Planning for the future: my response

by samalhamdani on 29 October, 2020

The deadline for responding to the Government’s white paper “Planning for the Future” was today. The paper is a fundamental overhaul of the planning system of the UK, and not for the better.

As well as contributing to the response of Oldham Borough Council, Saddleworth Parish Council, and the Liberal Democrat Group on Oldham Council, I have also submitted my own response to the paper, below.

The White Paper proposals for reform of the planning system provides a substantial number of challenges – not least the lack of detail contained within the plans.

There are a number of positive elements to the proposals, which should be encouraged. However, it should be clear that those positive elements are ones which should be brought forward regardless, and do not require the proposed overhaul of the planning system which the White Paper envisages. 

That is not to say that the planning system in the UK is not in need of reform, but that the proposals within this white paper do not address the route causes of the problems in the planning system in this country. 

Starting from the principle of the paper, that the cause of failure to build sufficient houses in this country is the planning system, and delays at local councils. This is manifestly incorrect, not only evidenced by the high percentage of planning proposals which are passed by local councils (not to mention the increased number of developments which are not subject to planning permission), but by the staggering levels of land banking once planning permission has been given. 

The foreword also contains a number of statements which are, at best, misleading. The reference to only 50 per cent of local authorities having a Local Plan which is up-to-date is made in reference to the length of time it takes to adopt them. It fails to mention that one of the conditions for having an up-to-date local plan is that a nationally set target of homes have to have been built in that local authority – and that target takes no account of the number of homes that have received planning permission. The result of this is that a local authority could approve double the number of homes that need to be built, but if developers do not build them, the local authority gets the blame. 

The paper itself makes clear that far more of the public have lost faith in developers (49%) for making decisions than the local councils (36%). Yet this is unashamedly a paper which places itself as a “developers’ charter” – aiming to make it simpler and easier for developers to develop, and placing the blame squarely on the local authorities, which are in fact, far more trusted of the two. 

The principles of better use of technology, and higher standards of design codes are to be welcomed, but it should also be clear that these can be delivered without the need to completely reform the planning system in the way described.

There are a number of key issues which must be reviewed, and which demonstrate that the planning system envisaged (very loosely) in this White Paper. 

1) The removal of transparency and democracy from the heart of planning decisions. 

This paper explicitly reduces the amount of consultation that will take place at key points in the planning process. First of all, when it comes to the creation of new local plans, when a fixed timetable and the need to ensure that all “growth”, “renewal” and “protected” areas are defined means that there is a small window in which all representations will need to be heard, creating a dramatic bottleneck in the ability of residents to respond effectively. This is compounded by the removal of the rights of residents to respond at the decision making point of planning applications – instead there is a loose commitment to consultation earlier in the process. 

2) Promoting the speed of the process at the exclusion of other considerations.

While a good decision made quickly is better than a good one taken slowly, prioritising time over effectiveness makes it much more likely that bad planning decisions will be taken. This white paper reduces the amount of time in which it is possible to conduct all the necessary reports, considerations and analysis required to properly assess – in particular – complicated or large scale developments, and particularly those with potential environmental or social impacts. This, together with a general presumption in favour of development, radically increases the chances of low-quality, negatively impacting developments being passed. 

3) A failure to provide the training and resources necessary to make better decisions, and to meet the timescales envisaged.

This should be seen in conjunction with point 2. The reduced timescales for both creation of local plans and assessment of individual applications would mean that in order to deliver these, a vast increase in the number of specifically trained staff would be required to deliver these assessments. Given changes in the planning departments of local authorities over recent decades, radically reducing these skill sets, this is a perfect storm of massively increased responsibilities with massively reduced capacity. There is no reference anywhere in the paper to any provision of the similarly massive training requirements that would be needed to deliver this wildly overambitious plan.

4) A failure to put environmental considerations at the heart of decision making.

This plan puts speed and development front and centre. It makes reference to “sustainable development”, but with little description of what that means, and judging by the later inclusion of “environmental standards” does not seem to put them at the heart of what sustainable development means. With the looming environmental crisis, a failure to put environmental considerations at the front of development, rather than the flimsy and visually-oriented “design codes” envisaged in this paper means that it would create an environmental legacy lasting generations, of homes with low environmental standards. While the paper commits itself at the start to homes which do not need to be environmentally retrofitted, this ambition is completely undermined by the prioritisation of speed of decisions and numbers of houses at the expense of all other considerations.

There are a substantial number of specific issues which the White Paper fails to address in sufficient detail for any review of its merits to be possible. As such, any decision to progress with the system it envisages without first giving clear explanations of either more detail, or how sections of it would work in practice would be a failure of decision-making of the highest order. 

The categorisation of areas into three silos – “growth”, “renewal” and “protected” is massively oversimplistic in its current form. While they would be reasonable approaches in a hierarchy, without considerable detail on how they would work in progress, and how specific types of currently defined land would be treated, this cannot be adopted as is.

The creation of centrally mandated design codes, but at the same time “locally popular” design codes are explicitly in opposition to each other, and there is no indication in the white paper of how this contradiction would be managed. 

The introduction of a one-size-fits-all Infrastructure Levy would be massively harmful in many places, and create a series of dramatic implications that would undermine the ability of local authorities and national government to encourage development in the most strategic places. The inability of decision makers to constructively use section 106 and a CIL (where it exists) to encourage development in the right place, and of the right kind, is a massive weakness to this proposal. The White Paper also seems to break the connection between an infrastructure levy and the local area, so there would be no necessary requirement to use monies raised to improve the infrastructure in the area of a development. 

The introduction of stronger enforcement powers is to be welcomed – although again, this requires no structural reform of the planning system, and should be pursued regardless of the progress of this white paper. 

Currently, this white paper states that it seeks to deliver streamlined, efficient decisions, higher environmental standards, and a planning process for the 21st century. Without substantial revision, it will deliver opaque decisions, removed from the public, erode trust further, and deliver off-the-rack picture postcard houses with no thought for environmental standards and coherent planning. 

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