Mr. John Spain:

The first issue relates to what we have been talking about with regard to judicial review. That is critical, and the provisions in the draft Bill are welcome. However, they need to go further. I do not think they are going to radically change the situation. We have an extreme situation in respect of the levels of challenge and overturn in the context of judicial review. Those issues need to be looked at further. There needs to be detailed engagement with all the parties involved in that process. We need to put mechanisms in place. We set out a number of such mechanisms in our previous submissions. If people identify issues or difficulties with a permission, how can they be addressed and resolved as quickly and in the most efficient way possible so that permission can then stand up? We have talked about provisions to allow the board the power to amend and correct its decision. That is an important step but we need to go further than what is contained in the draft Bill. We need to extend that provision to the entire process and not only the board's decision in order to get back to a situation where planning decisions can stand up in court and people can have confidence in the system.

In terms of the development plan process and the ten-year review, a key change would be a five-year review within that. An interim review becomes more meaningful where there is public consultation as part of that. That five-year review must review in particular housing targets and housing land supply at that five-year point.