process (2009) and Guidance on Transport Assessments (2007). However, we are concerned that it is unclear in the recommendations as to whether the existing guidance should be cancelled before new guidance is prepared. The Taylor review describes Manual for Streets (2007) as containing some good advice, but is not needed in its current format. It recommends that the manual is kept for now, but a review needs to take place to decide what is planning advice and what is outside planning and can be provided elsewhere. CIHT are concerned that the report fails to recognise the essential part that welldesigned streets play in the delivering of good places that meet the requirements of the NPPF. MfS addresses both planners and engineers and there is a danger that this would be lost in any redraft. Act Travel Wise has said: Notably the report states that there is no immediate need to keep either the Good Practice Guidelines: Delivering Travel Plans through the Planning Process (2009) or the Guidance on Transport Assessments (2007). Taylor recommends that they are withdrawn, but that relevant material be incorporated into revised guidance. It is unclear whether the existing advice will be cancelled before preparing new guidance. Taylor asserts that Manual for Streets (2007) contains some good advice, but is not needed in its current format. The report suggests that MoS is kept for now, but that a review be undertaken on what planning advice is, and what is considered outside planning and can be provided elsewhere. English Heritage has said: English Heritage (EH) has provided an important if preliminary and interim review of the potential implications of the Taylor Review on guidance used to manage England s heritage. In a note to the Historic Environment Forum (HEF), EH observes that some heritage-related documents will be cancelled by 28 March 2013, while other documents, including PPS5 Practice Guide and Circular 07/09 on the Protection of World Heritage Sites will be replaced, most likely by July 2013, and it is recommended that the PPS5 PG is withdrawn only once replacement guidance has been issued by sector, in order to support the NPPF.

19 English Heritage has offered the following as an initial evaluation: Key points Initial consultation runs until Friday 15 February The consultation is on the proposed lists of guidance to be deleted, the nature of the proposed preparation and the future management of planning-related guidance. It will inform the Government s path for preparing the new guidance. The goal is establishing a single, coherent and up-to-date suite of only essential guidance which is easily accessible on-line. Some heritage-related documents will be cancelled by 28 March Other documents, including PPS5 Practice Guide and Circular 07/09 on the Protection of World Heritage Sites will be replaced, most likely by July It is recommended that the PPS5 PG is withdrawn only once replacement guidance has been issued by sector, in order to support the NPPF. The Review seems to imply that the heritage text will be produced by HEF and not by Government and will thus be less definitive. HEF may wish to separate the current draft guidance into two parts with one part being included by Government in its web-based guidance, and the other more technical material being produced by HEF with EH assistance as a separate publication/web-resource. The position of future guidance from NDPBs such as EH and agencies is not clear. There does not appear to be a recommendation that EH guidance such as Enabling Development should not be produced, but the implication is that it will not have any formal Government endorsement and will stand or fall on the weight given by Planning Inspectors at appeal. Relevant extracts from the Report Conclusion bullet 2: guidance should support the application of local skills and judgement, not automate them. Guidance also has a crucial role in helping identify what information is required in different circumstance, to ensure proportionality and that decisions are appropriately informed without undue burdens being placed on applicants or the decision-taking process. Conclusion bullet 4: There is a role for Government Planning Practice Guidance in explaining complex regulatory and policy requirements. Para 2: The guidance should not be lengthy texts but prompts, essential information required or recommended processes. Para 8: Whatever material other departments wish to produce, Government is clear that it only formal Government Planning Practice Guidance once it is admitted to this website.

20 Para 9: The new guidance website should signpost organisations providing best practice guidance and other advice in relevant areas (e.g. links to heritage organisations associated with the National Planning Policy Framework section on heritage) but not endorse specific documents. Para 10: It will be necessary to create new material, drawing out (in consultation with practitioners) the vital elements from within the existing suite of guidance documents updating and formatting as appropriate to a web based resource, before decanting it on to the new site.we believe the aim should be to complete the great majority of this work by July 2013, subject to necessary, legislative and EU processes, etc. At that point all the existing guidance should have been, or be, cancelled. Para 12: The Government should. aim to complete the immediate cancellations, and work in progress on the preparation of the website and the most urgent updating of guidance by the first anniversary of the publication of the NPPF 28 March Para 13: After a rapid transition to such a radically new format we recommend there is a second formal consultation at the point the resource is alive, to identify any weaknesses or improvements, and ensure the guidance suite is then appropriate, coherent and up-to-date.