1D: Tourism and Planning
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This section gives a background to the planning system, as it may be encountered by destination managers. It covers:
- the planning framework
- sources of guidance, in particular the The Good Practice Guide on Planning for Tourism
- practical tips for successfully navigating the system.
There is a clear role for Destination Management Organisations (DMOs) in planning the process, through:
- helping local businesses with planning applications
- monitoring and making submissions to local development frameworks and regional planning strategies
- working with local planning authorities to promote the economic importance of the tourism industry.
The aim of this section is to provide some context to the planning system, and point to national planning guidance and The Good Practice Guide on Planning for Tourism which can help promote tourism in a local area.
The Department for Communities and Local Government (DCLG) is responsible for national planning policy. Its aim is to ensure that places and communities will be planned, built and managed in a way which sustains the global, national and local environments. Sustainability has become a key buzzword in the last few years, and promoting the sustainability of projects is a pre-requisite of a successful planning application.
The Planning Bill (due for Royal Assent in Winter 2008) aims to make the planning system simpler, faster and more accessible. The policy statement Sustainable Communities: Delivering through planning describes these aims in more detail. There has to be some doubt whether a policy aim of more community involvement and a system that is faster are compatible as objectives. This is particularly true for the leisure and tourism industry where fashions change and the nature of a "plan-led system" finds it difficult to cope with such a fast moving sector.
It is essential to understand the "plan-led system" under which all planning policy is made. The Planning, Building and the Environment pages of the DCLG website give further details.
Draft plans are produced by local planning authorities as "local development frameworks" and by regional assemblies as "regional spatial strategies".
- Local Development Frameworks (LDFs) determine how the planning system helps shape the community, and comprise a series of documents that are drafted, reviewed and revised over a period of approximately three years.
- Regional Spatial Strategies (RSSs) are prepared by regional planning bodies, except in London where the spatial development strategy is prepared by the Mayor of London. They set the broad planning context for their regions and how they should develop over the next 20 years.
Community involvement is a key policy for the Government. To complement LDFs, every local authority is required to produce a Statement of Community Involvement which gives details of how communities can contribute to, and participate in, the revision of planning documents and consideration of planning applications.
Unless the facility being proposed is seen to be in line with the LDF or RSS, local authorities have no option but to refer the application to a higher authority. This may well be only to the government office in the region, but it could be to the DCLG and may end up with a public inquiry. All this takes time and costs money.
The DCLG advises local authorities on its Local Plans and Regional Strategies through a series of Planning Policy Guidance notes (PPGs), which more recently have become Planning Policy Statements (PPSs).
These PPGs and PPSs have to be taken into account by local and regional authorities when preparing their application. They may also be a "material" consideration in decisions on individual planning applications. "Material" in this sense means that the local authority or planning inspectorate who deals with the appeals process has to take these policies into account when deciding if the application should be approved or turned down.
It is worth taking time to look at relevant PPSs or PPGs. On the whole they are not very long and are fairly easy to read, even for those who are not planning experts.
PPS1 gives details of the Government's objectives for the planning system. It covers:
- key principles
- social cohesion and inclusion
- protection and enhancement of the environment
- prudent use of national resources
- design and community involvement.
It is the lead PPS under which all other planning policy guidance statements and notes fall.
PPS6 covers planning in town centres, but does not only cover shops. PPS6 mentions specifically at paragraph 1.8 that certain forms of leisure are suitable uses for town centres. Their list shows "leisure, entertainment facilities, and the more intensive sport and recreation uses (including cinemas, restaurants, drive-through restaurants, bars and pubs, night-clubs, casinos, health and fitness centres, indoor bowling centres, and bingo halls)."
These types of proposals have to go through various tests encouraging them to develop in the town centre rather than on the edge, or out of town. The "sequential approach" requires developers or operators to prove that their proposals cannot be situated in an existing town centre. This is both costly and time consuming.
The problem for the tourism sector is that PPS6 is often used by local authorities to cover anything which is sport, leisure or tourism related. As an example, one of the DCMS-sponsored planning seminars in 2007 revealed a golf course which was forced to follow the "sequential test" in PPS6. The sequential test requires all developments to consider town centre sites first before they are able to consider sites on the edge of the town.
In this particular instance the developer eventually found a site "in town", but it was on the edge of a cliff so all the golf balls would have ended up in the sea! Reluctantly the local authority conceded and the original planning application for an edge of town site was approved.
The DCLG are in the process of producing guidance on both the sequential test and the new "impact test".
There is a real role for DMOs and others at a local level to encourage local authorities to consider sport, leisure and tourism applications under their relevant PPGs or PPSs.
PPS7 covers the Government's planning policy in rural areas includes a specific chapter on Tourism and Leisure which is worth reading. It also covers tourism accommodation.
PPG13 aims to integrate planning and transport policy at a national, regional and local level. It also seeks to encourage more sustainable transport choices.
Amongst its objectives is a desire to "promote accessibility to jobs, shopping leisure facilities and services by public transport, walking and cycling". This will require many applications for leisure and tourism facilities in town centres to have clear plans for how visitors will reach the new facilities and to work with local providers of public transport to see how this can work in practice.
The Good Practice Guide on Planning for Tourism does acknowledge that in some cases private car use will be necessary to access new developments, particularly in rural areas.
PPG17 is one of the older PPGs. It encourages local authorities to undertake audits of existing open space, sport and recreational facilities. Unfortunately few make these assessments which can be frustrating for private sector developers and operators.
At a time when tackling obesity is clearly important to Government policy, there is a real need for DCLG to take more steps to encourage positive planning for facilities which encourage physical activity. The recent Foresight Study on Obesity made it clear that communities where physical activity is encouraged are fitter and healthier and weigh less. As PPG17 is old, many local authorities try and use PPS6 as their guide to planning policy, to the detriment of facilities for open space, sport and recreation.
The Good Practice Guide on Planning for Tourism was published by DCLG in May 2006. It replaced PPG21 (Tourism) and already the industry has won several cases on appeal because the local authority did not take it into account when putting together their LDF or when refusing planning permission for a specific project.
Key elements of the Good Practice Guide are as follows.
- Regional and local planning authorities should have regard to this guidance when preparing their local development frameworks and regional spatial strategies and must recognise the diversity of tourism, which covers family holidays, but also shorter visits, weekend breaks and day trips.
- The guidance may be a "material consideration" in planning decisions.
- The guide adopts the World Tourism Organisation definition of tourism which makes it clear that tourism covers not only overseas and domestic tourists, but business tourists, day tourists and all who are away from home.
- The guide recognises the crucial importance of tourism to this country. It contributed 85.6 billion to GDP in 2006; is the UK's third largest foreign exchange earner after oil and vehicles; contributes circa 11.8 million to the national exchequer in terms of the tax paid by tourists on goods and services; and that every 1% increase in tourism revenue generates 118 million in revenue for the Government. 2.2 million people – 7.7% of the UK workforce – work in tourism.
- The guide addresses the promotion of more sustainable transport but recognises this may be particularly difficult for some types of tourism projects, or in areas that are poorly served by public transport, and that some developments (eg touring sites for caravans) are car dependent.
- Tourism can bring broader benefits by being made the focus of regeneration in urban and rural areas. It can offer social and economic benefits, bring derelict land and buildings back into use, and cater for visitors to historic buildings, archaeology and landscapes. In rural areas tourism businesses can be the mainstay of the local economy and provide valuable benefits for the local community through the provision of jobs and facilities.
- Specific annexes on tourism accommodation and seasonal and holiday occupancy conditions for holiday parks complement the current guidance in PPG21 (Tourism) and are hugely important to these sectors. The accommodation annex recognises the importance of budget hotel accommodation and the Holiday Occupancy Annex, and the importance of staff accommodation on holiday parks.
Take the time to read the Good Practice Guide to find out more.
With a clear understanding of how the planning system works, how can destination managers help local businesses put in better applications and assist local authorities with the preparation of their local plans within tourism
- Make an approach to your local authority planning department. If at all possible, visit and offer to help them understand the tourism industry better.
- Ensure your details are on their lists for planning circulars. This should ensure you know and are kept informed of the key dates for plan revisions, public inquiries, etc and can therefore warn local businesses that they need to make an input and raise any concerns that may exist about the direction the plan is taking. Making submissions to local planning inquires can be time consuming and difficult because there are so many procedures to follow. Working together as a local sectorial group may make this input easier and more effective.
- Meet or make contact with other local authority officers who are likely to be sympathetic to the development of sport, leisure, hospitality and tourism facilities. This may include directors of leisure or economic development, tourism officers and others whose responsibilities cover the cultural sphere. They can be used to support individual planning applications or to help identify barriers to a sympathetic hearing. They may also be interested in meeting with and understanding more about the tourism industry.
In helping individual tourism businesses to make planning applications the following advice may be useful.
In all the DCMS-sponsored seminars, planning officers stressed the need for businesses to ask for pre-application advice. Several went so far as to suggest that no plans should be worked up until they had an opportunity to discuss it with local planners. Local planning authorities have targets set by Government for hearing planning applications.
In most instances they are required to take a view on an application within eight weeks. If not enough information is provided, or there is a fundamental flaw in the application, they really have no choice but to reject it. It therefore makes sense to ask for advice before a submission is made. Eventually the applicant may decide that the advice they receive is not suitable, but the fact that they have asked for advice will go down well if recourse to an appeal is required.
There is a tendency to look at planning as being too difficult a challenge, and for the tourism industry to think they will always be turned down. A positive attitude, the right links and local engagement can bring about a totally different response and result.