The Government's 'Technical Consultation on Planning' (https://www.gov.uk/government/consultations/technical-consultation-on-planning) closes on Friday 26th September. It's a 98-page long document that, by its title and length, is likely to discourage people from reading it and responding. I almost gave it a miss until I heard a whisper that it contained something important about parking standards. So I looked it up and dug down, way down. What I found, unheralded, unevidenced, and horribly out of place, was the following question (Q 2.16): "Do you agree that parking policy should be strengthened to tackle on-street parking problems by restricting powers to set maximum parking standards?" You can respond on this or any other part of the consultation by visiting SurveyMonkey link: https://www.surveymonkey.com/s/JKMX63K. I don't just think that this is an unjustified, misleading and prejudicial question, however. I consider that the treatment of the matter of maximum parking standards within this consultation clearly contravenes the Government's own Consultation Principles (https://www.gov.uk/government/publications/consultation-principles-guidance). On the off chance that you're interested, I reproduce below the email I wrote to the Department for Communities and Local Government containing my grounds for this assertion.
Technical Consultation on Planning - conformity with Consultation Principles
Tue, 23 Sep 2014 17:19:45 +0100
I am writing to register my concern that the current Technical Consultation on Planning (TCoP) does not conform with the Government's published Consultation Principles.
In doing so, I am referring to the section relating to Maximum Parking Standards: paragraphs 2.77 and 2.78 and Question 2.16 on page 34.
The wording of this part of the TCoP is extremely confused, and therefore confusing. Paragraph 2.77 states that "Parking standards are now matters for local authorities"; but then paragraph 2.78 immediately goes on vaguely to express the Government's concern about impacts that may arise from local authorities setting maximum standards as they see fit; and then Question 2.16 abruptly asks consultees if local authorities' powers to set such standards should be restricted. Before proceeding, I consider Question 2.16's use of the word "strengthened" to be both misleading and highly prejudicial.
More importantly, the TCoP leaps from 'Localism' to central control in two quick, and unjustified moves. I say 'unjustified' not because there is no justification (there may be), but because none is given. This contravenes the Consultation Principle that "every effort should be made to make available the Government’s evidence base at an early stage to enable contestability and challenge". Especially when it concerns a matter having such potentially far-reaching implications, both for wise planning and for local democracy, it is surely unacceptable for there to be no reference to any evidence base underpinning Question 2.16.
I'm afraid it is very hard to escape the view that this particular proposal is not motivated by evidence, or wisdom, but that it is a reflection of a doctrinaire position. In a press release dated 26th August, which post-dates the publication of the TCoP by almost a month, the Secretary of State for Communities and Local Government makes plain(again without providing evidence) that he considers maximum parking standards to be "arbitrary" and that he wishes to "rein back in" local authorities' power in this regard. What is more, Mr Pickles makes plain that his concern with maximum parking standards relates to residential development whereas, in the TCoP, restricting the application of such standards is presented as somehow "supporting a mixed and vibrant high street". Bearing in mind that the press release from Brandon Lewis dated 31st July, at the launch of the TCoP, made no reference whatsoever to parking, the contents of paragraphs 2.77-2.78 and Question 2.16 appear in the TCoP as not only ill thought through but completely out of context. One might even surmise that they were suddenly dropped in at the last moment, for some reason or other.
Taking all the above into consideration, and referring solely to the section on Maximum Parking Standards, I consider that there has been meaningful no attempt at "achieving real engagement rather than merely following bureaucratic process" and that this has not adhered to"principles of open policy making". Furthermore, I do not think that, on this topic, there has been any attempt to engage in "real discussion with affected parties and experts" or to get "those who know most and care most about a particular issue to engage in fruitful dialogue".
There is no indication that a review of the very important matter of parking standards is under consideration in any materials associated with the TCoP, nor indeed in the Introduction to the TCoP on page 5 or the Scope of Section 2 on page 18. Instead, the Maximum Parking Standards section appears unannounced and buried under the following headings:
- Section 2: Reducing planning regulations to support housing, high streets and growth
- Part 2: Consultation proposals
- Supporting a mixed and vibrant high street
- Proposal H: Expanded facilities for existing retailers
- Maximum parking standards
Given that, as worded in the TCoP and as later indicated by Mr Pickles' 26th August press release, the proposals on maximum standards have nothing to do with 'expanding facilities for existing retailers', this part of the TCoP also contravenes the Consultation Principle about"being clear about the areas of policy on which views are sought will increase the usefulness of responses". It is therefore most unlikely that it will "ensure that the consultation captures the full range of stakeholders affected".
I would be very keen to hear your response to my concerns.