Planning for the Future




 Please respond to the consultation via

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.



·         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.