Tourism and Planning. Part 1: The Planning System

by Brian Human and Peter Sharp
Mar 2010
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Summary

The planning system has a significant impact on the tourism sector’s ability to grow in response to future demand, and to protect the natural and historic assets on which the industry is based. A tension exists between having a planning system that is flexible, so as to provide adequate opportunities for growth, and one that is strong enough to prevent inappropriate development that would limit tourism potential.

This article is divided into two parts. Part One gives an overview of planning policy and management and how this affects the tourism industry.

Part Two will examine the most recent changes, Planning Policy Statement 4 (PPS 4): Planning for Sustainable Economic Growth, and the effect this has on tourism development. It will also illustrate how and why the industry can and should be involved in the planning system to enable tourism growth.

Set up to control the development and use of land in the public interest, England has had a comprehensive, statutory land use planning system for over 60 years. Over time legislation has expanded its remit to embrace a wider range of social, economic, environmental, infrastructure and, most recently, sustainability issues (see the Mar 2010 Tourism Insights article Commissioning Green Buildings in Tourism – Legislation Changes and Beyond).

The fundamental purposes of planning are set out in legislation, specifically the Planning and Compulsory Purchase Act 2004 and the Planning Act 2008. The planning system broadly operates in two interconnected areas: policy planning and development management (traditionally known as development control).

Whilst there are many examples where the planning system has been over-sensitive or archaic for today’s dynamic leisure and tourism industry, it has long been recognised that there is a need for development to be sustainable and appropriate to place and the surrounding communities. The recent introduction of Planning Policy Statement 4 sets out measures that can assist both tourism operators and local authorities in planning for tourism growth and tourism-led development.

Planning policy is set out at three levels: national, regional and local. In operational terms the levels are hierarchical; national policy guides regional policy, which in turn guides local policy with a requirement for consistency between the levels.

National policy is principally set by Planning Policy Statements (PPS) and Planning Policy Guidance (PPG). There are currently 21 PPS/PPG in operation. These cover a wide range of issues and many contain aspects of policy that affect tourism. For those involved in planning for tourism the following are most relevant.

  • PPS 1: Delivering Sustainable Communities 2005
  • PPG2: Green Belts 1995
  • PPS4: Planning for Sustainable Economic Growth 2009
  • PPS9: Biodiversity and Geological Conservation 2005
  • PPS11: Regional Spatial Strategies 2004
  • PPS12: Local Spatial Planning 2008
  • PPG13: Transport 2001
  • PPG15: Planning and the Historic Environment 1994
  • PPS17: Planning for Open Space, Sport and Recreation 2002
  • PPG20: Coastal Planning 1992
  • PPG25: Development and Flooding Risk 2006

Supplements have also been published to accompany several of the Planning Policy Statements. These elaborate on policy in more detail.

Regional planning policy covers nine regions in England. Each has a Regional Spatial Strategy (RSS) prepared by the appropriate Regional Planning Body [1]. The RSS provides a spatial framework to guide regional, sub-regional and local strategies and programmes that have a bearing on land use activities. It should provide a broad development strategy for the region for 15 to 20 years.

An RSS takes into account matters such as housing need, priorities for the environment, economic development, transport and other infrastructure needs. This is set out in detail in PPS11, which includes guidance on what tourism issues should be taken into account, eg Tomorrow’s Tourism (1999).

Example 1 shows how the East of England Plan has approached tourism policy.

East of England Plan, Tourism Policies (extracts)

Policy E6: Tourism

Local development documents should:

  • include policies to encourage realistic and sustainable investment in the maintenance, improvement, regeneration, extension and diversification of the region’s tourist industry;
  • recognise that much tourism potential is based upon the presence of specific local features or assets eg the coast and the historic cities of Cambridge and Norwich. Proposals for tourism development should be fully sustainable in terms of their impacts on host communities, local distinctiveness and natural and built environments, including by avoiding adverse impact on sites of national, European or international importance for wildlife; and
  • integrate with other plans and strategies for managing tourism, particularly local and regional tourism strategies and visitor management plans, especially those for regenerating seaside resorts and extending employment outside the traditional tourist season.

Policy C2: Provision and location of strategic cultural facilities

Regionally or nationally significant leisure, sport, recreation, arts, tourism or other cultural facilities should be supported in locations where proposals:

  • will enhance existing facilities of regional or national significance or, elsewhere, reflect a sequential approach with priority to locations in town centres before off-centre or out-of-town locations, and to the use of brownfield land in preference to greenfield sites [...]

Policy HG1: Strategy for the sub-region

The sub-regional strategy aims to achieve transformational development and change throughout Haven Gateway which will:

  • develop the diverse economy of the sub-region, including provision for the needs of an expanding tourism sector, support for the establishment and expansion of ICT clusters and recognition of the potential and need for employment growth in the smaller towns [...]

Policy GYL1: Great Yarmouth and Lowestoft Key Centres for Development and Change

The strategy for Great Yarmouth and Lowestoft is to promote the comprehensive regeneration of the two towns, capitalising on their strengths and protecting and enhancing their environmental assets. Local development documents and other strategies should pursue this strategy by:

  • promoting radical change in the economy building on the area’s established sectors and diversifying into new and emerging sectors including:

    – a more diverse tourism cluster, based on the resort and leisure role of the towns, the proposal for a casino at Great Yarmouth and proximity to the Broads [...]

East of England Plan, Communities and Local Government 2008

Local planning authorities are required to prepare a Local Development Framework (LDF) under the Planning and Compulsory Purchase Act 2004. An LDF sets out development proposals and policies for the local authorities area. Key elements and examples of how they might tackle tourism include the following.

  • Core strategy – sets out a vision, the strategic objectives, a delivery strategy, and proposals for management and monitoring development, eg support for tourism development as part of an economic development strategy.
  • Site specific allocations – significant sites allocated for development, eg allocated sites for hotels.
  • Proposals map – identifies protected areas, flood risk areas and allocated development sites, eg designated sites for tourism development.
  • Area action plans – a planning framework for areas of significant change, eg integration of tourism facilities in a transport interchange.
  • Supplementary planning documents – provide greater detail on development plan policies, eg guidance on the development of tourism on farms.
  • Annual monitoring report – an overview of progress in implementing the plans.

Example 2 shows how the Colchester Borough Core Strategy has addressed tourism. Example 3 shows how Bridgenorth District Council has addressed farm-based tourism through the Claverley Parish Plan Supplementary Planning Document.

Colchester Core Strategy (extracts)

Urban renaissance

The Core Strategy seeks to maximise the potential of the existing regeneration areas and stimulate a broader urban renaissance throughout the town centre. To help deliver this urban renaissance tourism will be supported and promoted [...]

Environment and rural communities

The natural and historic environment, countryside and coastline will be conserved to protect the Borough’s diverse history, archaeology, geology, and biodiversity [...] Tourism that is appropriate to the local environment and context will be supported and promoted.

Colchester’s town centre needs to accommodate more business, tourism and retail developments [...] The town centre will also be the primary location for the delivery of 270-490 hotel bedrooms between 2006 and 2011, and additional hotel developments beyond this period [...] This development will be primarily focused on the town centre, and other highly accessible locations, to create a sustainable and prestigious regional centre.

West Mersea, with a population of 6,925 in 2001, is a relatively self-contained coastal community offering quality tourism and recreation opportunities. The West Mersea waterfront will be conserved for its historic maritime character and distinctive maritime-related local businesses.

Policy ENV2 Rural Communities

Outside village boundaries, the council will favourably consider small-scale rural business, leisure and tourism schemes that are appropriate to local employment needs, minimise negative environmental impacts, and harmonise with the local character and surrounding natural environment.

Colchester Borough Council, Adopted Core Strategy, October 2008

Claverley Parish Plan Supplementary Planning Document (extracts)

Local guideline

Proposals to introduce tourism activities or accommodation on farms will be permitted provided that:

(a) their introduction does not place undue pressure on the limited infrastructure of the parish,

(b) any proposed tourist accommodation is supported by adequate car parking provision,

(c) the activities proposed are considered acceptable in limiting environmental impact on the parish, and

(d) the overall business case brings benefits to the parish as a whole.

Justification

6.1 The parish of Claverley attracts significant numbers of visitors every year. This puts considerable pressure on the parish infrastructure. Not only are there restrictions as a result of the narrow country lanes and parking, but there are also very limited facilities for accommodating visitors overnight in the parish. Any significant expansion of tourism activities would be problematic unless these issues are addressed.

6.2 There is potential for a variety of tourist accommodation and activities including guided and non-guided walks, fishing, photography/painting or equestrian. Supporting such activities would improve the economic viability of the parish and support local employment, provided that supply of these activities benefits the parish as a whole.

Local guideline

Where it can be demonstrated that buildings are unsuitable for conversion to employment, tourism or sport and recreation use, their conversion to domestic use will be permitted providing:

(a) they are of substantial stone or brick construction capable of conversion without major reconstruction and

(b) the scheme has minimal visual impact on the local environment and conforms to Local Plan Policy

Bridgnorth District Council Adopted June 2007

Infrastructure development is also covered by the planning system. The Planning Act 2008 established a new, independent body, the Infrastructure Planning Commission (IPC), to be responsible for considering and making decisions on significant infrastructure planning applications.

The IPC remit covers infrastructure of relevance to tourism such as ports, airports and road and rail networks. The Government is in the process of rolling out National Policy Statements (NPS) covering these matters. Where a relevant NPS is in place, the IPC takes the decision on planning applications. If the relevant NPS has yet to be designated, the IPC will instead report with a recommendation to ministers.

Proposed developments need to meet criteria set out in the relevant Local Development Framework. This process is managed through a planning application with the relevant local authority. Generally all but the most minor developments will need to apply for planning permission.

At its simplest an outline application may be made to establish the principle of the proposal, or a full application made which covers both the principle and the details. Depending on the nature and scale of the development, additional information, eg an Environmental Statement and a Design and Access Statement, must accompany the application.

Typically the process through which the application will go includes the following.

  1. Submission of the application to the local authority.
  2. Consultation with interested parties, eg the highway authority, and the public.
  3. Consideration of the responses to the consultation and evaluation of the proposals against planning policy.
  4. Discussions and negotiation with the applicant.
  5. Report to the decision makers, most often a Council committee for larger applications.
  6. A decision is issued, usually subject to conditions.
  7. If consent is given the development may go ahead.
  8. If consent is refused the applicant may appeal to the Secretary of State.
This is a very simplified version and major proposals may undergo several rounds of submission, discussion, revision, consultation and negotiation.

Ideally, a development with a tick in all the boxes will receive planning permission. Where this does not happen a balanced decision must be taken. Consent may still be given where the problem areas are relatively minor and may be overcome, eg by attaching conditions to the development. In the event of fundamental problems, for example, where the building is inappropriate to the site or there are insuperable traffic problems, the weight of argument may go against the development.

When consent is given it may be subject to an agreement between the developer and the planning authority under which the developer pays for related works, without which planning permission could not be granted. These are now commonly referred to as S106 agreements.

Their main purpose is to provide the mechanisms to secure the provision of new infrastructure or improvements to existing infrastructure, and measures to mitigate the adverse impacts of development. The types of infrastructure requirements covered by the local authority's requirements might include open space, transport, public art and public realm improvements.

The Government is also in the process of introducing a Community Infrastructure Levy (CIL) under the 2008 Planning Act. This is a flexible hypothecated local levy which local authorities can choose to introduce to fund infrastructure in their areas. CIL will be charged on most types of development, but will not fully replace S106 requirements. It is viewed as a valuable top-up for local communities wishing to see additional facilities in their area, such as roads, public transport or open space. Local authorities can choose the CIL rate that they want to apply, but must set this out in a new legal document, which is independently examined, to ensure that it is evidence-based and appropriate for the area.

Example 4 gives an example of how S106 requirements might affect tourism development, and the contributions required of the developer.

Cambridge S106 Contributions (extracts)

DevelopmentS106 [Developer's Requirements]
Major developments comprising employment or services (2500m2 gross floorspace or above), leisure (100m2 gross floorspace or above or 1500 seats)Preparation of comprehensive travel plan
Non-residential developments comprising 500m2 or more including extensions to existing uses (gross)Improve the surrounding Public Realm: £4,000 per 100m2
Hotel comprising 100m2 or moreImproving Community Safety in the area: £4,000 per 100m2
All major applicationsProviding Public Art: 1% of the total capital construction cost of the development
Cambridge Draft Planning Obligations Strategy, 2007

Tourism is affected by planning policy at national and local level, and it is important to be aware of how this can affect proposed developments. Anyone considering carrying out a tourism-related development is advised to seek the advice of consultants, such as an architect or planning consultant, and ask them to conduct pre-application discussions with the relevant planning authority to ensure that proposals are in line with their policies.

Tourism also exerts major influences on the places for which local authorities are the responsible planning bodies. Authorities, therefore, must also respond to the pressures of tourism. The planning process can encourage positive management and appropriate development, or, if done badly, it can frustrate the achievement of social, economic and environmental benefits.

It is naive to suggest that the relationships between local authorities and the industry are always harmonious at the planning interface. However, it is important that they aim to be so, especially as planning has a vital role to play in promoting more sustainable approaches to tourism. Part Two of this article examines ways in which this can be achieved.

  1. Regional planning and economic development functions will be merged in 2010 and a single economic and spatial planning strategy will be prepared.

Planning Policy Statement 1: Delivering Sustainable Development, Office of the Deputy Prime Minister, 2005

Planning Policy Guidance 2: Green Belts, Office of the Deputy Prime Minister, January 1995 (Amended March 2001)

Planning Policy Statement 4: Planning for Sustainable Economic Growth, Communities and Local Government, 2009

Planning Policy Statement 9: Biodiversity and Geological Conservation, Office of the Deputy Prime Minister, 2005

Planning Policy Statement 11: Regional Spatial Strategies, Office of the Deputy Prime Minister, 2004

Planning Policy Statement 12: Local spatial Planning, Communities and Local government 2008

Planning Policy Guidance Note 13: Transport, Department of the Environment Transport and the Regions, 2001

Planning Policy Guidance 15: Planning and the Historic Environment, Department of the Environment, Department of National heritage, 1994

Planning Policy Guidance 17: Planning for Open Space, Sport and Recreation, Office of the deputy Prime Minister, 2002

Planning Policy Guidance 20: Coastal Planning, Department of the Environment 1992

Planning Policy Statement 25: Development and Flood Risk, Communities and Flood Risk, 2006

Good Practice Guide on Planning for Tourism, Communities and Local Government, 2006.

Brian Human has worked in urban and environmental planning in England for over 30 years. Until 2008 he was Head of Policy and Projects at Cambridge City Council, leading a multidisciplinary team dealing with planning, conservation, transport, urban design and sustainability issues. He is now an independent consultant taking an interdisciplinary approach to urban planning issues. During his career, Brian has built up a strong interest and knowledge in tourism planning and destination management. He was Chair of the Historic Towns Forum in 2006-2008 and is currently Vice Chair – the Forum promotes best practice and interdisciplinary working in historic towns and cities. Brian is also a Fellow of the Tourism Society.

Peter Sharp is a Senior Consultant at Humberts Leisure. After graduating in Tourism and Planning from the University of Westminster, he worked in the financial services and construction industries for a number of years prior to joining Humberts Leisure in 2004. Peter has worked with clients including regional development agencies and local authorities, major private landowners to small businesses and local entrepreneurs. He specialises in preparing detailed feasibility studies, business plans, need assessments, site options appraisal and economic impact across the leisure and tourism spectrum. Peter has recently completed a post-graduate certificate in Local and Regional Economic Development.