As you might know, the Government wants to drastically overhaul the planning system, seriously threatening local democracy, countryside and the wider environment. The Planning White Paper (PWP), in which most of the reforms are proposed, has been talked about widely in the press and has sent alarm bells ringing (with good reason). The consultation on the PWP ends on the 29th October, and BEAG will be responding.
However, less well known are the the innocuous-sounding “Changes to the current planning system” (CCPS) proposals which were published around the same time as the PWP. While the CCPS proposals are not the main event, they would still be far-reaching if they come into effect. The proposals would put data before democracy, impose top-down housing numbers on communities, and treat crucial environmental matters as mere after-the-fact technical details within permitted development rights.
The consultation on the CCPS ended last night and BEAG’s response is below. I also suggest reading the detailed response from Smart Growth UK – it is excellent.
If you have an appetite for more reading, the Town and Country Planning Association has written a very useful critique of the Planning White Paper, spelling out what is at stake. Click here.
Subject: Consultation: Changes to the current planning system
Date: 2020-10-01 21:19
From: BEAG Updates
The Buckinghamshire Expressway Action Group (BEAG), is responding to the consultation on proposed changes to the current planning system published in August 2020.
MHCLG has given the public a relatively short timescale to respond to the proposed changes to the planning system, despite the fact they anticipate proposals in the Planning White Paper that would overhaul the planning system, and that are also out for consultation. Given this, and given than BEAG feels the approach within the consultation to be fundamentally flawed, we have confined ourselves to general issues rather than responding to each question.
The Standard Method for Assessing Housing Numbers in Local Plans.
The level of housing should be based on objectively assessed need (not demand), particularly the need of those who are less affluent. The system as proposed simply perpetuates the expansion of the economy around London at the expense of the rest of the country.
The proposal starts with a Whitehall-imposed target of 300,000 plus houses per year and then distributes this around the country according to an algorithm of the kind the government appears to be relying on increasingly. The algorithm in question is unsophisticated and unfit for purpose. There is no allowance for understanding actual local need or conditions, and the impact of buy-to-let, Airbnb, second homes and a property market chronically distorted by massive investment is ignored.
The model of attempting to deliver ‘affordable’ housing, by allowing developers to develop profitable housing in the hope that some less profitable but affordable housing might follow, has failed. The planning system cannot meet real need because developers will always simply sit on land with permission until it is profitable. Even if developers built out on the land that they are currently banking, it has not been demonstrated that increasing housing supply increases affordability. The obvious solution, to allow local authorities to build meaningfully affordable social housing, is simply ignored.
The solutions proposed are disappointing, but not surprising, given the reliance on advice from Lichfields (a planning consultancy) and Savills (an estate agent). Plainly, this advice cannot be impartial and does little to inspire trust in the proposed reforms that flow from it.
Extension of the Permission in Principle consent regime.
Our concern lies in the proposal to extend the ability to give Permission in Principle to developments up to 150 houses. As the paper makes clear (para 94), this would account for 46% of all housing development. The purpose is to remove the need for environmental assessment of any sort to a point where the recognition of environmental harm can no longer trouble the process. We understand the government’s wish to increase housing supply, but cannot agree that this should be done without understanding the environmental impact.
If this came into effect, potentially half of all housing development would have the impact upon the natural and historic environment relegated to technical detail offered as supplementary information. This would be considered after the decision to build the houses, so presumably it would allow only some sort of minor twiddling with designs to attempt to mitigate the harm in some way. This demonstrates that the government’s own commitments to protecting the environment, and “to bring all greenhouse gas emissions to net zero by 2050” are meaningless compared with its commitment to allowing developers free rein.
In response to Q24, we strongly disagree that Permission in Principal should be extended.
No new expressway – here, there, anywhere