Appendix A Risk Assessment

Risk Description Control Measures
National policy and legislation changes

Changes to the National Planning Policy Framework and
other policy create uncertainty and delay through additional
evidence base work.

National Development Management Policies are introduced
that will require changes to emerging plan policies.

Delays and uncertainty in relation to current and proposed
plan-making system.

 The Council has limited control but will monitor national changes and continue to liaise with Government.
Political

Risk of political approval being withheld and/ or change of leadership and/ or direction and/ or political priorities.

Deviation from stated dates due to use of the Council's call-in procedures.

Long reporting procedures to follow and long lead-in times to take reports through Council committee cycle.

Early consultation and involvement of elected members at
an early stage in order to provide ownership, leadership
and commitment to future implementation.

Regular monitoring and review of timetables/ progress and
ability to meet key dates.
Staff turnover, recruitment and absence

This may include loss of experienced staff, long term sickness or maternity leave. Recruitment may well be difficult, particularly for temporary periods.

Reduced capacity within the team to manage workloads and meet timetables resulting in slippage with adverse impact on staff motivation.

Prompt recruitment of new experienced staff and/or
recruitment of temporary staff or providing secondment opportunities, or appoint specialist consultants.

Need for on-going project and workload management.
Lack of specialist skills in house in key policy
areas

There is a requirement for a robust evidence base to support
the preparation of the Local Plan , on a range of policy
areas, resulting in:

  • slow progress of preparation
  • evidence being challenged or a gap in policy
  • potential negative impact on the quality of the Local Plan

Consider need to appoint specialist consultants for key policy areas or evidence base requirements (dependent on budget).

Obtain training for areas where expertise is lacking.
Financial – constrained
Council budgets, increases in Planning Inspectorate fees		 Risk of inadequate financial provision hindering progress and scope of work required. Regularly report on budget requirements and minimise
financial expenditure to ensure value for money, including joint and partnership working wherever feasible.
Flexible and mobile working Risk of slippage due to changing working patterns, arrangements and difficulty of co-locating the team and reduction of collective desk/office space (especially during the Examination in Public). Need for on-going project and workload management - particularly with regard to regular staff One-to-Ones and team meetings.
Pressure on staff time due to competing work streams and other policy work areas

Other work areas either led by or requiring planning policy input, take resources and focus away from dedicated Local Plan document work, causing slippage in the programme. For example:

  • increase in support required for Neighbourhood Development Plans
  • supporting legal challenges, planning appeals, hearings and inquiries

May have to consider prioritising Local Plan document work over Neighbourhood Development Plan support.

Ensure Local Plan is recognised as a corporate priority.

Identify key staff to be “shielded” from other work, wherever possible.

Consider increasing staff capacity through the procurement of external consultancy support.
Third Parties Risk of comments and representations from third parties causing delay (including lengthening of examination) and/or additional expense/ delay from unexpected volumes and/or unforeseen issues arising, with need for additional evidence and/or consultation.

Consultation and involvement of relevant stakeholders.

Ensure timetable is realistic but has some flexibility built in and monitor progress against LDS.

Consider the need for additional resources as part of ongoing monitoring.
Joint working with other internal departments and/ or external authorities causes delay

Key milestones in programme not met.

Duty to Co-operate not met.

Ensure timescales for Local Plan realistically reflect partner authorities ability to contribute to joint working.

Ensure commitment to milestone dates and resource allocation is obtained from relevant parties in advance.
Legal

Risk of non-compliance with legal procedures and requirements and/ or judicial review leading to adopted Local Plan documents being quashed and additional workloads.

Changes in plan-making requirements/ procedures can also result in delays.

Ensure relevant legislation/ regulations are checked and complied with at each stage.

It is not possible to easily plan for further changes to the planning system. The Council will endeavour to deal with new requirements with minimum disruption to the timetable as part of ongoing monitoring.
Capacity of the Planning
Inspectorate		 Examination and/ or Inspector’s Report is delayed and key milestones in programme not met.

Close liaison with the Planning Inspectorate to ensure early warning of any problems.

Minimise the volume of issues to be resolved at examination, through ensuring a robust evidence base and wide pre–submission public consultation.
Soundness Modifications required by the Planning Inspectorate. Local Plan cannot be adopted without significant additional work, possibly including repeated stages of preparation and consultation.

Ensure Local Plan is legally compliant, founded on a robust evidence base, accompanied by appropriate assessments and appraisals and well-audited community and stakeholder engagement.

Use of self-assessment toolkit (published by national advisor PAS).

Maintain awareness of best practice.