Planning for the future – our response to the white paper
Last week Woods Hardwick’s Planning team submitted their response to the Government’s Planning White Paper.
As daily users of England’s town planning system, acting on behalf of landowners, land promoters, commercial developers and small, regional and national house builders, changes to the system are long overdue. This is necessary if we are to deliver 300,000 new homes annually to meet housing need across the country.
This review of the system provides an opportunity for fundamental reforms which if successful, will provide more certainty in the planning process and increase the speed of decision making.
This is also the opportunity to rethink the system’s approach to strategic planning. The ‘Duty to Cooperate’ has failed to deliver good planning outcomes and it should now be replaced. An effective solution to strategic planning is now required, to support the Government’s objectives for sustainable growth and provide a framework for distribution of housing numbers and coordinate the delivery of supporting infrastructure. Right on our doorstep, the Oxford-Cambridge Arc is recognised by Government as a strategically important area, yet without a clear plan and economic strategy underpinned by political leadership and key stakeholder buy in, questions will remain on whether the area’s full potential can be realised.
Here are a selection of the key takeaways from our response:
Planning for development
- Local plans should be simplified and use digital technology to ensure ease of accessibility. However, they need a clear set of measurable objectives to ensure tests on ‘sustainable development’ remain accountable
- Central government should specify the housing requirements for an area using the standard method but also acknowledge that a review of the Green Belt boundary will be required where necessary to accommodate some of the housing need.
- Affordability and extent of existing urban areas are appropriate indicators of the quantity of development but we would add another factor: employment densities. Invariably, areas with high employment densities, for example the Ox-Cam Arc, will have a need for more housing and the sustainable approach would be to reduce travel distances by providing housing within easy reach of employment.
- New initiatives will require the appropriate funding and resources. We welcome the proposed shortened time frame for the production of Local Plans as well as the proposal for review at least every five years, which will ensure that plans adapt to changing circumstances. However, this is an ambitious target given that many Local Plans can at present take 5 years or more to reach adoption and much will come down to planning departments being appropriately resourced with ‘ring fenced’ funding.
- We question the role of Neighbourhood Plans in the proposed system. Neighbourhood Plans in the current system can play an important role in the allocation of sites at the local level, however it would appear that this role will be taken away in the proposed new system of Growth, Renewal and Protected Areas.
- There should be a stronger emphasis on the build out of developments and we welcome the requirement for masterplan and design codes for substantial development to include a variety of development types by different builders (particularly SME builders) to allow more phases to come forward together.
- Increased social housing delivery by Local Authorities and their development partners has an important place in speeding up the delivery of housing development to meet housing need. Local authorities are in a position to borrow money at more competitive rates and should also be encouraged to forward fund development from the proposed new system of Infrastructure Levy.
Planning for Beautiful and Sustainable
- The quality of design varies widely. Each authority should have a chief officer for design and place-making which should improve decision making in terms of quality of design. This needs to be supported by a general upskilling, with dedicated design staff in local authorities with appropriate funding. However, implementing such processes needs to come with a clear message that the role of local authorities will be to influence and improve the quality of design and not stifle or prevent development.
- Sustainability needs to be integral to the design of both buildings and places, focusing on more green and open spaces, more trees, and energy efficiency of new buildings.
- Design codes are useful tools to encourage quality development, but they can also stifle innovative design and overly extend the approval process without benefit. More detail and clarity is required on how the new system will engage with communities on design codes and how they will fit with the new Local Plans system.
Planning for Infrastructure and Connected Places
- The Community Infrastructure Levy and Section 106 planning obligations should be replaced by a new consolidated Infrastructure Levy. A simpler and more transparent system to capture uplift in land value will enable the delivery of infrastructure to support development. However, there will still be a role for Section 106 obligations in the control of development where planning conditions are not sufficient.
- The Infrastructure Levy should be set locally, recognising local/regional differences across the country.
- Local authorities should be allowed to borrow against the Infrastructure Levy, with appropriate checks and balances in place to ensure that it is related to the new development coming forward.
- Where appropriate the scope of the reformed Infrastructure Levy should capture changes of use through permitted development rights.
- There is a chronic need for the delivery of affordable housing. It also be important to secure as much on-site provision as at present to ensure the continued creation of mixed communities, whilst also allowing for flexibility for off-site contributions where on site provision is not practical.
- The current affordable housing model of private house builders working with registered provides should remain the most appropriate mechanism for delivery.
To read our response in full, download here:
If you would like to discuss any of the white paper and our response in more detail, get in touch with one of our team: