FSB NI response to Consultation on Strategic Planning Policy Statement for Northern Ireland (Draft)

Transcription

1 FSB NI response to Consultation on Strategic Planning Policy Statement for Northern Ireland (Draft) April 2014

2 FSB response to the Consultation on the Strategic Planning Policy Statement for Northern Ireland (draft) Introduction With more than 7000 members from across every sector of enterprise and industry, the Federation of Small Businesses (FSB) is Northern Ireland s largest representative business organisation. The FSB s aim is to promote and protect the interests of all those who own or manage their own businesses, and to create a better business environment for the typical Northern Ireland business. Small businesses account for 98% of the private sector business environment and employ almost half a million people across Northern Ireland, contributing 60% of all private sector turnover. Therefore, FSB welcomes the commitment made within the Strategic Planning Policy Statement for Northern Ireland (hereinafter referred to as SPPS ) to unlock development potential, support job creation and aid economic recovery The FSB would initially welcome the objective of the SPPS to streamline 20 separate policy statements into one document as a means to provide a new approach to the preparation of regional planning. In condensing over twenty planning policies into one statement, this works to reduce the guidance on planning from around 800 pages to less than 100. While on a basic level that is a welcome step, the real question for us is around whether the new SPPS is more accessible for small businesses. Northern Ireland members of the FSB have frequently cited difficulties in navigating the planning process in a timely way. Conversely, when we speak to our colleagues in other areas of the United Kingdom, many of the processes involved in their planning systems are significantly quicker and more efficient. It is important that our new system matches the best performance amongst its peers. Two tier planning system With the introduction of a two tier planning system through the return of planning powers to local councils, FSB recognises and welcomes that there will be a greater onus placed on Local Development Plans.

3 As planning powers pass to the new councils, it is imperative that the process is smooth, clear, timely, and efficient and offers good value for money. It is equally important that there is consistency in the process both within councils and across all councils, so that we do not find some businesses in certain areas being hampered by partial or skewed interpretation of the policy. Overall, it is widely accepted that local government are best placed in terms of being responsible for planning, as in England and Wales for example. The FSB recognises that it is difficult for councils to deliver their services, particularly economic development, if they are not responsible for planning. The FSB however are concerned as to the implementation of the SPPS and the difficulties that would arise should the current multiple policy statements operate alongside the SPPS until the development of Local Development Plans (LDP) by the new councils, which have been allocated a completion date of a minimum 40 months. The SPPS will go live on 1 April 2015, and the document states that transitional arrangement will remain in the short to medium term. On follow up questioning, it was said this time period would be fluid. However, there is estimation from DoE that it will take 20 months for Councils to formulate a first stage or draft LDP and a further 20 months to produce a final LDP. Consequently, this would result in at least a three year transitional period, during which time planning decisions will continue to be made regardless of the draft LDP. The existence of the SPPS alongside a large number of the PPSs already in operation seeks to defeat the original and overarching purpose of the draft SPPS. Additionally this will create further complication and red tape amongst applicants wishing to expand their businesses and in doing so positively contribute to the local economy and its growth. The FSB would in particular highlight concern on the judicial review of decisions whilst a dual framework is in operation is of real concern. Furthermore, the FSB would contend that there is certainly merit in a complete divorce from the previous planning policies from 1 April Coupled with the transitional arrangements for Northern Ireland, there is a need for greater clarity to be set out within SPPS as to the two-tier system alongside the transitional arrangements in regards to implementation of the SPPS alongside the establishment of the new local council structure from April The FSB would therefore argue that the SPPS be made more prescriptive, meaning that transitional arrangements would be less subjected to a dual framework.

4 Community Planning Clause 70 of the Local Government Bill establishes a statutory duty upon councils to establish a community partnership to inform their community planning role. In order to ensure that community planning effectively develops and implements a shared vision for promoting the social and economic well-being of the local government area, there is a need that small businesses be recognised for their integral role within the community. The FSB would therefore recommend that the 11 new councils in developing their Statement of Community Involvement (SCI) would ensure that one or more business representatives be included within the membership, and from the outset in creating the Local Development Plans (LDPs) for the area. In addition to this, we would also highlight the importance of the new councils putting in place their community plans as soon as possible, to ensure maximum time in which to engage with local stakeholders as to the future development of their local area. The Town Centres First Approach Whilst FSB recognises the need to rejuvenate our town centres, it is also recognised that new planning legislation could be detrimental upon our existing rural industries. The draft SPPS states that: councils or the Department must adopt a town centre first approach in the consideration of applications for retail or main town centre uses. A sequential test should be applied to planning applications for main town centre uses that are not in an existing centre and are not in accordance with an up-to-date Local Development Plan (LDP). Where it is established that an alternative sequentially preferable site or sites exist, an application which proposes development on a less sequentially preferred site should be refused. The Town Centres First Approach is new policy and not a straightforward one for small businesses. Whilst on one hand the policy is welcomed by retailers and small businesses operating within town centres, many of our members are positioned in the supply chain to bigger out of town developments. Out of town developments can be crucial for economic development and small businesses often benefit further down the supply chain, particularly in the hard pressed construction industry, which it has been reported has suffered an 8% decline this month (April 2014). Therefore a balanced approach is needed.

5 In paragraph 6.80 of the draft SPPS it is stated that for larger settlements, proposals will be determined on their individual merits. The FSB would recommend that there be clarity as to having a town centre first approach alongside consideration of each case on the basis of economic merit. The FSB would recommend that there is a need for such existing centres to be able to expand and regenerate however there is neither reference to this in the SPPS nor specific references to existing developments such as Sprucefield and Junction One. Additionally, the FSB would highlight as with planning legislation amongst local government in England that the new councils would seek to positively identify and assist opportunities to meet the economic development needs of their area, within both the rural and urban contexts. Another issue that the FSB would highlight is the weight given to sustainable economic development. For example, how under the SPPS will a decision be made on the strength of the economic importance of an out of town development in relation to the related potential economic detriment to a town centre? The SPPS as currently drafted does little to address how a decision will be made in such a case and we would therefore call for greater clarity around this. Renewable energy A proportionate number of FSB members, who have sought to utlise renewable energy within their small business, have encountered difficulties connecting to the energy supply, due to problems presented in the current planning process. There have been concerns expressed by our members regarding timing of planning permission for sequential developments. For instance, business owners who have sought to connect wind turbines to the main electricity grid in Northern Ireland, have to gain initial planning permission for the wind turbine and only then can make application for connection to the main grid. There is then the danger that this is not possible or the cost for connection has increased, thus creating a large amount of paperwork, time, advice and cost. Therefore the FSB would invite the Department to meet with FSB members impacted by this to discuss the needs around integrating renewable energy technology within new and existing developments. In addition such a meeting would serve the Department in providing them with a fuller understanding of the difficulties being faced by small businesses that are being penalised for their desire to utlise renewable energy.

6 Sustainable Development The draft SPPS sets out that the emphasis on sustainable development within the strategy is equally weighted and neutral in regards to the three areas of; social, environmental and economic. The draft SPPS references furthering sustainable development, which we would request greater clarity on, in regards to what currently is sustainable development as set out under the document. The draft SPPS sets out that the economy, society nor environment be elevated in consideration to the others. The FSB recognises the need for environmental and social considerations to be prioritised within planning decisions, however would stress that Northern Ireland is currently in a position in which it is lagging behind other parts of the UK in terms of economic recovery. We would therefore stress that there is a need to place emphasis on the importance of the planning system in facilitating economic recovery within Northern Ireland to ensure not only recovery but increased economic activity amongst the population, such as by way of jobs creation. As the leading business organisation in Northern Ireland, the FSB stresses that economy be the golden thread running throughout the document. The economy is the number one priority of the current Programme for Government after all and this approach would remove some of the current ambiguity within the SPPS. Development Management The hierarchy of development is outlined under the section Development Management within the draft SPPS. This section advances that regionally significant development will be decided upon by the Department of Environment (DoE) whilst local development will fall within the remit of local councils, which it is stated, will also make the vast majority of all planning decisions. The FSB would contend that there is a need for greater clarity as applying these classifications to planning applications. We recognise that this may be a particular area in which there will be a challenge to consistency in planning decisions across Northern Ireland. For instance, planning applications could be presented in a way to either emphasise or conceal regional significance of an application leading to similar applications being considered by both local councils and the Department.

7 Infrastructure The FSB note that there is no specific provision within the SPPS on regionally significant infrastructure projects within the SPPS. These are necessary in attracting both foreign direct investment (FDI) and tourists to Northern Ireland. With the Dublin Airport Authority recording an 11% increase in NI customers flying directly from Dublin onward, in April 2014, it underlines the need for serious consideration around expansion of our current road, rail and air infrastructure. This however is omitted within the SPPS. Conclusion The FSB once again welcomes the opportunity to respond to this review however is concerned around the lack of priority attached to economic importance of planning proposals. We would like to therefore take this opportunity to reiterate the recommendations that we have made therein, including: The FSB would urge consideration by the Department in ensuring that the SPPS is utilised as one central document for all planning statements and policy within Northern Ireland ahead of the reform of local government powers set to take effect from April The FSB urge that the Minister and his Department consider the impact that out of town developments have upon small businesses within the supply chain, whose primary consumers are the larger retailers. Deterring such developments would have a detrimental impact upon these businesses who provide services and products to chains and developments, including the construction industry. The FSB invites the Department to meet with relevant FSB members to discuss the needs around integrating renewable energy technology within new and existing developments. The FSB recommends that there be consistency in the process both within councils and across all councils, so that we do not find some businesses in certain areas being hampered by partial or skewed interpretation of the policy.

8 The FSB recommends the addition of specific provision within the SPPS on regionally significant infrastructure projects in terms of travel to and within the Province. The FSB stresses the need for the SPPS to place emphasis on the importance of the planning system in facilitating economic recovery within Northern Ireland to ensure not only recovery but increased economic activity amongst the population, such as by way of jobs creation. The FSB would welcome engagement with the Department in relation to SPPS and in particular would welcome the opportunity to participate within discussions under the Preferred Options Paper referenced therein.