Development plan amendment regulations: consultation

There needs to be guidance on what a ‘significant’ alteration would be, and what level of consultation or parliamentary process would be expected for government to make such changes. It would be helpful to discuss examples. For instance; adding a new national development, amending a policy, adding a new policy. Each of these examples would likely have different definitions for significant. Guidance should look at the impact of changes as part of a consideration of whether a change is significant.

We agree that there should be flexibility to make such changes without triggering a full review, but we would like to ensure that Government does not have carte blanche to change much-debated policies without an expectation of due process.

We suggest an additional element to account for cumulative change. For example, if Government were to change half or more of national planning policies ‘within a 12-month period’. This would prevent a situation where Government amends slightly fewer than half of the policies one month, then slightly fewer than half in a subsequent month.

We would welcome explicit reference to expert independent stakeholders bodies, as we do not think that it is reasonable to suggest that these stakeholders are in the same category as the 'public at large'.

Sufficient time and resource must be given to ensure that key stakeholders are consulted on material changes to national planning policies.

It is important to ensure that the NPF, which is subject to public scrutiny in its full review, cannot be altered in potentially significant ways without proportionate scrutiny of any changes.

We support the 12 week standard for consultation for any material policy changes. We recognise that non-material changes may not require a full 12 week consultation, but it would be more appropriate to set out circumstances in which a shorter consultation may be appropriate, rather than a blanket minimum which could be more easily abused.