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TO READ MORE ABOUT THE PROPOSALS PLEASE SEE BELOW

The government has published 2 white papers which if enacted will radically change the planning system giving more power to developers. The most urgent campaign is against the paper 'Changes to the current planning system' as this could come into force before Christmas.

For links to the consultation papers and suggested responses please see the points above. Although the consultations have now closed, it is not too late to lobby your MP.

Introduction to

This is one of two important documents issued for consultation by the Government (White Papers), and responses to it are required by 1 October. The second (“Planning for the Future”) asks for responses by 29 October. Taken together, they come “at a crucial time for the future of democratic planning in England, with the real prospect that a system designed to uphold the public interest will be effectively extinguished by the end of 2020” [Dr Hugh Ellis, Director Policy, Town and Country Planning Association, introducing a report on the proposals as “a serious heavyweight analysis from a group of the nation’s leading planning academics”].

We might all agree that changes to planning processes are required in a number of areas – perhaps especially in relation to its complexity and (sometimes) its lack of transparency, both of which have led to a serious lack of public confidence in the system (and, by extension, in local democracy); however, in the view of many people, the current proposals would simply make matters worse.

This short note is designed to encourage everyone concerned with the future of planning decisions in this country to respond to the Government’s proposals – and to express strong opposition to most of them. In view of the urgency, it is limited to the first of the two White Papers, entitled “Changes to the Current Planning System”.

The White paper poses a total of 35 questions to which responses are sought. Many of these are technical in nature, but they fall into a number of broad topics, four of which are the subject of this note.

1. Amendments to the standard method for assessing housing numbers in strategic plans

A number of detailed changes to this are proposed, resulting in a simplified and uniform basis for calculating housing land requirements which “Planning for the Future” says should now be determined by central government and effectively imposed on local authorities. This would leave little room for meaningful community engagement (contrary to the Governments’ stated intentions) or for account to be taken of local circumstances. Many commentators have also pointed out that changing the methodology in the way proposed would result in completely unachievable targets in some parts of the country, as well as a reduction in housing requirements for many areas where high levels of housing delivery have actually been successfully attained.

 Similarly, it is widely accepted that granting more planning permissions and imposing “viability tests” does nothing to address the nation’s need for genuinely affordable housing. The White Paper entrenches the supremacy of the market, rather than allowing a sensible level of intervention in the way the development industry operates. It is the latter which would increase public confidence, not the former.

2. Delivering First Homes

 The White Paper proposes to ensure that at least 25% of any new affordable homes would be reserved for first-time buyers, ie as a national requirement. This is too crude an approach; it deprives councils of the opportunity of providing for those in housing need in the most effective way, based on a detailed understanding of local circumstances. This applies also to the question of exemptions, discount rates, etc.

 It is also proposed to replace the existing provision for “entry-level exception sites” (land outside the Local Plan designations, which currently must be no bigger than 1 hectare) with First Home Exception Sites (with no size limit). This would permit significant developments which could effectively undermine Local Plan policy, having only to satisfy the very broad requirements of the National Planning Policy Framework – again resulting a reduction in a loss of local control and of public confidence in the system.

3. Developer Contributions – smaller schemes

 The Government proposes to raise the size threshold for requiring developer contributions towards the provision of affordable housing. This is designed to support small and medium-sized developers, in part as a result of Covid-19; however, it would significantly reduce the amount of affordable housing being made available, and cannot be justified as a permanent arrangement – especially since developers can, and do, successfully negotiate with local councils if they have particularly difficult issues of viability on a specific site. These arrangements work, both in rural and urban areas of the country, and there is no evidence of any need to change them.

4. Extension of the “Permission in Principle” Consent Regime

PiP currently applies to housing developments of fewer than 10 dwellings. “Planning for the Future” would radically change the existing system by introducing automatic planning permissions in a wide number of circumstances – something to which there has been widespread opposition nationally. As a stop-gap measure, the present White Paper would immediately extend Permission in Principle to encompass major developments.

There is no evidence that the introduction of PiPs has had any benefits over the traditional system of outline planning permission followed by subsequent consideration of the detail. Increasing its scope would simply introduce more, not less, uncertainty about what is actually being proposed and what its impacts might be – this is because less information need be provided by the developer when submitting a PiP application (and often it is no more than is already available through examination of the policies in the local plan. This again can only weaken the public’s confidence in the system.