The Role of Spatial Plans Adopted at the Local Level in the Spatial Planning Systems of Central and Eastern European Countries

Highlights

Most CEE countries have at least two types of spatial plans at the local level. In every CEE country, at least one type of spatial plan is a universally binding legal act. A recurring problem in them is the appearance of barriers to the interpretation of planning provisions. Differences can be found across CEE countries, in relation to the role of spatial plans. A problem is the differentiation of the contents of the different types of plans.

What are the main findings?

• There are major analogies in the countries studied regarding the legal formula of local spatial plans and the practical problems involved.
• The implementation of the spatial plans into other acts is a serious challenge in the countries studies.

What is the implication of the main finding?

• A practical debate is needed on the optimal formula of spatial plans, based on the experience of the countries studied.
• It is necessary to develop an interdisciplinary discourse to help implement the findings of the plans more widely.

Abstract

The article deals with the issue of spatial plans at the local level. The aims of this paper are (1) extracting the characteristics of local spatial plans that can be compared more broadly (2) identifying, on this basis, the role of spatial plans at the local level in the countries of Central and Eastern Europe (CEE). In achieving these aims, the authors have critically examined spatial plans and their performance, as well as the planning systems they belong to. Hence, they have investigated the types of local plans in each country, their legal features, and the layout of their content. This examination has revealed a host of problems in the workings of the CEE planning systems. The article highlights those spatial planning issues that could be the subject of more in-depth international comparisons. The study provides additional evidence that in countries where spatial plans are legislated, there are more (mutually differentiated) legal problems in their application. Such problems have been analyzed. Besides procedural problems, discrepancies between the contents of different types of plans (e.g., general plans and detailed plans) are very often a problem. The paper also proposes a novel method for detailed comparisons of selected aspects of spatial plans. It can be applied to a large number of countries and also to other aspects of spatial planning. Last but not least, the paper emphasizes the need for a detailed multi-stage consultation of each aspect to be compared.

1. Introduction

The problem of comparing national spatial planning systems has been the subject of numerous studies. There is no doubt that comparisons, especially those involving a larger number of countries, are challenging and require great caution. Against this background, it is worth considering the particularities of spatial plans adopted at the local level. In most countries, these plans constitute the basic key instrument of spatial planning. Essentially, they delimit zones, define the parameters of development, and impose restrictions on development. However, we find different approaches across countries [1]. Thus, local plans have quite different legal formulations [2], varied objectives, different implications, as well as varying degrees of implementation. Notwithstanding these differences, there is an important debate in the scientific literature about the optimal formulation of such plans [3].

It classifies spatial planning systems in different ways. According to the authors, the distinction between restrictive and more flexible systems should be considered one of the most important [4,5]. There have been attempts in the literature to propose criteria on the basis of which systems can be classified [6,7,8,9]. It is important to emphasize that with broad comparisons it is difficult to obtain fully consistent categories [7,10]. Often, differences will come down to the way in which particular concepts are understood, as well as the embedding of these concepts in specific practices. Terminological discrepancies are therefore also a problem [1,11]. At the local level, spatial plans play, for the most part, a key role. Gielen and Tasan-Kok [2] indicate that one direction of the classification of spatial planning systems is plan-based and development-based systems. In plan-based systems, the findings of spatial plans are universally binding. Within the literature, spatial plans are subjected to various analyses (when describing them, one must bear in mind the diversity of perspectives from different countries). They concern diverse thematic spheres. The scope of the possible implementation of planning provisions and the issue of their integration with other instruments are often identified [12,13,14,15,16]. Attention is also paid to the relationship of spatial plans with selected environmental elements and nature [17,18], social issues [19,20], energy issues [21,22,23], and the real estate market [24,25]. A separate research direction is the detailed analysis of the legal dimension of plans, especially in the context of their translation into judicial decisions [26,27,28,29].

Specific approaches to spatial planning issues are found in the countries of the western part of the European Union themselves. A similar degree of diversity is also present in CEE countries. It is not only the differentiation resulting from the country’s membership in the European Union. Dabrowski and Piskorek [30] analyzed the determinants of planning systems (and their changes) in the New Member States. In their view, accession to the EU created a new context, especially for the strategic dimension of planning. Ondrejicka et al. [31] focus in this context on integrated planning, a tendency that is reflected across a variety of national literature [32,33]. This does not change the fact that often legal changes regarding planning systems have been superficial. However, Nadin et al. [1] recognize the increasing influence and openness of some CEE countries to the European debate. At the same time, Nadin and Stead [34] find CEE countries difficult to fit holistically into the classifications designed. Nevertheless, there are some attempts in the literature to do so [9]. Other comparative analyses also draw attention to the wider socio-economic context of national spatial policies [35]. Undoubtedly, in the group of countries identified, the historical context is very important, especially the long communist spatial planning tradition, which limited public participation and focused on compact urban development [36]. This was also manifested in the approach to urban construction, where, without regard to market conditions or potential conflicts, housing developments characterized by spatial generosity were erected. There are also differences in the development of agricultural land [37,38]. In the 1990s, Central and Eastern European countries began to implement new concepts of spatial planning. However, authors point out the different conditions of planning culture in new and old Europe [34]. Economic stability returned to most of the identified countries at the turn of the 20th and 21st centuries. The stimulus for change in most countries also became the prospect of accession to the European Union [30]. In addition, some authors present developed suburbanization, i.e., chaotic urban development on the outskirts of cities, as a frequent trend in these countries [39]. Thus, the common features of CEE countries include:

• A different approach to the market and conflicts in spatial planning (determined by the socialist planning tradition, the effect of which are still visible), characterized by the failure to provide fully adequate and coherent responses to the new economic context and to the tensions within these planning systems.
• Emphasizing the rights of property owners in the spatial planning system (related, in turn, to a specific rebound after the communist period).
• An incoherent response to intensive urbanization (including suburbanization)—especially in terms of adapting specific spatial solutions to this challenge.

The above theses are confirmed by the diagnoses in the national literature about the low effectiveness and poor use of spatial plans [24,31,32,40,41,42,43,44].

When comparing spatial planning systems, it is still difficult to compare national planning solutions. As postulated by Reimer et al. [8], a comparison of issues such as flexibility or micro planning practice is very valuable. However, such comparisons still remain at a rather general level. Hence, comparative studies choose between a general comparison across countries, including a larger number of aspects [1], or a more elaborate description of certain features found across national systems, but with less detailed comparisons [9]. Sometimes, individual countries are also compared [2]. What is lacking is an in-depth comparative analysis of the more specifically defined features of national spatial planning systems. The reason for such an omission is legal, practical, and terminological discrepancies. Furthermore, analyses of spatial plans should be treated separately, with in-depth comparisons lacking as well. Such comparisons involve an interdisciplinary approach, ranging from a skillful definition of legal consequences to a careful translation into planning practice. This type of analysis is particularly lacking in Central and Eastern European countries. Despite attempts at comparisons [9,35], there is no synthesis of the detailed similarities and differences in the spatial planning systems of the individual countries. This is especially true when studying spatial planning instruments.

The aim of this paper is to fill in this literature gap by (I) extracting the characteristics of local spatial plans that can be compared more broadly, and (II) identifying, on this basis, the role of spatial plans at the local level in the countries of Central and Eastern Europe (CEE). Subject to the necessity of caution in comparisons, it was considered possible to verify several issues across all CEE countries. Based on these issues, the authors determined the position and the formula or spatial plans across planning systems, the consequences of plans (legal, urban), as well as the relationship between plan features and problems within national planning systems, while always considering both the normative and practical dimension of planning. This includes the identification of key issues related to local spatial plans in the countries studied. Of particular importance is the identification of common trends. The paper also attempts to align the spatial planning systems of Central and Eastern Europe with the groups of plan-based and development-based systems identified in the literature.

The novelty of the article lies in:

• jointly identifying and comparing the features of local spatial plans in Central and Eastern Europe;
• extracting the features of local spatial plans that can be compared in the countries studied;
• to identify and compare problems related to the application of local spatial plans;
• to determine how the features of local spatial plans can be compared, despite differences in terminology, features of planning practice, and legal solutions in the countries studied;
• to relate the results to the scientific discussion on the classification of spatial planning systems and the role of spatial plans.

Thus, the article is structured as follows: In the Introduction, the authors introduce concepts pertaining to the classification and comparison of spatial planning systems, as well as the perception of the role of spatial plans at the local level. The historical and current conditions of CEE countries are also characterized. After explaining the methods used, results on the role of spatial plans are presented. The discussion relates these results to the key theses of the literature on the subject. The text concludes with a summary with formulated conclusions.

2. Methods

All Central and Eastern European countries were selected for the study (Figure 1). The selection of countries is justified by the classifications in the literature [45,46]. Undoubtedly, they share similar historical conditions in the second half of the 20th century, which are still reflected in their current spatial planning practices. Of course, there are major differences from one country to another. These range from more specific historical circumstances, to surface areas, to political systems. However, one has to agree with the position that the common features (geographical and socio-historical) provide a serious basis for comparison [34,35]. This group also includes countries outside the European Union: Ukraine and Belarus. Previous publications [29,47,48] show that, despite numerous different systemic and political conditions, a large part of the problems related to spatial planning itself is comparable (at least within the scope of this article). Furthermore, the study of Tosics [9] shows that the CEE Member States of the European Union have comparable relations between the arrangement of power at the local and national levels.

When comparing national spatial planning systems, the authors kept in mind the theses within the literature, especially the fact that it is very difficult to form a comprehensive comparison of most elements of the individual systems. Therefore, they decided to focus on one aspect: the role played by local spatial plans within the system. The dedicated literature shows that spatial plans are the key instrument used in urban and regional planning. Obviously, spatial plans have slightly different applications, depending on the planning system they operate in. Therefore, it seems important to verify the basic features (legal, implementation) of spatial development plans in CEE countries.

The authors representing each country completed specially prepared questionnaires. In answering the questions, the authors relied on the spatial planning legislation and literature of their country. Thus, both legal acts and key publications on the spatial planning systems of Belarus [49,50], Bulgaria [40,51], the Czech Republic [52,53], Estonia [54,55,56], Hungary [57,58,59], Latvia [60,61,62,63,64,65], Lithuania [66,67,68], Poland [69,70], Romania [71,72,73,74,75], Slovakia [76,77,78], and Ukraine [79,80] were used in developing the results. They also used their own knowledge and experience in spatial planning. The authors have worked with the consolidated versions of planning and other laws, the point of reference being September 2021. The main idea behind the questionnaire was that comparing spatial planning regulations is not enough, and that related planning practices are also relevant for this study. Hence, the survey questions in the first round were:

• The basic characteristics of spatial plans at the local level in each CEE country, including how many types there are—this is justified by the need to properly translate the content of detailed plans into planning practice.
• Whether spatial plans are binding regulations or non-binding instructions—this distinction is relevant, among others, when distinguishing between plan-based and development-based systems.
• Determining whether local authorities are required to adopt spatial plans for all areas or not—this determines the actual application of plans in each country (which may be different from statutory regulations). It is worth noting that the national literature regards the legal dimension of plans and the obligation to adopt them as key criteria [81].
• Detailing the content of spatial plans, especially that of general plans. This is another point to consider when answering the question of how the provisions of the plans affect land.
• An indication of the key values within different national spatial planning systems (declared in the national laws on spatial planning)—these values are not always sufficiently protected in practice. It is nevertheless useful to identify the legislator’s general point of view, which can then be verified by an analysis of the literature on the subject.
• Brief reviews of the national literature on the problems observed in different spatial planning systems—this study did not portray the broader dynamics of changes within spatial systems. Doing so would have introduced even more terminological discrepancies in relation to the research assumptions. Nevertheless, it was considered that a possible accountable reflection on the dynamics of systems change was a discussion of their problems. Diagnosing specific problems in the national literature provides a rationale for change. It may be added that in some countries, such diagnoses are far more relevant than the changes contemplated at the statutory level (Figure 2).

In addition, the selection of the topics identified also considered discussions on the classification of European planning systems. For example, the European Compendium focused on the extent of centralization and the possible legal nature of plans. The literature review shows how important these elements are and how they form the planning system (irrespective of the discussion on planning ‘families’).

In the second and third rounds, the authors were asked to refine the answers selected by the first author. In this way, it was possible to standardize the answers.

It must be stressed that even similar trends must be presented with the caveat that, when considering detailed solutions/stipulations/interpretations of regulations/planning practice, divergences are not excluded. The authors are fully aware of these divergences. In addition to the differences in planning culture, the varying role/establishment position of local government units at the local level, the varying construction law regulations, as well as the varying scope of investment projects can be pointed out here. The size of the basic local government unit and its population is also a differentiating factor. Being aware of such differences, the authors also took directional tendencies into account, when comparing so many countries. The plans were analyzed primarily from the perspective of public policies in terms of the role played at the local level. From this perspective, the additional discrepancies that exist between countries (related, for example, to the size of municipalities, the number of inhabitants, and the details of the interpretation of the law) must and should be the subject of further research. However, this research already lies beyond the scope of this article. In addition to examples of these trends, the results provide numerous examples of detailed solutions and practices. These are meant to broaden the context of the discussion and open the way for even more in-depth analyses in the future. However, such reservations do not change the fact that, within the scope of the above-mentioned issues, it is possible to present some common trends for all the countries of Central and Eastern Europe.

Concerning the term “spatial planning”, the authors assume that it is a process of organizing territory, land use, and managing competing interests, thereby following Nadin et al. [1]. From this perspective, the purpose of spatial planning is to guide development while ensuring environmental protection, and land conservation, as well as involving local communities. However, the authors signal a varied understanding of the term. Spatial planning is an important lever for promoting sustainable development and improving the quality of life [82]. Spatial planning involves attempts to plan processes of social, economic, and environmental change to bring about certain ends, together with drawing up plans, maps, or diagrams that indicate where social and economic activities should take place [83].

Spatial plans at the local level are essentially a basic instrument of spatial planning. It is important to underline the different terminology used both in different disciplines and in various countries. Therefore, for the purposes of this article, the term “spatial plans” is used. The authors understand spatial plans as plans that (I) specify the purpose of a given area (i.e., the direction in which the area is to be used) and (II) provide more detailed parameters for the development of the area (e.g., the height of development or the intensity of development). This group does not include “spatial development plans”. It should also be emphasized that the understanding of the term “land use plans” varies. There is no doubt that they are understood as something narrower than spatial plans. However, there are different concepts as to their content. Therefore, using the concept of “spatial plans” in the sense presented above seems to be the optimal solution for the purpose of comparison. In addition, two categories of spatial plans at the local level should already be distinguished:

• Plans, which for the purposes of the article we refer to as general plans (general plans);
• Plans, which for the purposes of the article we refer to as detailed plans (detailed plans).

This classification does not exist in every country studied. There are states in which there is only one type of plan (including features of a general and a detailed plan). There are also states in which, in addition to the general plan, there are more categories of plans. Nevertheless, when averaging, one must conclude that the point of reference for analysis is the separation of these two broad categories. The primary role of the general plan is to determine the use of land—land function—land zoning. The primary role of the detailed plan is to specify/complement/develop the provisions of the general plan.

3. Results

The first stage of the analysis is to identify key values and problems in each national spatial planning system (

Table 1. Key values and main problems in national spatial planning systems at the local level.

State	Values/Goals of the Spatial Planning System as Expressed in Laws	Problems of the Spatial Planning System, Based on the National Literature and Experiences on the Subject
Belarus	- protection of the environment, nature, and cultural values; - Aesthetic living environment; - Citizens’ right to rest and recreation in suburban areas and green areas of cities;	- Lack of integration between planning documents and other strategic/sectoral documents; - Complexities of planning documentation transition into the implementation stage; - Lack of implementation for the provisions comprised within spatial plans; - Shortage of financial resources at the local level.
Bulgaria	- Conceiving space as a national treasure; - Sustainable development; - Taking care of favorable conditions of work and rest.	- Plans are not adapted to socio-economic dynamics; - Lack of implementation for the provisions comprised within spatial plans; - No clear vision for the sites; - Weak social activity and participation.
Czech Republic	- Sustainable development; - Reconciling private and public interests; - Considering the social and economic potential for development.	- Extremely small size of municipalities. Problems in defining the competences of the smallest municipalities; - Lacking methods for evaluating competing public interests; - Cumbersome planning procedures; - Lack of coordination between different spatial plans, as well as a weak role for regulatory plans; - Challenges with digitization; - Too many legal changes; - Inefficiency of public authorities in spatial planning.
Estonia	- Environmental protection; - Sustainable development; - Democratic long-term spatial development; - Considering the needs of the entire community; - Forming/(or providing) a high-quality living and built environment.	- Complications in the content of the general plan (caused by the recent administrative reform); - Challenges with digitization.
Lithuania	- Sustainable development; - Environmental protection, preservation of both nature and landscape; - Rational urbanization; - Ensuring compatibility between different levels of spatial planning; - Quality of urban development.	- Balancing public and private interests (and the difficulties involved).
Latvia	- Sustainable development; - Quality of the living natural environment. - Sustainable, efficient, and rational use of territories, as well as other resources; - targeted and balanced economic development; - integrated approach—economic, cultural, social, and environmental aspects are coordinated, etc.	- Laws and regulations change too often; - Sectoral approaches are not well coordinated. - Even though awareness-raising is increasing, the methods of public participation used do not provide for in-depth dialogue; - The provisions of spatial plans are often not implemented.
Poland	- Spatial order; - Sustainable development; - Environmental protection, preservation of both nature and cultural heritage; - Protection of the public interest.	- Spatial chaos; - Weak role of spatial plans; - Problems with terminology; - Inefficiency of public authorities in spatial planning; - Failure to protect the public interest; - Procedural problems.
Romania	- Territory as (national) wealth, which is subject to spatial management; - Sustainable development; - Protection of the public interest;	- Procedural inconsistencies; - Discrepancies between the contents of different types of plans; - Constant changes within the planning law; - Underdeveloped flexibility in planning.
Slovakia	- Harmonization of all spatial planning activities; - Environmental protection, preservation of both nature and cultural heritage; - Sustainable development; - Safeguarding the ecological balance.	- Limited scientific debate on urban planning; - The Building Act is 46 years old, from the former Czechoslovakia, updated through Amendments (43 since 1990); - Challenges with digitization; - Same type of general plan for both the capital city and a small village; - Questionable flexibility of plans, due to slow and long planning procedures.
Ukraine	- Sustainable development; - Environmental protection, preservation of both nature and cultural heritage; - The ecological security of individual sites.	- Low level of planning documentation; - Poor translation of planning documentation into the realm of implementation; - Numerous abuses and corruption; - Old plans that are not adapted to the current development challenges.
Hungary	- Territorial cohesion; - Sustainable development; - Harmonious [Coordinated] development of the spatial structure; - Environmental protection, preservation of both nature and the cultural heritage, (national and regional identity).	- Inadequate relationships between different plans; - Lack of cooperation between local authorities; - Lack of financial resources at the local level; - Ineffective environmental assessment of plans; - Poor public participation.

Source: Own Studies.

). This will provide some insight into the determinants of spatial planning systems in the countries studied. The values were identified based on national spatial planning laws, whereas the problems were based on national literature reviews and the authors’ own scientific and practical experience.

The declaration of certain fundamental values in the Act on spatial planning and development does not always translate into actual implementation. Hence, in some countries, in addition to the classic values, such specific actions are also visible. However, these differences are not very considerable. Moreover, the reference to specific values at the beginning of the Act is an expression of the legislator’s concept of the spatial planning system. Even if these values are not applied to a significant extent in national planning practices, they still provide a certain point of reference (for example, when interpreting individual provisions). Table 1 shows that there is a high degree of congruence between values across CEE countries. These are primarily sustainable development (10 countries) and environmental protection (7 countries referring explicitly to it), as well as the preservation of cultural heritage (7 countries). In a significant number of countries (5 countries), the value of space itself is also emphasized. It is presented in various ways (even “space/territory” as the “national treasure” of one country). However, it can be reduced to understanding space as a public good, with different values, and, as such, being subject to protection. The requirement for such protection is linked to the protection of public interest in spatial planning. This aspect is explicitly addressed in the legislation of three countries, but for some of the others, a similar assumption follows from other guidelines (e.g., “integrating the needs of the entire community” in spatial planning in Estonia, “improving the quality of life for all inhabitants” in Lithuania, and “lasting harmony of all spatial activities” in Slovakia). In Poland, where the public interest in spatial planning has been explicitly articulated by the legislator, the concept of spatial order has been introduced as a target, ideal state of spatial development.

The other values invoked are varied. There are also less typical approaches. Belarus, for example, postulates preferential living conditions for rural areas (in the construction of residential buildings and social and cultural facilities per capita in relation to urban areas), at the same time emphasizing the recreational dimension of suburban zones. In Bulgaria, the legislator also refers to the leisure of the population, postulating the introduction of favorable conditions in this area, as well as favorable working conditions. Lithuania emphasizes the need for consistency between the different levels of government that are responsible for spatial policy. Hungary refers to territorial cohesion.

The second issue included in Table 1 comprises the key problems faced by individual planning systems. The most common are procedural problems related to the preparation of new spatial plans (five countries). Legal and procedural problems are absorbing and often distract attention from the main spatial planning activities. These main activities include the implementation of planning provisions. The problems are that these provisions are often not implemented (Bulgaria) and there are discrepancies in terminology between the different parts of plans. These discrepancies may concern the different contents of one plan (Estonia) as well as inconsistencies between different types of plans (Czech Republic, Romania, Hungary). The problem may lie with frequent changes to the zoning law (Czech Republic, Romania), as well as the system being too strongly rooted in old legal and planning practices (Slovakia, Ukraine). In three countries, there are explicit problems with the protection of public interest in spatial planning practices, and in five countries there are problems with the local authority’s approach to spatial planning. Four countries mention the need (and challenges) to digitize spatial planning. Against this background, it is also worth highlighting the challenges related to Europeanisation (Bulgaria), poor planning flexibility (Romania, Poland), and the need for complex green infrastructure development plans (Hungary).

The next issues analyzed by the authors were the role of local authorities in spatial planning and whether the spatial plans are universally binding legal acts (

Table 2. Planning autonomy of local authorities and the legal dimension of spatial plans at the local level.

Issue	Explanation
The role of local authorities in spatial planning	Local authorities have planning autonomy. However, the degree of autonomy may be limited by higher-level authorities.
Exceptions	Planning autonomy at the local level is declared in every country. However, there are some countries where it is weaker in practice (Belarus).
Are zoning plans universally binding legal acts	Yes, in all countries
Exceptions	No

Source: Own Studies.

).

The values of sustainability, environmental protection, and balancing public and private objectives were most frequently referred to in the laws of the countries surveyed (Figure 3). The indicated values are strongly interlinked. However, they do not fully exhaust the range of issues relevant from a spatial planning perspective. The different values are already expressed in more diverse ways. The issues related to balancing private and public perspectives in spatial planning are very important. They also include the context of responding to spatial conflicts, as well as defining the tasks of public authorities. Sustainability and environmental protection are strongly linked. However, it is right to separate environmental protection. This is important if only from the perspective of the need to respond to climate change.

A separate comparison needs to be undertaken of the legal problems relating to spatial plans (Figure 4). These occur in each of the countries studied and are very similar. From a national perspective, they are framed in different ways. In some countries, the main problem lies in the difficulty of legally coordinating the content of different planning acts. In other parts of the countries, much more attention is paid to the implementation of planning provisions (the extent of this implementation is questionable). Nevertheless, the two types of problems are similar. They confirm the existence of barriers when matching the legal perspective and the urban planning perspective. This translates into difficulties in the implementation sphere, noticeable in each of the cases studied.

In all surveyed countries, spatial plans at the local level are generally binding legal acts (having specific effects on property owners/investors). Of course, the specific provisions of the plans in Europe vary from country to country. However, this does not change the fact that in some planning systems plans are not legal acts. This trend does not exist in Central and Eastern Europe. Plans are defined as general, and although they are the basis for detailed plans, at the same time they may (to a varying extent) constitute an independent basis for the implementation of investments. This topic is developed in

Table 3. Types of spatial plans at the local level and the obligation to adopt them.

State	Types of Spatial Plans	Determining Which Plans Should Be Adopted on a Compulsory Basis
Belarus	- General (генеральный план); - Detailed (детальный план); - Special (специальный план);	General plans
Bulgaria	- General (oбщ устрoйствен план), - Detailed (пoдрoбен устрoйствен план).	General plans
Czech Republic	- General (uzemni plan) - Detailed, or so-called regulatory (regulacni plan);	No obligation to adopt plans
Estonia	- General/comprehensive (üldplaneering), - Detailed (detailplaneering).	General plans. Detailed plans are mandatory in densely populated areas, in case of development
Lithuania	- Comprehensive (bendrasis), - Detailed (detalusis).	General plans
Latvia	- General (teritorijas plānojums), - Local (lokālplānojums), - Detailed (detālplānojums).	General plans. The detailed plan is mandatory in the cases specified in the spatial plan (general), in the local plan, as well as in cases specified in the regulations.
Poland	- One type of plan (miejscowy plan zagospodarowania przestrzennego);	No obligation to adopt plans. There is one plan at the local level which contains both general plan elements and detailed plan elements.
Romania	- General (planul urbanistic general), - Zonal (planul urbanistic zonal), - Detailed (planul urbanistic de detaliu).	General plans. Zonal and detailed urban plans are only mandatory in specific situations, outlined in the general urban plan or in the planning law.
Slovakia	- General (územný plán obce), - Detailed (územný plán zóny).	General plans are mandatory for communes with more than two thousand inhabitants
Ukraine	- Comprehensive (кoмплексний план прoстoрoвoгo рoзвитку), - General (генеральний план), - Detailed (детальний план).	General plans and detailed plans
Hungary	- One comprehensive plan (településterv) from 2021: the former two types of plans are united into one comprehensive plan Formerly: - local development concept (településfejlesztési koncepció) - local spatial plan (land use plan) (településrendezési terv). A new regulation unites these plans defining a general plan.	No separation between the general plan and the detailed plan.

Source: Own Studies.

A conclusion can also be drawn that (apart from Belarus) the surveyed countries apply the principle of the planning independence of local authorities. This means that local authorities should, as a rule, decide to the greatest extent on the designation and principles of development for individual areas. The basic instrument here is, of course, the spatial plan. Obviously, this authority is not absolute. On the one hand, it is limited by the legal framework of a given system (especially the understanding of the rights of property owners and investors), while on the other, it is influenced and sometimes restricted by the actions of regional and national authorities. In each of the surveyed countries, except for Poland, at least for the time being, there is a document at the national level defining the directions of spatial development. National authorities are also involved, directly or indirectly, in the spatial policy concerning (I) public investments that are key from their perspective, and (II) the protection of valuable assets. Therefore, they may impose certain planning provisions on local authorities. Amongst countries with planning autonomy for local authorities, this problem is particularly acute in Hungary, where certain land uses are often imposed from a national perspective. In Belarus, local authorities are rather the initiators of actions dedicated to spatial policy, which are then approved at a higher level of public authorities, this being related to the general status of municipalities in Belarus.

As the next issue, the authors analyzed types of spatial plans on the local level in all CEE countries and determined which of these plans should be adopted on a compulsory basis (Table 3).

Most of the countries studied have two types of local plans (Table 3). In five countries, spatial plans are of two types: a general plan and a detailed plan (obviously with different terminology and scope). In four countries there are three types of plans, and in two countries there is only one type. The option of distinguishing between three types of plans is sometimes chaotic, especially when differentiating the roles of two types of plans that are not general plans. We should highlight the example of Ukraine, which is amid a long process of change, in which general and detailed plans are still in force. At the same time, comprehensive plans are being adopted, of which general and detailed plans will be parts. To put it another way, Ukraine is departing from a system with two types of plans and heading towards one type of plan, while at present employing three types of plans. Problems also arise where there is only one type of plan, such as in Hungary or Poland, if one does not include typical development plans.

The problems described above, to which we shall return in more detail below, do not alter the fact that, according to the law, in eight countries, at least general spatial plans must be enacted throughout the country. Therefore, at least from a formal and declarative point of view, a spatial policy is applied throughout these countries. In Slovakia, spatial plans are mandatory for municipalities with more than 2000 inhabitants, while in other areas, investment projects also require a plan. In the Czech Republic, spatial plans are optional, but enacting a plan at the local level is linked to the possibility of obtaining a state subsidy for technical infrastructure. Consequently, plans are in force in 95% of municipalities. The worst situation is in Poland. The plans are optional and apply to a mere 31% of the country’s area.

As the next issue, the authors analyzed the specific relationship between the different spatial plans at the local level in the countries studied. These relationships were determined directionally by (I) determining whether general plans provide a sufficient basis for investment, and (II) determining which investments the detailed plan refers to. However, the treatment of these issues has been adapted to the specificities of each national system. (

Table 4. Country-specific issues in determining the interdependencies and consequences of enacting spatial plans at the local level.

State	Specific Issues of Enacting Spatial Plans at the Local Level
Belarus	General plans are a sufficient basis for investment, The detailed plan is drawn up based on the general plan in force, the solutions of which specify and make concrete the functional purpose, planning organization, and development of the projected area. Detailed plans are technical regulations. They are subject to compulsory execution. Detailed plans could be enacted at the request of investors.
Bulgaria	General plans are not a sufficient basis for investment. Detailed plans are necessary to execute the investment. Detailed plans address specific projected investments. In a situation where a general plan is not enacted (despite such a legal obligation), a detailed plan may be enacted (this is the original legal trick). This results in bad practice and inadequate coordination of instruments and policies at the local level.
Czech Republic	General plans are a sufficient basis for investment. The detailed plan sets comprehensive plot regulations. It must respect the general regulations comprised within the general plan. Regulatory plans are very rarely enacted, as they do not bring sufficient benefits for investors. When adopting general plans, municipalities can obtain grants for technical infrastructure. Public investment can be realized exclusively in municipalities having valid general plans. Private investment can be realized either in areas that are built up even without a general plan and/or in areas designated for development in the general plans. Outside these areas, one cannot carry out investments.
Estonia	General plans are a sufficient basis for investment. A general plan must be adopted for all municipalities. A detailed plan is adopted only in densely populated areas. In the remaining areas, the provisions of the general plan are sufficient for the implementation of investments. A detailed plan has several (22) functions. It specifies the division of plots, while at the same time defining the possible location of buildings, infrastructure, as well as traffic arrangements. It also contains conditions for planting vegetation.
Lithuania	General plans are a sufficient basis for investment. If a detailed plan does not apply, development may be carried out under the general plan. It should be stressed that the plan at the national level is also a legally binding act.
Latvia	General (spatial) plans, enacted according to sustainable development strategies, form a sufficient basis for carrying out investments, except for the cases when a detailed plan is mandatory. Local plans, developed for a part of the city, for a town, a village, a rural territory, or their parts: 1) solve a planning task or expound on the general spatial plan, and 2) amend the functional zoning of the general plan during the planning process, thereby finding an appropriate land use for the investment. Detailed plans are developed to lay down the requirements for land use and building parameters, as well as to adjust the borders of land units and restrictions. In addition, they describe and specify zoning and building regulations for each land unit. General plans at the local level are in force for the whole country, so investment in almost all cases is based on one of the spatial plans—general, local, or detailed—with the exception of national interest investments, such as military infrastructure, railway infrastructure, etc., when the Cabinet of Ministers approves them.
Poland	Spatial plans are a sufficient basis for investment. Plans are in force for less than 30% of the country’s area. Spatial plans in Poland combine features of general plans (designation of zones) and detailed plans (determination of detailed development parameters). In the remaining part of the country, administrative decisions (decisions on development conditions) are the basis for investments (also private ones). This results in bad practices.
Romania	General plans are a sufficient basis for investment. General urban plans are mandatory at the LAU2 level (i.e., commune, town, or city). These plans contain both short-term provisions (i.e., zoning and building regulations), as well as medium- and long-term provisions (i.e., strategic interventions). Hence, general urban plans are both regulatory and steering in character. Zonal urban plans refer to zones, thus being more detailed than general plans. They are regulatory in character and are more detailed than general urban plans. They either contain finer-grained zoning and building regulations, or they modify the regulations of the general urban plan, within legally defined thresholds. Both general urban plans and zonal urban plans come with an action plan, dedicated to their implementation, as well as with a public investment program.
Slovakia	General plans are a sufficient basis for investment. General plans (local land use plans) are a sufficient basis for investment, as they cover all aspects, including regulations and strategic investments. They are approved by the local council in the form of generally binding regulations. Zonal plans refer to zones and are more detailed than general plans (contain detailed regulatory plans of a zone). In general plans (local land use plans) a need/requirement for a zonal plan is expressed. Some strategic public investments can be undertaken without plans adopted at the local level. In such cases, regional plans are the point of reference.
Ukraine	General plans are a sufficient basis for investment. Detailed plans elaborate on general plans. Detailed plans may act as an alternative to general plans if the latter is missing. In connection with the administrative-territorial reform, the role of plans is changing. The main spatial planning document will be a comprehensive spatial development plan. It will include both general and detailed plans. There is also the possibility of implementing part of the investment without plans, in case local authorities are unable to develop spatial plans.
Hungary	Spatial plans are a sufficient basis for investment. The spatial plan, understood as the land use plan, is complex. It defines the settlement structure and settlement regulations and acts as the basis for the local building code. Starting in 2022, a reform will unite the two planning documents (development concept and land use plan) into a general plan at the local level. The comprehensive plan includes the development plan, development action area, and regulation plan, thereby acting as the basis for the local building code.

Source: Own Studies.

).

The meaning of mandatory general spatial plans in most countries does not exhaust the characterization of possible plan roles across individual planning systems. Therefore, Table 4 shows the various problems concerning the interdependence between different types of plans and the consequences of their adoption, with these two issues being very strongly linked. In most countries, investments can be carried out solely based on general plans. The case of Estonia should be emphasized here, where a detailed plan may only be adopted in densely populated areas. There is an interesting situation in Bulgaria, where general plans are not enacted everywhere, despite a formal obligation to do so, there being the possibility to enact detailed plans for individual investments. However, this procedure should be treated as a kind of circumvention of spatial policy requirements. An even more dubious situation occurs in Poland, where, in an area without a spatial plan, an administrative decision applies: the decision on outline planning and spatial development. It also applies to individual investments and allows for their very extensive implementation, usually based on subjective criteria. In Lithuania, it is possible to use spatial development projects, approved by the director of the municipal administration, instead of plans. The possibility of carrying out investments without plans also exists in Slovakia and Ukraine. In Slovakia, however, it refers to key public investments (by the way, a similar solution can also be found in Poland, through the so-called specustawy—special laws which enable the implementation of investments outside of spatial planning). In Ukraine, the developers have the possibility to force the execution of investments in areas not covered by the plans by filing claims in the courts.

In some countries, despite the formal obligation to do so, there is a problem with adopting general plans. In Bulgaria, even when the parliament forced municipalities to adopt general plans, enactment is still lacking. There is also the obligation to adopt new general plans (until 2025) for united, newly created municipalities in Latvia, following the administrative-territorial reform of 2021. In Romania, on the other hand, plans are in force but are often completely outdated, partly because their updating is a long and bureaucratic process [75]. In addition, it should be noted that Ukraine and the Czech Republic are undergoing major legal changes within their spatial planning system.

As the next issue, the authors analyzed key elements of the content of general plans (

Table 5. Content of general plans at the local level.

State	Content of the Plan
Belarus	Approving part: general plan, basic provisions of territorial development, urban planning regulations; justifying part: strategic plan, base plan, historic and cultural plan, environmental diagrams and schemes, zoning scheme, infrastructure diagrams and schemes (transport and engineering), the description of typical street cross sections, explanatory note.
Bulgaria	Description of the settlement structure, inclusion of territories, technical infrastructure requirements, the impact of the provisions for the environment and cultural heritage, the description of the principles for implementing these provisions.
Czech Republic	Land use, built-up area contours, protection zones for protected areas, proposals for nature and landscape protection, contours of the agricultural land and forest land funds, spatial order regulations, conditions/restrictions for land use (development parameters), public investment map (expropriation purpose).
Estonia	Spatial principles of the entire municipality, directions of settlement development, general location of transport networks and other infrastructure, land development, location of waste treatment sites, development exclusion zones, culturally valuable areas, development and building conditions, noise levels, minimum plot size.
Lithuania	Land use, separation of residential area system, requirements for the protection of forests, protected areas and landscape, natural framework system, requirements for activities within protection zones, development principles for engineering and social infrastructure.
Latvia	On the development of space/territory on the local level, in LV we have two interrelated plans—sustainable development strategy containing vision, strategic goals, and spatial perspective—settlement structure, spatial structure of natural areas, main transport and infrastructure corridors, areas of landscape value, cultural and historical significance, priority development areas and guidelines for spatial planning and general plan, developed according to the sustainable development strategy, including functional zoning, building and land use regulations, public infrastructure and transportation guidelines, determining areas with special provisions and village boundaries.
Poland	Spatial plan: land use, demarcation lines between areas with different uses, principles of protection and shaping of spatial order, environment, nature, landscape, cultural heritage, development parameters.
Romania	Development guidelines or goals for the entire municipality (infrastructure, economy, transportation, land reclamation, and land use), zoning and building regulations, utility easements, and other restrictions.
Slovakia	Urban planning concept of the spatial layout, land use, delimitation of contours of the built-up area, protection zones for protected areas, proposals for nature and landscape protection, contours of the agricultural land and forest land funds, spatial order regulations, conditions/restrictions for land use (development parameters), delimitation of protection zones for protected areas.
Ukraine	Development guidelines for the entire municipality, zoning and targeted use of the land, public services, road, engineering, and transport networks, principles for land and environmental protection, guidelines for the creation of an ecological network, principles for the protection of cultural heritage.
Hungary	In Hungary, recently, one comprehensive plan was introduced but the local development plan and land use plan still exist in parallel. The comprehensive plan defines the development plan with long-term development goals, development action areas, the regulation plan with land use zones and types of basic activities. It defines the rules for technical infrastructure, environmental protection, open spaces, and distinguishes newly developed areas and areas requiring special attention.

Source: Own Studies.

).

Determining the role of spatial plans at the local level in different national systems will also be easier once their content has been reviewed. Again, the basic point of reference comprises statutory guidelines. Table 5 shows the different approaches to spatial plans across the countries surveyed. It is worth noting that the contents of the general plan also vary across the countries. Hence, in systems where development orientation plays a more important role (Latvia, Hungary), the contents duly refer to this topic. Nevertheless, common trends can be found. In most cases, it is possible to distinguish a plan that can be classified as general. In countries where there is only one type of plan, it is this type that is also associated with the general plan formula. It is on the content of this particular type of plan, or a plan as close as possible to it, that we shall focus. This is because it determines the planning system at the local level to the greatest extent, obviously subject to the differences and specificities presented in Table 3 and Table 4. While the content of plans is diverse, the focus lies with those parts of plans which have a regulatory dimension.

Three recurring provisions were identified in this type of plan:

• The separation of zones/functions of the site,
• The definition of technical infrastructure guidelines,
• Reference to the environmental and cultural values of the area.

As indicated, these issues are addressed in detail in different ways, both in terms of terminology and scope. For example, in Lithuania, the general plan specifies social infrastructure in addition to engineering infrastructure, and in Latvia, it is public and transport infrastructure. In Ukraine, the plan specifies the road, engineering, and transport networks, while in Hungary, the technical infrastructure networks that determine the settlement structure of a given area are specified. Even greater discrepancies can be found in the inclusion of environmental and cultural issues in the plans. The plans in Bulgaria specify the impact on the environment and cultural heritage, the plans in Estonia designate natural objects and culturally valuable objects that need protection, and the plans in Lithuania state requirements for the preservation of forests, protected areas, landscape, and the natural system. The plans in Poland specify principles of environmental and nature protection, as well as principles for cultural heritage protection, which are difficult to specify unambiguously.

Notwithstanding all of the above, more original provisions can also be found in individual general plans. The plans in Estonia, the Czech Republic, and Lithuania set out development and exclusion zones. The plans in Estonia also set out permissible noise levels. The plans in Slovakia refer to an agricultural land fund and a forest land fund, while the plans in Ukraine characterize the public service system. The Hungarian plans, on the other hand, set long-term (15–20 years) development objectives. The same observation applies to Slovakia as well, where the plan is a long-term document that should be revisited every 4 years, according to the law.

As indicated, the other (non-general) types of spatial plans at the local level are even more mutually differentiated from country to country. Their common task is to clarify the provisions of the general plans. This may consist either in specifying detailed development parameters for specific sites, or in specifying detailed development parameters for specific investments (for example, allowing detailed plans to be drawn up for individual investments in Bulgaria usually leads to the circumvention of basic planning instruments). Sometimes, it will be a clarification of parameters included in general plans; sometimes, it will be a comprehensive determination of these parameters, when they are not included in general plans. In Romania, detailed plans are mainly used in cases where specific parameters (geometry of the plot, access to the property) require a more extensive analysis. Individual solutions can also be singled out. In Belarus, detailed plans have specific deadlines for the implementation of investments (similar to, e.g., spatial plans in Poland before 1984). In Estonia, detailed plans specify, among other things, the principles for planting vegetation and ways of limiting crime.

It can be added that in some countries, the spatial planning system is either being implemented or changed. This is particularly the case in Hungary, where a system with general plans takes shape, Latvia, where a much more flexible system is being considered, in Poland, where, according to government proposals, general and specific plans are also to be introduced, as well as in Slovakia and in the Czech Republic. Ukraine finds itself during a lengthy process of legal change. Within our sample, Latvia, Hungary, and Ukraine endeavor the strongest attempts at linking plans with development. This particular trait is reflected in their wider association with development documents.

4. Discussion

In a nutshell, common features and key differences in the group of studied countries were identified. The countries of Central and Eastern Europe should be regarded as an important case study worthy of further analysis. Until 1989, 1990, or 1991, these countries had a socialist regime [84], which implied a specific understanding of spatial planning [35]. Under the socialist regime, spatial plans depended on the extra-territorial expectations of the public authorities, respectively, the communist party. Consequently, provisions in parts of the plans were the result of pressure from public authorities. Spatial planning was centralized and top-down—plans were elaborated by the state institutions according to political party settings without any public consultations. It was also often the case that more substantive planning provisions were not implemented, for example, public participation, environmental protection, etc. [85]. There was also a certain problem with plans specifying deadlines for the implementation of individual investments (impossible deadlines). In the 1990s, the belief that the market would solve all problems was very strong in the countries studied. These and other conditions influenced societies’ specific approaches to spatial planning after 1989. It was often treated as a relic of a bygone period. It took a long time to change this way of thinking. In the 1990s, these countries therefore had to take a new approach to the concept of a spatial planning system. For most countries, the accession (at a similar time) to the European Union was also an important factor [30].

The contribution of our study to advancing the commonly agreed body of knowledge in the planning field is threefold. Firstly, its purpose of identifying similarities and differences related to the role of local plans within planning systems is very important [1]. Despite numerous discrepancies, local plans are recognized in many systems as key instruments in spatial planning. It is their formulation and their contents that influence the territory of a country to a significant extent. By identifying the similarities and differences between plans in different countries, we define a realistic planning framework and highlight opportunities.

A critical comparison of spatial plans in such a large number of countries may be considered innovative. Until now, comparisons have either been limited to a smaller number of countries or reduced to separate descriptions of individual countries, without attempting more in-depth comparisons. A major handicap is not only the diversity of national spatial planning systems but also significant methodological differences. Nevertheless, the research has identified those issues related to spatial plans that can be the subject of critical analysis in other countries as well, which we believe is a helpful contribution to further discussions. It seems that the classification of plans, the determination of their legal formulae (legal effects and binding character), the influence of supra-local authorities on the spatial plan, as well as the contents of the plans are criteria that may constitute a basic point of reference in other studies [29]. Linked to the diagnosis of spatial planning problems at the local level, these analyses allow a broader understanding of the relationship between the way a plan is formulated, its characteristics in a given country, and the spatial planning system it belongs to [34]. The research draws the important conclusion that giving spatial plans a legal dimension generates legal problems [8]. However, these vary from country to country: On the one hand, there are procedural issues, while on the other, there is the sometimes complicated relationship between different types of plans. The latter is a very promising research avenue, as discrepancies between different types of plans partially block the implementation of the spatial planning system’s objectives. They also provide a basis for exacerbating bottom-up abuses and overinterpretations. Consequently, these legal problems significantly impede (in many of the countries studied) the achievement of the stated objectives in the spatial planning system. It can be added that the intensity of these problems is broader than in other parts of Europe [86,87].

Secondly, our study provides additional evidence that in countries where special attention is paid to the rights of property owners, there is a strong need to give plans a legal dimension [7,88]. This means that authorities have recognized that space needs more protection by law. This gap is not only geographical; our results are crucial because the theory is verified in countries with a different recent history, with significant ideological changes, thereby allowing us to generalize properly. Other features of spatial plans in the countries studied should also be highlighted. There is a dominant division in two types: general plans and specific plans. Common elements of general plans in all studied countries were identified. The value of this finding is important in characterizing plan-based systems identified in the literature. Such an arrangement can be taken as a reference when characterizing other national planning systems and their possible differences.

Thirdly, and equally important, our study employs a novel methodology for comparing plans, which takes into account different scientific disciplines. Its interdisciplinary nature suggests the transferability of this approach not only to planning studies from different countries and areas but even to studies beyond planning disciplines [24]. The proposed methodology makes it possible not only to bring together perspectives of different countries but also of different scientific disciplines. These divergences are significant, and the authors are aware that adjusting them requires further discussion. Nevertheless, the results of the time-consuming analysis and consultation of diverse terminological, practical, and scientific details related to the topic should be considered as an important contribution of this research. This may also translate to other spheres related to public policies.

The results presented here cover the countries of Central and Eastern Europe. As indicated above, a comparative analysis was possible due to many common features (spatial, social, political) linking these countries. One may even risk the opinion that (despite the identification of numerous detailed differences) the spatial planning systems of the indicated countries are strongly similar. This is confirmed by the survey results. For this reason, too, the results presented should be considered important from the perspective of a broader contribution to the international discussion. Indeed, Western European countries are mutually strongly differentiated from the perspective of the planning concepts practiced [1]. Deeper analogies are even more challenging on other continents. One can mention the diversity of planning systems in Asia [89,90], the different approaches to spatial planning in North American states/provinces [91,92], as well as the social barriers translating into spatial planning in South America [93,94]. Such conditions cause such broad, in-depth comparisons of a larger number of countries to be difficult. Therefore, the comparative methods used for the comparisons of Central and Eastern European countries, in this case, were the most widely applicable. The compilation prepared may inspire similar issues to be addressed in other systems, despite the barriers signaled.

Additionally, in this context, the authors consider the broader addressing of the role of spatial plans in spatial planning systems as an important contribution to the scientific discussion. Many approaches analyze spatial plans singularly, in the specific context of a given topic. An in-depth, interdisciplinary, and international reflection on the role of spatial plans in the system is missing. An analysis that connects the question of spatial planning objectives and the values of individual systems with the legal framework for the enactment of spatial plans and the problems that arise on this occasion is needed. Reimer, Getimis, and Blotevogel [8] rightly point out that comparing spatial planning systems only on the basis of an analysis of the legal framework is a mistake. It can be added that it is crucial to juxtapose the values and assumptions of the systems with implementation practice. This requires a broad, interdisciplinary approach. The results of the study confirm that the analysis of the law (and legal consequences) is particularly important in isolating the problems of planning systems. In the group of countries studied, it is precisely the legal and procedural problems that constitute a very significant barrier to further development. Again, the context of spatial plans recurs here. It is the problems associated with the application of these instruments that determine the framework of the respective systems to a key extent. A very good example of this is the problems that translate into the limited enactment of plans (e.g., in Bulgaria and Poland). It can be pointed out that the issue of the implementation of the provisions of specific plans is also interesting. Again, the example of Poland, where most of the provisions of the plans are not implemented, is relevant here [70]. This is another interesting and important research task. Its implementation in comparative terms, however, poses a major challenge.

What needs to be emphasized is the fact that common parts of general spatial plans (or their equivalents) have been identified in the studied group of countries. Very well, this is not just the designation of individual zones. The indicated minimum also includes guidelines for technical infrastructure and environmental principles. The latter is important and necessary from the perspective of the need to respond to the challenges of climate protection. The experiences of other countries can complement this perspective. Nevertheless, it is worthwhile to take the set of issues just indicated into account in further theoretical considerations. They make it possible to provide a first, general response to spatial challenges. Effective reference in the plans to the indicated thematic spheres will also argue for the necessity of spatial plans at the local level. Contrary to appearances, this approach is not common. It is sometimes replaced by a neo-liberal paradigm that boils down to freedom of investment [95]. Again, the example of the countries studied is relevant in this regard. The lack of planning coordination can lead to serious problems related to spatial chaos [88].

Further research directions are also rewarding. They may relate to different groups of countries:

• In CEE countries, an important issue seems to be the analysis of the role of courts in spatial planning. Since spatial plans are, at least partly, legally binding acts, they are subject to judicial review. The interpretation of legal regulations is a good way of defining spatial planning problems.
• An in-depth discussion is needed on the issue of terminology because it is linked to different understandings of certain concepts (e.g., “land use policy”). These perspectives differ not only between countries but also between scientific disciplines.
• In the planning systems surveyed, it is worth looking for elements of flexibility in planning. These can then be collated and compared.
• More detailed analyses can be carried out in smaller groups of countries. Hence, a more in-depth review of the practice of circumventing planning provisions (e.g., comparing Bulgaria and Poland in this respect) might prove particularly interesting.
• The evolution of spatial planning systems, the broader dynamics in changes within these systems or their development from plan-based systems to more strategic development-based systems is also worth academic attention.
• The dependence of planning provisions and the direction of planning practice on the number of municipalities in each country, the size of these municipalities, and the average population in the municipality also require further analysis.
• Further discussion is needed on how to classify European spatial planning systems. While the general separation of groups of countries (families) provides a point of reference, it is equally important to further elaborate on specific issues that can be compared in-depth. From this perspective, it is an interesting task to compare the key issues of spatial planning in all European countries.
• A broader reference of systemic solutions to the latest challenges, both on a universal scale (adaptation of spatial planning to climate change) and in individual groups of countries (the problem of urban shrinkage, urban sprawl, and suburbanization).

5. Conclusions

Based on the research carried out, it is possible to diagnose some key features of spatial plans at the local level in CEE countries. These include:

• The universally binding nature of at least one plan in any given country,
• A major role for local authorities in drawing up plans (predominant in most countries), but one which is curtailed by higher-level authorities, especially when dealing with major public investments and particularly valuable areas,
• The dominant division of plans at the local level between general and detailed,
• The coverage of the entire area of a country by (general) plans in a group of countries,
• The inclusion of areas of land, technical infrastructure, and references to environmental and cultural topics in the general plans.
• The key problems defined in national systems boil down primarily to how the provisions of the plans are implemented. There are several trends visible here:
• The circumvention of planning provisions,
• The lack of coordination in content between different types of plans (e.g., general and detailed).

Another relevant problem is the way public interest is understood in national planning systems. On the one hand, common values are very strongly emphasized in national laws. On the other, these values are not always implemented systematically.

In the countries studied, the differences mainly come down to:

• The terminology used to describe both the names of the plans and their contents,
• A more detailed classification of the plans in each country and a wider range of their contents, including the type of plan in which development parameters are included,
• Individual differences in relation to the trends revealed earlier.

In each country, at least one type of plan is legally binding. Hence, plans define the norms for land use, at least to a basic extent. The consequences are numerous restrictions and attempts to circumvent planning provisions. These conditions significantly weaken the role of plans in many countries (e.g., Bulgaria, Czech Republic, Poland). The inconsistency between legal regulations and implementation is a key problem in assessing the role of a spatial plan in any CEE country. Most national spatial planning problems are linked to the application of plans at the local level. This link can be (I) legal-procedural, concerning the coherence of plans and the interpretation of related regulations. This group may include the circumvention of plan provisions; (II) implementation, related to the difficulties of implementing the key values of spatial planning systems through plans; (III) postulation, related to the implementation of new postulates and challenges related to spatial planning in these plans.