Official Report: Minutes of Evidence

The Chairperson (Mr Maskey): We have a briefing this morning from Juno Planning & Environmental Ltd. We have the following representatives from Juno Planning: Helen Harrison, Andrew Heasley and Orlaith Kirk. I formally welcome the three of you here this morning. Thank you for your submission and your attendance and for assisting the Committee in its deliberation of the Bill that we are dealing with this morning. Without further ado, if you are happy enough, you can make your presentation to the members, and then we will take questions.

Ms Helen Harrison (Juno Planning): First of all, thank you for inviting us to participate in this session discussing the Regeneration Bill. We have prepared a short presentation, which summarises our submission and, more particularly, the context for our submission, with particular reference to the statutory documents that we have talked about, namely, the local development plan under the provisions of the Planning Act (Northern Ireland) 2011 and the community plan under the provisions of the Local Government Act (Northern Ireland) 2014. If the Committee is agreeable, we will provide a quick summary background of those two documents, because they really provide the context of our submission in relation to the Regeneration Bill.

In terms of local development plans, the Planning Act 2011 transfers responsibility for planning powers to local councils, and that includes the preparation of development plans. That establishes a plan-led system whereby the determination of planning applications is referred directly to the development plan and policies therein. The purpose of that plan is to guide future land use to those areas that have been designated for particular uses and, importantly, to inform investors, developers, members of the public, community and government public bodies and the wider representative organisations of the framework that will be used for decision-making within those council areas. It will also be a tool for translating down to a local level wider government policies on land-use planning.

In the preparation of local development plans, the councils have to take account of the regional development strategy, the single planning policy statement and other documents as they are referred to in guidance by DOE; for example, neighbourhood plans and regeneration plans. The local development plan itself comprises two stages. There is the plan strategy, which is formulated, goes through a public consultation process and has strategic objectives. Those are then taken up through the local policies plan, which seeks to identify actions for delivering those objectives. The policies are subject to public consultation at a number of stages, and there is a statutory requirement for councils to prepare and monitor local development plans on an annual and five-yearly basis.

The stakeholder engagement process in local development plans is critical. It is one of the new areas of the legislation. Councils must publish a statement of community involvement (SCI) that sets out their policy for involving interested parties in the preparation of the plan. Councils, interestingly, have to attempt to agree the terms of the SCI with the Department. Coming out of that is the preferred options paper that sets out the pattern of new development through the council area, the options for the growth of main settlements and options for major infrastructure. The timescale for that — I am sure that the Committee has looked at this previously — is not set. However, the single planning policy statement suggests an indicative time frame of 40 months, which is three years and four months, for the preparation of local development plans. We see them as being critical to the development that takes place in the council areas.

The second type of document that we refer to is the community plans. They are prepared under the provisions of Part 10 of the Local Government Act (Northern Ireland) 2014. DOE advice on community planning is that it will provide a framework within which councils, Departments, statutory bodies and other relevant agencies and sectors will work together to develop and implement a shared vision for promoting economic, social and environmental well-being based on effective engagement with the community. In simple terms, the information contained in the community plan is intended to include the plan objectives that the council considers appropriate, following consensus through the community consultation process, and the actions to be performed to deliver those objectives. Section 68 of the legislation requires that a community plan must be produced as soon as is reasonably practicable after the community planning process has been undertaken.

This is a new area for all councils in Northern Ireland; indeed, for councils across the UK and the island of Ireland. Community planning is new for everyone. In that context, DOE issued a community planning foundation programme in October 2013, which provided non-statutory guidance to councils on the preparations that they could make for preparing community plans. It actually provided tailor-made capacity-building support to council officers in preparation for them preparing community plans. You may be aware that DOE has recently published the draft statutory guidance on the operation of community planning, with submissions closing recently, on 9 March. The time frame for the community plans, again, is not set, but draft guidance indicates that they should be published within one year of the commencement of the community planning duty, which would be one year from the commencement of the transfer of powers, as we would see it.

The reason we have referred to both of those documents is that we believe that they have an important relationship to the development schemes that are listed as being part of the Regeneration Bill. In our evidence, initially we suggested that there should be a stronger relationship, particularly between the development schemes and the development plans. We note that, under the heading "Development schemes of councils", clause 5(4) of the Regeneration Bill requires that councils should have regard to the regional development strategy and the current community plan, but no reference is made at that point to local development plans. In effect, we feel that there should be an additional paragraph (c), which would mean that, in preparing development schemes, the councils should also have regard to the local development plan under the meaning of the Planning Act 2011.

The context for that, briefly — I am almost finished — is that development schemes are such an important tool that councils will have in order to take forward development that we believe that it is important that they have regard to the wider development plans for the area. We would particularly use the words "have regard to" rather than "take account of" or "must be in compliance with", because that means that there is an element of flexibility. You have to have regard to them, but you do not necessarily have to slavishly follow them. There may be good reasons not to do that; for example, if the local development plan is out of date — indeed, all but one of the existing development plans in place will be out of date by the end of 2015 — or it may be that the development that is the subject of the development scheme is contrary to the development plan but is of such public interest for other reasons that it may need to go ahead anyway.

There are provisions in the Planning Act 2011, at section 14(2), that allow councils to make revisions to local development plans. That would be in the instance where a development scheme is not foreseen or accounted for in the development plan, and a change would need to be made to the development plan to take account of it.

As a final point, we note that councils will have the powers to take forward development schemes and that the Department will also retain powers to take forward development schemes. We suggest that, by the same token, when the Department is taking forward a development scheme, it too should have regard to community plans, which the council is required to have regard to, but which the Department, under legislation, is not. Similarly, the Department should have regard to local development plans under the meaning of the Planning Act 2011.

Those are the main points that we picked out for our presentation this morning. I have alluded to another couple of matters in our letter, but we thought that those would be the most relevant ones today. That brings me to the end of our presentation. Thank you very much for inviting us to take part in the discussion.

The Chairperson (Mr Maskey): Thank you. Does anybody else want to make any opening remarks?

Ms Harrison: No.

The Chairperson (Mr Maskey): You are happy enough. Thank you very much.

I read in your report that you had concerns around the process of vesting land. I am trying to find that in my notes. You had concerns that the vesting of land was only possible after the development of a development scheme.

Mrs D Kelly: It is at clause 7.

Ms Harrison: Through our involvement in the Victoria Square regeneration project, we are aware of development schemes that have taken place. We wanted to draw the Committee's attention to the timescales required to effectively take forward a development scheme and the legal aspects of doing that. With that point, we are trying to highlight the importance of having a streamlined process, in which we fully acknowledge the consideration and consultation that needs to be undertaken. We suggest that the Committee needs to be aware of all those steps and how long it might take and of the impact that that timescale will have on live development projects and on the ability to make it investor-ready. It may be helpful to have a diagram that shows the process, to understand better where the logjams in that process might be. That was the main point.

The Chairperson (Mr Maskey): The Department made the argument, and we all probably agree, that the power to vest is a strong power. Most people would therefore presume that you would need to have a strong argument if you are going to vest property. On that basis, you would need to have a specific idea or plan in mind, rather than just vesting the land and working it out afterwards. That is the responsibility put on that.

Ms Harrison: We would agree with that point. It is a very serious power and has huge implications, so it needs to be used wisely, in a considered manner.

Mrs D Kelly: My question is on the same point, particularly in the case where land has a plan that has been passed by the planning authority but was not developed because of the property crash, and where the plan that the developers pursued was in keeping with the needs of the area and its environs. I have a particular site in mind in my constituency, which is a trouble spot. How does that sit with the power to vest? If there is an existing development plan, albeit that the council has a plan, how would you see arguments being constructed by which the council could approve, in principle, and pursue the development that is already approved, when the developers have scattered and are hard to pursue?

Ms Harrison: That would, most likely, come down to the detail of the legal agreement that exists between the Department and the developers. Using Victoria Square as an example again, as I understand it, there was an agreement there between the developers and the Department of Social Development. I do not know what the terms of that agreement were, but no doubt there would be something written into it that would create opportunities to review the agreement, were the situation to change.

Mrs D Kelly: This is not council-owned land or publicly owned land. It is only privately owned land.

Ms Harrison: Which the Department vested.

Mrs D Kelly: In the place in Lurgan that I am thinking of there is a lot of alcohol and drug abuse, and there was a riot near it the other night. It is derelict land that the developer will not take responsibility for but has approval on. It is creating huge concerns in the local community. It is an area of high social need. I wonder how the vesting power could be used by the council in its community planning.

Ms Harrison: As I understand it, under the terms of the Regeneration Bill, the council — or indeed the Department, but we will say the council — could, or should, as you may see it, identify that site as part of the development scheme. It would need to be part of a development scheme that fulfils the requirements under the legislation of meeting the wider public interest and benefit. Under those terms, there is an opportunity for the council to vest it as part of the development scheme, which would doubtless have other aspects including regeneration, redevelopment, community facilities or whatever it may be. Under this Bill, councils will have the power to do that.

The Chairperson (Mr Maskey): It is probably a question for the Department, but you gave a good answer.

Mr Wilson: First of all, sorry I arrived late in the middle of your presentation.

Development schemes can be put forward by councils and by the Department. Do you see any need for both the Department and the council to put forward development schemes? If so, in what circumstances do you think it would be appropriate for the Department to put forward a scheme, rather than a council, or vice versa?

Ms Harrison: That is an interesting question, and one that we actually posed to ourselves when we were looking at the Bill. Our initial reaction was that the Department should not need to take forward development schemes itself, for the reason that you have suggested, which is that the councils are in charge of local planning; development planning and community planning. However, on reflection, we thought that the councils, at this stage, are coming into a situation where they are only fledgling councils. There is a huge amount of responsibility, as a result not just of this but of all the other legislation related to planning. It is not beyond the realms of possibility that there would be instances where a project may be of significance to the whole of Northern Ireland, or it may be something that the council is struggling with at a local level because of the capability or expertise needed to take it forward. We felt, on reflection, that the provision should be included in the Bill; certainly in the short term.

Mr Wilson: So you would see it as an interim arrangement, rather than a permanent arrangement.

Ms Harrison: Possibly, although it may be something that could be reviewed after a period. There will always be projects of regional significance that will require councils to work together. That is something that will be new to some degree, in terms of major development projects and attracting investment. Rather than an interim measure, maybe it is something that could be reviewed.

Mr Wilson: The legislation does not actually refer to development schemes that may cross council boundaries; it simply refers to development schemes that are contained within existing council boundaries. Even from that point of view, when you talk about "strategic in nature", they are strategic within the confines of the council.

Ms Harrison: Yes, I acknowledge that. On reflection, we felt that it may be helpful, for both the councils and the Department, if that section was in the Bill in its first form.

Mr Wilson: On Part 1 — I was not in for that, so you may have touched on this — you talk about finance to address social need. One of the issues that concerns a lot of people is that sometimes regeneration plans are only concentrated in areas where there is a huge concentration of social need, whereas regeneration is sometimes required in areas that might be surrounded by areas of prosperity, and indeed some of the better-off areas may be affected by the fact that there are small areas of deprivation in the middle of them. Have you any thoughts on how that social need provision might be applied? Do you think that the current way in which it is applied facilitates regeneration sufficiently, or should there be some change in the application of the social need criteria?

Ms Harrison: Thank you for the question. It is a very valid point. Being from a planning background, we are probably not best placed to answer it, to be honest. I acknowledge that regeneration is often needed in areas that are not necessarily identified as having social need, but they have a much wider stimulus that will ultimately trickle down to areas that do have social need.

Mr Wilson: That is the point that I wanted to get at. Sometimes, it is easier to start regeneration in areas where there is a chance of the regeneration working, rather than jumping right into the middle of an area that is badly run down. Starting at the periphery and working in is sometimes more effective. I am interested in your view on this from a planning background. Simply saying that there has to be a huge concentration of social need may lead to missing an opportunity to have effective regeneration.

Ms Orlaith Kirk (Juno Planning): We are conscious that we would like everything to be plan-led when identifying areas of social need. It should be identified in the community plan, addressed in a holistic manner by the council and its community planning partners and, in addition, reflected in the local development plan. With our expertise in planning, we would like it to be addressed in a more holistic fashion.

Ms Harrison: It is also important to consider that, in regeneration, you are relying on public-sector finance but sometimes on private-sector finance also. The community plan and local development plan should provide the framework that will give investors an idea of where investment will succeed and where their investment will be matched and supported by other investment, be it public or private.

Mr Wilson: That is helpful. I have one last question. I know that you are probably more interested in the physical planning side of the equation, but do you see a role in the regeneration process and in the Regeneration Bill for the provision of finance for things that do not do physical regeneration but regenerate an area in other ways such as, for example, support for community organisations or training organisations? How important do you think it is to have provision in the Bill for that? If you think that it is important, what limits would you place on that kind of finance?

Ms Harrison: It might be difficult to include that aspect in the Bill as we see it now. I refer to what my colleague Orlaith said. The community planning process is new for everybody, and we maybe have not quite grappled with what exactly it is. It should provide an opportunity for that type of funding and the need for that funding, as you have described, to be identified as part of the community plan. That community plan will include actions to deliver objectives, which could include the provision of funding for community projects.

Mr Wilson: Do you think that there should be any limit to the projects that that money should apply to?

Ms Harrison: That will be for the councils to determine through their community planning exercise and through engagement with the local community, local businesses and the community planning partners.

Mr Wilson: There is, of course, provision in the Bill for that at present. There is a catch-all clause. I am not sure of the clause because I do not have the Bill in front of me. I am trying to find out about it from a planner's point of view.

Mr Allister: It is at the end of clause 1(2).

Mr Wilson: Yes, it is at the end of clause 1(2). Paragraphs (a), (b), (c), (d) and (e) of that subsection refer mostly to physical regeneration, but the catch-all at the end opens the door for all other kinds of finance. It may be an unfair question because you are probably more interested in the physical aspect, but are you saying that, from a planning point of view or from your knowledge of the regeneration of areas, there is scope for money to be spent on non-physical aspects of regeneration? What about limits? Would you leave it as open-ended as it is here?

Ms Harrison: On reading it, we felt that it read as very open-ended. It is difficult. Regeneration can be social, community, economic or physical, and, in that sense, it is extremely difficult, if not impossible, to define whether something is a regeneration benefit. That is why we keep going back and saying that, if the guide is linked to other strategies and policies that the council has prepared for the community plan and development plan, the council's priorities for those aspects, which are not physical, should be picked up through the community plan. That might give some direction to what is, at the minute, quite open-ended, as you say.

Mr Wilson: Can I take you back to the first point that I asked you about? I am a bit unclear in my mind about where the boundaries between the Department and the council might be. Do you see potential for confusion, or, indeed, conflict, if the Department brought forward a development plan and the council brought one forward, with each thinking that it should be the other's responsibility? I am a bit concerned. I really wanted to hear about it from your point of view with the expertise that you bring to it. I am a bit concerned that either thing could fall between two stools, you could have conflicts between the two or you could simply finish up with duplication.

Ms Harrison: As I said, we considered that point. On reflection, we felt that, particularly in the interim, it would be useful for the Department to retain some level of influence in undertaking its own development schemes. The legislation uses the words, "consulting the appropriate district council", but it does not say that the council has to agree or that it needs to be involved in the process. The terminology just says, "consulting". Clarification on that would be helpful to understand the role that the council will have in influencing the development scheme that the Department has the power to prepare. That is something that we questioned. You might ask why a council would prepare a development scheme on one site and the Department would do one on another. The guidance is that that can be the case, particularly if it is something of significance to the whole of Northern Ireland or, as the terminology says, it is "not appropriate or expedient" for it to be undertaken under the Regeneration Act. We took that to mean that the council would, for whatever reason, have a difficulty doing it itself and would therefore look to the Department to assist it with it. Rather than the Department instigating it and imposing it on the council, the Department would be there to assist the council if it was not able to do it itself.

Mr Wilson: The Bill indicates that the initiative would be with the Department, which would then consult with the council. That is not really your interpretation of it.

Ms Harrison: That is at the final paragraph, yes. That is why I think that clarification on the term "consulting with" would be helpful; otherwise, as you said, I can see that the Department could progress it and consult with the council as an afterthought, if you like. The first part of clause 13 implies that it would be of assistance to the council, rather than this being something that was imposed on the council.

Ms Kirk: In addition to what Helen said, we recommend that the Committee consider suggesting that the Department must have regard to the council's local development plan and community plan to cut down the opportunity for the Department to come in and do something that is completely different or materially different to what the council had considered for its own area. That is something that we think the Committee should give regard to.

Mr F McCann: Thanks for the presentation. I think that everybody you speak to has a different definition of community planning. It is probably a catch-all term for everything that may go in new councils. I understand that Sammy is saying that there may be a difficulty, at some stage, between what the developer sees as a regeneration plan and what the council sees. At the end of the day, it will probably take something like that to work out what ground either of them is on. I think that that will proceed once the new plans start to bed in.

In one way Sammy is right, in that there are regeneration plans that are outside areas. Areas like Belfast city centre could have a knock-on effect for areas of high social deprivation. There are areas of high social deprivation with some dereliction, where a factory or something similar can bring jobs, which could have an immense impact on the local population and turn around a fortune. That always needs to be taken into consideration, and I think that one of the beauties of community planning is that it allows you to look at the wider picture.

To go back to one of the first questions that Dolores, I think, asked about vesting, when you were speaking about the timeline and blockages, were you asking for a speedier way of bringing vesting through, or are you opposed to it? I was not sure.

Ms Harrison: No, we are not opposed to it at all. There is a requirement for vesting, and there are good examples of where it has worked. Our concern would be that, whenever there is an opportunity to develop a piece of land and an investor wants to develop it, they will be interested only for so long. They will have a timeline for when they need to become operational. Victoria Square can again be used as an example of that. We need to be careful that the legislation includes provision for that process, which has to go through a number of important steps, to be as effective as possible. For example, the Department requires a council to consult it prior to the preparation of a development scheme. The council then has to go back to the Department prior to the adoption of the scheme. We ask that the Department be fully resourced so that, when it receives the draft development schemes from the councils, it knows who will look at them, how long will it take and what process it will follow. That is not clear in the legislation. An investor, working with the Department or a council, will need an understanding of how long that process is likely to take, particularly as it can potentially include a public inquiry, which is time-consuming and expensive. It would help, from an investor's point of view, to understand clearly the start and end of the process, how long it would take and what the critical steps are that they have to be involved in as they go through it.

Using Victoria Square as an example, that process took upwards of two years. That can happen before the planning application, the environmental impact assessment (EIA) or any of the other bits that we would be familiar with go in. It is quite time-consuming, and when an investor is looking at the very beginning and thinking of investing, they need to add that time on to their longer development programme and to think of the day when they open, become operational and start to get their money back. That is where we were coming from in understanding the vesting process and making it as streamlined as possible whilst having regard to the important steps that need to be followed.

Mr F McCann: Thank you for that. That certainly explains it, and again Dolores touched on the fact that there are quite a number — I have heard colleagues raise it before — of classifications of land. You might have departmental land, council land or private land sitting in the middle of what you may see as a major development area, and the developer who owns that land plays hardball. Do you think that, at times like that, the Department or the council should move in speedily and vest the land?

Ms Harrison: In effect, that is what the development scheme and the Regeneration Bill will allow the councils to do, as the Department has been doing. So, yes, following the criteria set out here, the point is to make the process as transparent and fair as it can be.

Mr Beggs: Thank you for your presentation. Do you see the format of the Bill and the proposed legislation modelled on legislation elsewhere? If so, are there suggested changes that should be made from experience to make it better?

Ms Harrison: Recently, we looked at the equivalent in the South of Ireland. Orlaith may want to comment on its format, because it is different.

Ms Kirk: It is different. It is in the local government legislation and is driven by residential development. That is distinct from the Regeneration Bill, so you are not comparing like with like. It is hard, on the back of that, to make recommendations for improvement. You find that a lot of the regeneration schemes in the Republic of Ireland are driven by housing and the provision of social housing development. Councils are behind it, but the housing section of councils is involved. Key members of Republic of Ireland councils are in charge of regeneration, but it is primarily about a housing function. We are not comparing like with like.

Mr Beggs: Is this modelled on Scottish, English or Welsh legislation?

Ms Harrison: Elements of it would be very similar to the English legislation through the compulsory purchase powers that councils have for similar types of projects.

Mr Beggs: In some town centre areas in my constituency there are derelict buildings that may have sat for 20 years or more, even through the boom time, because the owner, for whatever reason, did not progress them. One of the issues that can cause difficulty is conservation areas and the difficulty in having an economic proposal that will provide all the protections that may be imposed while being economically viable. Do you see the legislation being able to allow such sites to be moved forward, whether by compulsory purchase or perhaps by some form of grant, if councils are demanding high levels of conservation to enable economic development?

Ms Harrison: The really important aspect of the Regeneration Bill as we have been talking about it is that the majority of it is geared towards councils preparing development schemes. In the example that you gave, the council would be concerned about a piece of land. That land may be in a conservation area, but the council will be establishing a planning policy that affects that conservation area, and it will also be responsible for taking forward the development scheme. It is the decision maker and the policymaker. It will have the powers itself to do as you described and to make a judgement on the basis of the policy that protects the conservation area and the desire to improve the derelict site. It will have the powers under this legislation to take forward improvements on that site, and it can choose to do that either in complete compliance or to some degree in contravention of its development plan policies.

Mr Beggs: It may just be one or two properties in the middle of a street. Do you believe that that is a big enough critical mass to warrant a plan under this legislation? It may be down to one or two owners.

Ms Harrison: I think that it is important to understand that, as we talked about, the development scheme is a really powerful tool. Traditionally, in the Department it would have been used not on a very regular basis and probably not on a building-by-building basis but more where there was redevelopment and regeneration of a wider area to give a wider-spread benefit. Part of that might be because it is quite a complicated legal process to go through. Traditionally, it would have been more for the benefit of a wider area, rather than just one or two units. There may be some development schemes that are for two or three units. I am not familiar with that, but it would usually be for an area larger than that.

The Chairperson (Mr Maskey): No other members indicated that they wish to ask a question. Having read your submission and listened to the discussion this morning, I think that a couple of key themes are coming through. Obviously, there is the clarity of any process and a need to resource the Department or the councils to make sure that they are responding in a timely fashion and in an appropriate way so that there is no prolonging of any kind of process. Central to your submission is the contention that there is a need for people to have due regard to all the other plans around them. I do not think that we mentioned business improvement districts (BIDs) this morning, but they are another key tool that people in council areas have. Am I right, then, that you are basically saying that the centrality of all this has to be the community plan? I think that most people accept community planning, or some variation or definition of it, but it is a very central plank of local government reform. Am I am right in saying that your key point this morning is that all plans that are on the table and are relevant, whether at Department level, regional level or council level, have to be taken into regard when developing any plan? That makes sense, but you are making the point that it is not nailed down properly

Ms Harrison: Yes. In essence, Chair, we focused on the plans that the council is required to make under legislation. You are right about BIDs, but we focused on the regional development strategy, which already required the development plans and community plans. It is important, though, to note that we understand that there may have to be flexibility, because it may be that the development scheme cannot be in accordance with those plans. That is why we suggest the words, "to have regard to" on the understanding that it may not be able to be in accordance with them.

The Chairperson (Mr Maskey): I note that you are not making the point that one has to trump the other, but you are saying that they need to have proper regard. I want us to take this up with the Department to see how we can square these circles, so to speak.

Mr Wilson: Just on that, because it is an interesting point. Obviously, you deal with people who are putting in planning applications. We now seem to be adding layers of new information. I am not saying that it will all be regulation, but there seem to be layers of new things that people have to take into consideration when putting forward a planning application, whether it is the area plan, community plan, development scheme or a Department or a council development scheme, not to mention the regional strategic plan. Do you see this as adding unnecessary complications for people trying to get a development going in what is already an overcrowded regulatory field?

Ms Harrison: We focused our discussion in our submission on the development scheme aspect of the Regeneration Bill. I think that there is a need for provision in a piece of legislation — in this case, the Regeneration Bill — to allow councils, certainly, and possibly the Department, to be more proactive in facilitating development. I do not think that people will be expected to be overly familiar with the terms of the Regeneration Bill, but they need to understand that provision exists to allow development schemes to be taken forward where councils feel it necessary.

We said previously in information we provided relating to the Local Government Bill that we feel that the community planning process and the development planning process should run in parallel. Otherwise, there is a danger that communities will be asked to comment on something, and then six months later they will be asked to comment on something else that seems quite similar. We feel, and this is certainly in our submission, that there needs to be a really strong relationship between the community plan and the development plan and that the public needs to be aware of what is in those because it has been part of their formulation. The development scheme might come along before the development plan or in between, when the plan is about to be reviewed and is not quite up to date. It is more of a one-off, rather than something people could necessarily foresee when preparing the development plan.

I think that that is needed, but there also needs to be really clear referencing on the relationship between the Regeneration Bill and, in particular, development schemes, community plans and development plans so that everybody knows that they have to look at them. They should all, however, say the same thing insofar as they can, subject to them being out of date.

Mr Andrew Heasley (Juno Planning): The main message for your councillor colleagues is that we need the area planning process rolled out. Once all the plans are up to date, everything else can follow, giving developers and everyone else confidence that land zoned for a particular use should get planning on that basis. It is important to get that back to your councillors.

The Chairperson (Mr Maskey): That starts with the community planning process.

Are there any other remarks that you want to make this morning, Helen or Andrew?

Ms Harrison: No.

The Chairperson (Mr Maskey): I thank you again for coming this morning, making your submission and dealing with members' queries. We will follow up on a number of the concerns you raised with us in our deliberations. Thank you very much for helping us.