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“PLANNING
FOR THE FUTURE” WHITE PAPER The consultation closes on 29 October, 2020 Here are some comments to help you formulate your response: There
is a need for some overhaul of the planning system, in particular: ·
Local Plans
take too long to prepare and are over-complex, and the whole process is
dominated by interest groups - so we should welcome genuine attempts to
involve local communities more in deciding what happens in their area; ·
further
improvements could be made in the process of deciding planning applications –
without the removal of local scrutiny (which is what the Government intends). But
this can be achieved without the abolition of the fundamental safeguards for
local communities and individuals provided by the existing system. MAIN
CRITICISMS OF THE WHITE PAPER ·
there is no
evidence whatever that shortcomings in the planning system are primarily,
or even significantly, responsible for the housing crisis. The proposed measures
are the product not of independent analysis and advice but of free-market
ideology; ·
there is also
no evidence to support the implication that local authorities are primarily
responsible for the failure to build
enough houses. In many parts of the country, well over 90% of all applications
are approved at first attempt; more are approved after agreed changes are made;
and well over a third of all appeals are allowed (which also means that, in
nearly two-thirds of the cases, Inspectors agreed that the Council was justified
in refusing permission). The system works; ·
the imposition
of binding (and apparently arbitrary) housing figures by central government
cannot possibly be described as increasing transparency, legitimacy and
democratic involvement. It is more likely to be seen by the general public as
the product of behind-the-scene lobbying by vested interests, and a further
dilution of the relevance of local government; ·
there is no
evidence that the introduction of a crude “rules-based” system will of
itself result in “certainty” – ie, the assured delivery of more homes - as
opposed simply to the accumulation nationally of yet more unimplemented planning
permissions. Despite acknowledging that “having enough land supply in the system does not guarantee
that it
will be
delivered”, the document
simply says Govt will rely on the Housing Delivery Test and the
vague “presumption in
favour of
sustainable development” to
put things right. This is a wholly inadequate response which again seems to lay
the blame for the housing shortage at the door of the local authorities; ·
in any event,
all “rules” (especially in relation to subjective matters such as design,
visual and amenity impact etc) will have to be interpreted by someone charged
with making a decision – this is no different from the present arrangement,
where local councils assess schemes against the policies in their local plans,
which will themselves have gone through a process of independent examination; ·
there is to be an
automatic grant of permission if the Council is slow in coming to a decision,
and a return of the application fee if there’s a successful appeal (but no
recoup of costs to the Council if the appeal fails). This smacks of
punishing those authorities taking the time they need to come to a sensible
decision, or coming to the “wrong” one; ·
the White Paper
is full of vague policy statements,
such as an intention to “automatically permit proposals
for high-quality
developments where
they reflect
local character
and preferences”,
or to “make
land available in the right places for the right type of development”, or building “beautiful places where people want to live” -
meaningless rhetoric, offered in a complete vacuum. How could we monitor whether
or not these “policies” have been successful? However it is dressed up, the
clear message behind the White paper is that the market can be trusted to
apply these tests and to decide where, what and (crucially) when to build; ·
similarly,
while there’s much criticism of the process, there’s no reference to
any failures or inadequacies of national policy; for example – “we
will ensure the planning system supports our efforts to combat climate change
and maximises environmental benefits” – you don’t need to change the
whole planning system to do that, you just need to have a genuine intention to
deliver on your promises. ·
Finally, is it
worth the huge upheaval? Doesn’t the country have more important priorities
just now?
Please make the following recommendation in response to Question 14 which
asks "Do you agree there should be a stronger emphasis on the build out of
developments? And if so, what further measures would you support?" The government should focus
on supporting local authorities and give them the power to ·
charge Council Tax on the number of potential homes unbuilt after
3 years of planning permission being granted. ·
allow compulsory purchase of land at agricultural land value or
pre-scheme value where development has not come forward within 3 years of
planning permission being granted. |