Department for Transport, Local Government and the Regions
Planning Green Paper Planning: Delivering a Fundamental Change
Chapter five: A fundamental change in development control
5.1 Development control is the process by which decisions are made on applications to develop land or buildings or to change their use.This is the point at which people are most likely to encounter the planning system.
5.2 A system for regulating development in the public interest is undoubtedly needed. But the present system of development control is not customer-friendly and is not well understood.
5.3 Not only is the speed of processing planning applications often very slow, it is also highly variable between local authorities with a particular impact on business. Business applicants also complain that the planning system is insufficiently responsive to their needs. In particular, they are concerned that the slow pace of decision-making shows insufficient appreciation of the impact of both the timing and nature of planning decisions on investment decisions.Communities are equally affected by the uncertainty arising from delays in making planning decisions.
5.4 We need to look at the system afresh.We want a fundamental change in performance, a system that:
- is responsive to the needs of all its customers and offers a new culture of customer service;
- delivers decisions quickly in a predictable and transparent way;
- produces quality development; and
- genuinely involves the community.
5.5 Our proposals to meet these objectives are set out below.We propose to:
- introduce a planning checklist so that people know how to submit a good quality planning application;
- tighten targets for determining planning applications and deal with the delays caused by statutory consultees;
- encourage masterplanning to improve the quality of development;
- promote better community involvement by offering community groups advice on planning;
- introduce delivery contracts for planning for major developments;
- introduce new business zones where no planning permission is required for certain forms of development; and
- seek better and tougher enforcement against those who evade planning requirements.
Improving customer service
5.6 Most people only have limited experience of the planning system.They may encounter it because they wish to start up or expand a business, extend their house or because they are consulted on a planning application submitted by someone else which may affect their property. Whichever is the case, for many people and small businesses, the development control process is unfamiliar.We have got to make it much more understandable, more service-orientated and responsive to customers.
The user-friendly checklist
5.7 Because people find the planning system complex and hard to understand, too many planning applications are poor in quality and incomplete.This slows down the processing of applications and often leads to frustration with the process. One local authority estimates that around 30% of the applications it receives are deficient in that they contain insufficient information to allow a decision to be made.
5.8 Applicants need much better guidance about how to prepare and submit a planning application so that it can be processed quickly and efficiently.We propose that local authorities should publish a user-friendly checklist of the information needed in an application. It should explain in plain English what the applicant is expected to do and the information they should provide. In return, the local authority should state how the application will be processed and the service they will offer.We propose to work with the Local Government Association to develop a model checklist that can be used or adapted by local authorities.
5.9 The checklist will help to improve the quality of applications and the information needed to support them.We also want to encourage pre-application discussions between applicants and local authorities.These can frequently help to guide applicants through the process, clarify what is required and help them formulate acceptable proposals, particularly for larger schemes.This can be of particular help to small business and individuals who may find the planning process difficult to understand.
What a model checklist might contain
- name of applicant or their agent
- signed and dated application form
- signed and dated certificate of ownership
- site identification plan identifying the site for development and any other land in an applicants ownership or control
- a clear statement of what is proposed including its design, materials, impact, accessibility and environmental effects
- clear plans of the proposed development at a suitable scale and in sufficient detail to allow the proposal to be assessed
- a statement of planning policies in the Local Development Framework which refer and the developments compliance with them
- a statement of the action plan policies or land use designations that apply and the developments compliance with them
- a copy of the notice served on the owner if this is different from the applicant
- a statement of what consultation has been carried out in conformity with the Statement of Community Involvement and the originals of all correspondence with anyone affected by the proposed development who has been consulted
- a statement of consultation with any statutory and non-statutory consultees and their response
- reasons in support of the application
5.10 We recognise that pre-application discussions can represent a significant drain on authorities resources.The Local Government White Paper announces our intention to enable local authorities to charge for most discretionary activities.This will enable local authorities to charge for pre-application advice, if they wish. In setting fees for pre-application discussions, local authorities will need to ensure that they are not set at such a level as to discourage applicants from seeking advice which might improve applications, thereby lessening the burden on the local authority later in the planning process.
5.11 Applicants sometimes complain that their applications disappear into a black hole and they are not kept informed of progress.We expect all customers of the planning service to be able to keep track of the progress of their application. Local authorities should identify a nominated officer so that applicants know who to turn to for advice and guidance. For larger schemes, we have recommended use of a project approach (see para 5.25).
5.12 We must make sure that the local planning department is user-friendly and orientated towards customer service. Almost 40% of households now have internet access and electronic technology has a huge potential to make the planning system more transparent and accessible, more responsive and more efficient.
5.13 The Government has given over £6m backing to a new project, the Planning Portal, which will provide publicly available information and advice on the planning system and allow greater electronic access to national, regional and local planning policies. It will soon be possible to make applications for planning permission and planning appeals on-line.The system will unlock major efficiency gains and will also allow people to track the progress of individual applications.
5.14 Some authorities are well down the road but others have a lot to do to meet the Governments 2005 target for electronic provision of planning services.We are talking to local authorities about making the investment and operational changes and will shortly publish good practice guidance for local authorities on ICT and planning.
One stop shop
5.15 At the moment, it is quite possible that more than one consent regime may apply to a single development. For example, alterations affecting a listed building may need planning permission and listed building consent.This can be very confusing for people and time-consuming both for the applicant and those dealing with the applications.We need to make the process simplerand more customer friendly.
5.16 We will move quickly to standardise application and administration procedures under different consent regimes.We will encourage local authorities to provide a single application point for such consents.We will also continue to support the development of Infoshop, a computerbased package to deliver a one-stop shop for a range of local authority services.We propose to initiate a review of the case for integrating the present array of controls into a single consent regime.
Parallel consents with pollution control authorisations
5.17 For development with potential for polluting emissions, such as waste management facilities and some industrial plants, separate consents are required from two different organisations - a planning authority on land use matters and from the Environment Agency on pollution control matters such as control of emissions to air, water and land.We think that such developments can be handled more efficiently and both the developer and the community can benefit from greater certainty if those proposing to develop such facilities apply for pollution control authorisation and planning permission at the same time.
5.18 Consequently, the Environment Agency has been working with the Local Government Association and the Confederation of British Industry to produce a concordat, aimed at synchronising the two processes and reducing delays and uncertainty.A consultation exercise on the proposals will be carried out shortly.
5.19 One of our objectives is to deliver planning consents in a predictable and transparent way. Slow planning processes can be a source of frustration for all planning applicants and may have real economic consequences for business.We need to ensure that better service to the customer is matched by an increase in the speed with which local authorities deal with planning applications.
5.20 Best Value imposes a duty on local authorities of continuous improvement in the delivery of their services. It requires regular fundamental review of functions and implementation of changes arising from those reviews, with the aim of providing better customer focus. Performance achievement is measured against a set of national indicators.
5.21 The current target is for local authorities to determine 80% of applications within 8 weeks. We are concerned that local authorities are struggling to meet this target.Average local performance is around 65% and has been for many years; only 30 authorities meet the current target; 45 authorities decide less than 50% of applications in 8 weeks (see figure 3).
5.22 We recognise that the current target is unsatisfactory. It does not differentiate between applications which may have a big local impact and those that will have minimal effect. It may even encourage authorities to give priority to simpler applications to the detriment of those that are more complex.
5.23 We have set new handling targets for 2002/03 which are:
- 60% of major commercial and industrial applications to be determined in 13 weeks;
- 65% of minor commercial and industrial applications to be determined in 8 weeks;
- 80% of all other applications to be determined in 8 weeks.
5.24 Current achievement is well below these targets (see figures 4 and 5) These targets will be monitored through the Best Value regime and will be one of the principal ways in which the performance of local planning authorities will be judged.We say more about Best Value in
5.25 While our new targets should give much greater certainty to most commercial and industrial applicants for planning permission, the bigger development proposals will inevitably take longer to consider.We need a framework for ensuring that larger applications are delivered to clearly agreed timetables.
5.26 Business organisations tell us that business would be prepared to waive the right to appeal against non-determination of an application if, in exchange, they had greater predictability about when a decision will be made and were kept informed about its progress.We propose that, for the bigger applications, local authorities and developers should at the outset agree a timetable for delivering a decision.This would be set out in a contract or undertaking reached between the local authority and the developer.
5.27 We will work with business organisations and local government to develop a model undertaking.We would expect that it would include an agreed project plan with a project manager. It would also take account of the potential input of consultees and any need to agree a planning obligation (see box).The contract would need to be open to variation by mutual agreement to address unforeseen delays.
5.28 There would need to be sanctions if an application was not decided by the agreed date without good reason.We propose that in such an event, if agreement cannot be reached on a revised delivery date, either party should be able to refer the application to the Planning Inspectorate and that it should be automatically handled on a fast-track basis.
Planning obligations (or section 106 agreements) are usually contractual agreements reached between a local authority and an applicant to help facilitate a development.They may include a financial contribution covering, for example, the cost of constructing a new site access or to provide a new bus route to serve the development.
An important form of planning obligation routinely used by many local authorities is an agreement to require that a proportion of new residential development should be affordable homes.
Planning obligations have been criticised for being complex, difficult to agree and for delaying the planning process. It has also been alleged that they are agreed behind closed doors and are not sufficiently open to public scrutiny. Our proposal in para 5.59 addresses this point.
We are publishing a companion consultation document with proposals for changing the basis of planning obligations.We think that there is a strong case for allowing local communities to share in the benefits of development and growth. Our proposed new Local Development Framework will set out clearly a local authoritys policies towards seeking planning obligations.The consultation document will show how the agreement of planning obligations can be speeded up to complement our other measures to make the planning system more efficient.
Statutory and non-statutory consultees
5.29 There are two classes of expert consultee. Some, like the Environment Agency and English Heritage, must by law be consulted on particular types of applications, and these are statutory consultees. In other cases, consultation with certain bodies is advised, and these are the nonstatutory consultees.
5.30 Consultees are important to the planning process because they can contribute expertise which is invaluable to both the applicants and to the local planning authority. Unfortunately, they are also a major source of delay. While planning decisions may be made without necessarily waiting for advice from non-statutory consultees, most planning authorities will not take a decision in the absence of advice from a statutory consultee.
5.31 Many consultees are Government-funded bodies and we regard their performance in responding to requests for comments on planning applications as unacceptable.We recognise, however, that regularly commenting on planning applications can be a drain on consultees resources.These bodies do not currently prioritise such work, particularly as they are not statutorily required to respond to planning consultations.
5.32 A very effective way of speeding up planning decisions, especially for larger applications, is for the developer to consult a statutory or non-statutory consultee direct before an application is submitted. If developers chose to use this approach then we propose that the statutory consultees should be allowed to charge a fee, subject to provision of a timely and better service.
5.33 We further propose to:
- reduce the number of statutory consultees.There are a wide range bodies that are required to be consulted depending on the nature of the application.We propose that only those bodies whose advice has health and safety implications or which operate another parallel consent regime (such as listed building, playing field or environmental consents) will be given statutory consultee status;
- allow the new list of statutory consultees to charge a fee for their response provided that a substantive response is given in a defined timescale of 21 days. No fee would be chargeable to an authority that needed to pursue with a consultee issues unresolved when an application was submitted;
- impose a statutory responsibility on statutory consultees to respond to consultation requests within a statutory timescale; and
- link future funding to satisfactory performance where statutory or non-statutory consultees are dependent upon Government for financial support, based on new arrangements to monitor performance.
5.34 Some consultees are already identifying low-risk areas and types of development where they can provide standing advice to local authorities. Because they do not provide advice on individual planning applications in these categories, the time needed for consultation is reduced, thereby removing a potential impediment to the decision-making process.We shall ask consultees to build on this approach and see if it can be adopted more widely.
5.35 We do not want to add unnecessarily to the list of consultees. However, given their role in promoting regional economic development, it will be important for Regional Development Agencies to be able to make representations in respect of major investment proposals likely to have an economic significance that extends to the region or sub-region.The RDAs themselves do not expect there to be more than a handful of cases in each region each year.
Business planning zones
5.36 We need to ensure that the planning system is capable of meeting the needs of fast-moving businesses such as our leading-edge technology companies. Planning delays can prove a significant obstacle to the development of such companies.We propose to allow local authorities, working in the context of a need identified in regional economic and planning strategies, to create business planning zones where no planning consent will be necessary for development, if it is in accordance with tightly defined parameters.
5.37 We intend such zones to be specific to types of business that have a low impact on the surrounding area, such as clusters of high-tech industry. Low impact means that they would not add significantly to high local housing demand, have large infrastructure requirements or require special environmental precautions to be taken.This would not be free-for-all development. Criteria would be set to ensure that the quality of development is of the highest standard in order to ensure that the zones remain attractive to leading-edge companies and are acceptable to their local communities.
5.38 We would expect the need for most business zones to be identified in regional strategies and to be planned by local authorities in partnership with universities, RDAs and leading edge companies but we think that any of the partners should be able to initiate proposals for the designation of a business zone.We propose that every region should have at least one such zone to promote technology companies. It is equally possible that an existing business area could apply to have special business zone status.We should welcome views on the concept of business zones and the safeguards that might be necessary to ensure that they deliver quality development.
Masterplanning larger developments
5.39 Large sites can take time to plan properly.They are also highly significant in relation to our objectives to involve local people in planning the future of their community and to improve the quality of development. Masterplanning developments can help speed up the planning process by indicating clearly the nature, type and design of development expected on a particular site or area.
5.40 Where a site is specifically identified as a major development opportunity by a local planning authority, the expectation will be that there will be an action plan drawn up for it under the Local Development Framework. At the moment, the principle of development may be explored in pre-application discussions or by the submission of an outline application. Neither option is very attractive because there is no clear masterplan or design brief with which the community can be engaged. All too often the result is that local authorities receive an application for outline planning permission but with no guarantee that the concept approved will actually be delivered.
5.41 The community, developers and the local authority all need a safeguard in these circumstances. Our solution is to engineer a way in which they can all work together on a development proposal.
5.42 We would like views on a proposal to introduce a new arrangement to replace outline consents whereby a developer can seek a certificate from a local authority that it has agreement for a defined period to work up a detailed scheme against parameters determined in agreement with the local authority.The certificate might cover, for example, design, affordable housing provision and community participation. Any resulting formal applicationwould subsequently be submitted in detail rather than in outline form and the existence of a certificate - and compliance with its requirements would weigh heavily in the final determination of planning consent. Alternatively, the certificate would automatically lapse on a predetermined date if no application has been made. In appropriate cases, the masterplan might be formally recognised as a local action plan in the Local Development Framework.
Improving the effectiveness of the system
Some developers use repeated applications to wear down opposition to undesirabledevelopments.This is damaging to peoples confidence in the planning process and inefficient.We propose that once a planning application has been refused and not appealed, or appealed and refused, no substantially similar planning application for the same site should be accepted unless there is a material change in circumstances, such as a relevant new policy in the Local Development Framework.
It is not unusual for housebuilders and other larger developers to twin-track identical applications so that one can be submitted to appeal once the statutory period for determination of an application has been passed. It is a negotiating ploy and wastes resources. The proposed new delivery contracts (see para 5.25) would make this practice unnecessary. We propose in any event to supplement authorities current powers so that they can refuse to accept a substantially similar application for the same site if a previous one is still being considered by them or is at appeal or has been called-in.
Time limited consents
Permissions and consents normally last for five years and are often automatically renewed.We think that five years is too long and that unimplemented consents effectively prevent the use of potentially developable land for other purposes.We intend to limit permissions and consents to three years and they should automatically lapse thereafter. Applications to renew permission and consents will need to be considered afresh in the same way as completely new applications and tested against the policies and priorities prevailing at the time.
Use of compulsory purchase powers for land assembly
The successful implementation of major planning proposals, whether for new infrastructure, the re-use of brownfield sites or the regeneration of run down areas, depends on the timely assembly of land.This, in turn, requires a simple and speedy method of acquiring the necessary land, by compulsion if necessary, with fair recompense to those from whom the land is taken.
We have launched a comprehensive Procedure Manual, to help acquiring bodies to navigate their way quickly and accurately through the whole compulsory purchase process and we have published new public information booklets to better inform those affected by orders.
We are publishing a consultation document setting out our proposals for major changes to the way that the compulsory purchase and compensation system operates. Our objective is to make the system simpler, fairer and quicker.We will:
- simplify the law, consolidating the complex mass of case law;
- clarify the powers available for acquiring land for planning and regeneration purposes;
- speed up the confirmation process;
- ensure that implementation follows promptly once an order is confirmed; and
- provide a fairer basis for assessing compensation.
Entering the appeals process
5.43 One of the pinch points at which applicants can experience delay in the planning system is when they decide to exercise their right of appeal either against a decision by a local planning authority or because their application has not yet been determined.We have two proposals to make:
- in the case of appeal against non-determination, a planning inspector should pick up the local authoritys case file and take over jurisdiction.This means that work done to consider the application is not wasted but transferred. If the application is determined before the inspector starts work then that decision would stand, unless appealed;
- both local communities and developers need certainty about whether an appeal is to be made. At the moment, the applicant has 6 months to decide whether to lodge an appeal. We think this is too long and we propose to reduce this period to 3 months.
5.44 One of the questions we have asked is whether we can streamline the planning system by ensuring that planning applications do not have to be submitted unnecessarily.There are two measures that are available to achieve this objective permitted development rights and use classes.
Permitted development rights
5.45 The General Permitted Development Order (GPDO) enables certain kinds of development to proceed without the need for a planning application. For example, many home extensions do not require a planning application. By establishing a threshold below which applications are unnecessary, permitted development rights significantly reduce the regulatory burden of the planning system.
5.46 The GPDO is widely regarded as being difficult to understand. Lack of understanding of what is, and what is not, permitted development leads to queries about whether particular developments require planning permission.
5.47 We recognise that any relaxation of permitted development rights raises difficult issues: even small structures or alterations can have a real impact on neighbouring properties and the way people feel about their homes and their neighbourhood. For this reason, we are not proposing any significant change in the national regime for permitted development rights but we intend to update the GPDO and make it more comprehensible.
5.48 At present, permitted development rights are determined nationally. One option is to allow local flexibility in the definition of permitted development rights. Local orders could help authorities to be proactive in encouraging development by cutting red tape for developers: they are already able to make permitted development rights more restrictive in, for example, conservation areas.
5.49 On the other hand, local permitted development rights could lead to inconsistent arrangements between and within local authority areas and become a source of confusion. We would welcome your views on whether the introduction of local permitted development rights would help or hinder efficient planning.
5.50 Development control extends not only to new building work but also to changes in use of buildings and other land. However, certain uses are so similar in land-use planning terms for example, noise, traffic, visual appearance and parking that there is no obvious reason why a planning permission for change of use should be required.The Use Classes Order (UCO) excludes from planning control any change of use where both existing and proposed uses fall within one class.The GPDO provides some additional flexibility to move between classes without making a planning application.
5.51 We believe that the UCO should be constructed in a way that allows the maximum possible deregulation consistent with delivering planning policy objectives.We have recently published research into the operation of the UCO and will issue a consultation paper early next year seeking views on a range of possible changes.
Greater access for the community
5.52 A key test of the planning system is the extent to which it is trusted by the community. Its workings have to be honest and transparent and allow access by people who want to engage in the process of planning the future of their community.That trust depends not only on the formality or length of the process but on whether it allows the communitys influence to,be felt.
5.53 Consultation on planning applications has a vital role to play in giving the community an opportunity to express their views on individual development proposals. Current arrangements fail to provide adequately for this.
5.54 We believe that, as far as possible, consultation should take place and issues should be resolved before an application is submitted. Consultation by a local authority on an application can account for a significant proportion of the time taken to determine an application. Advance consultation not only potentially speeds up the decision process but helps to build consensus and reduce suspicion about the proposed development.
5.55 We have considered whether we can shift the duty of undertaking effective consultation solely to the applicant. Our view is that this would impose too much of a burden on individuals and small businesses, who may find it difficult to carry out a consultation unassisted. However, we strongly believe that, with larger and more complex proposals, developers ought to be engaging with local communities to the greatest extent possible in advance of submitting a planning application, in line with the proposals for Statements of Community Involvement set out in para 4.22.
5.56 There remains an important distinction between consultation with near neighbours and giving the wider population information about planning proposals in their area. So we do not propose to withdraw the requirement to list planning applications weekly in local newspapers. New technology may offer the opportunity to dispense with newspaper advertisements in due course, though these may still have a place for major development.The requirement will need to be reviewed in the future, as local authorities routinely use e-business for accepting and processing planning applications.
Community advocacy: Planning Aid
5.57 Individuals and community groups often feel in need of independent and impartial advice about how to engage effectively with the planning process and lack the resources to be able to use planning consultants.They want help to develop planning advocacy skills and they need access to better training and planning advisory services.We propose to help
5.58 Planning Aid, a network of 600 planners who give their services voluntarily, can be one source of help, particularly for individuals with a planning problem.We fully support the aims of Planning Aid and we are working with the RTPI on ways in which the service can be expanded and, subject to the introduction of necessary statutory powers, better funded.
5.59 Almost two thirds of local authorities regularly provide the opportunity for the public to speak at planning committee meetings. Discussions of planning applications by local authority planning committees should, in our view, always be held in public.We look to local authorities to ensure that their new constitutions, which they are bringing forward under the Local Government Act 2000, provide a transparent framework for making decisions on planning applications, as well as other issues.We propose that Best Value inspectors should take the failure of local planning authorities to open up their meetings to public participation into account when considering the performance of local authorities.
5.60 People need to know why a planning application has been agreed as well as why it has been refused.We propose that local authorities should always give reasons for their decision to approve a planning application as they already do when they refuse one.This should include relevant reference to plan policies.The Secretary of State will follow the same principle in respect of called in planning applications (see para 6.18).
Access to planning papers
5.61 One of the aspects of the planning system which is repeatedly criticised by community groups is the level of charges levied by local authorities for copies of plans, committee papers and planning applications.The cumulative cost of these can be significant in a community organisations budget over the year.
5.62 We accept that local authorities should charge for any hard copies they produce but these charges must be reasonable.We intend that copies of plans and planning applications received electronically should routinely be entered on the local authority website (in due course, as part of the Planning Portal project (see para 5.13)) and should be available to download free. We strongly encourage planning authorities to have a publicly available terminal in planning departments in order to access such information.
5.63 In addition, we encourage local authorities to use other means to make documents available at low or no cost. Public libraries usually have publicly available web access with trained staff who can help those unfamiliar with internet use who can help to access planning information; copies of documents relating to significant planning applications might also be made available in public libraries for inspection or for free overnight loan.
5.64 Many planning consents for larger developments attract planning obligations (see box) Many people feel that they are negotiated behind closed doors, they are subsequently not well publicised and they are insufficiently transparent.
5.65 A separate consultation document is being published which considers wider reforms to the process of delivering planning obligations.We intend, as part of that initiative, to change the law to make it a requirement that information on planning agreements and undertakings is entered on the planning register. At the moment this is done as a matter of good practice but we will ensure that all such agreements are openly available to public inspection so that councils can be better held accountable for them.
Information about appeals
5.66 If people are to participate fully in the planning process, they need to know that appeals have been lodged and that inquiries may take place. Less publicity is currently required for appeals and called in applications than for planning applications.We will review the requirement to publicise planning appeals and called in applications with the aim of encouraging greater participation.
Planners working on the ground often have a good appreciation of the impact of planning policies on the needs of different groups in the community, including ethnic and religious minorities, the elderly and the disabled.
At all levels of the planning system, special attention is paid to the elderly and disabled people whose needs are particularly apparent.There may be other groups that have been less engaged in considering whether there are planning policies that impinge particularly on them.
We invite black, ethnic minority and other groups to respond to this consultation and let us know whether there are aspects of the planning system considered in this Green Paper on which they have a particular viewpoint.
5.67 We are creating a simpler faster development control system.We must also ensure that it is a system which people trust. Deliberate evasion or abuse of the planning system is unfair to others and brings the system into disrepute.We need more effective sanctions against those trying to cheat the system.
5.68 The current enforcement system is unduly complex and cumbersome. Whilst minor breaches of planning regulations can often be resolved through negotiation and persuasion without the need for formal enforcement action, it can be difficult and expensive for local authorities to take effective action against those deliberately evading the system.
5.69 There are several issues:
- developing without planning consent or in breach of that consent is not an offence.There is a case for reviewing the law;
- existing sanctions do not act as a deterrent and they may be insignificant in proportion to the value of the unauthorised development or the income derived from it; and
- those seeking to evade the planning system may appeal to the Secretary of State against enforcement notices in order to delay action being taken against unauthorised development.
5.70 Planning enforcement is a complex subject that raises difficult issues.We intend to review current arrangements with the intention of introducing simpler procedures. As part of this process we will look again at whether there should be punitive charges for retrospective applications and whether a deliberate breach of planning regulation should constitute an offence immediately pursuable through the courts.
Foreword | Chapter 1 | Chapter 2 | Chapter 3 | Chapter 4 | Chapter 6 | Response | Appendix