Richard Blyth FRTPI is the RTPI’s Head of Policy, Practice and Research.
The RTPI champions the power of planning in creating sustainable, prosperous places and vibrant communities. We are a membership body, a charity and a learned society.
Using our expertise and research we bring evidence and thought leadership to shape planning policies and thinking, putting the profession at the heart of society's big debates. So it is appropriate that twice this week I have been asked to give evidence to Parliamentary Committees.
The first session was to speak to the Levelling Up Committee about the UK Government consultation on the National Planning Policy Framework (England) (NPPF) which has just closed and to which the RTPI responded to recently.
I explained to MPs that it is indeed true that the “start-stop” nature of proposed changes to the planning system and to planning policy in England does tend to produce inertia in the system. For example, very substantial changes to planning were proposed by the Government in October 2020 and we heard nothing again from the Government until May 2022 when rather suddenly a Parliamentary Bill was produced which differed a lot from the original ideas.
In the RTPI’s response to the NPPF we pointed out that regarding both green belt and existing area character as reasons not to have to meet a housing requirement put planners in a difficult position given the overall target of 300,000 homes a year the Government is still saying should be built. In addition, these policy changes coming as they do in the absence of robust subregional arrangements for planning for housing across local authority boundaries make handling all these conflicting pressures especially difficult.
Witnesses were asked to give views on the proposed removal of the requirement for local plans to be “justified”. This got support from the Local Government Association, but I and Sam Stafford from the Home Builders Federation resisted this idea. While plans may benefit from a smaller quantity of reports, they must still have a high quality of evidence to justify why decisions of such significance to communities and landowners are being taken in the public interest. Without evidence, how can we decide what the public interest is?
The second session was to give evidence to the House of Lords Built Environment Committee on the role of environmental regulations in planning in England.
I was asked how the complexity of environmental regulations could be reduced. I explained that there are two ways in which environmental regulations apply to planning – firstly they affect plan-making. Currently, local authorities have to take account of a multiplicity of local plans on the environment. And from some as-yet-unspecified date, the new “local nature recovery strategies”(LNRS). Local plans are also currently subject to Strategic Environmental Appraisal and to Habitats Regulations Assessment.
And development management is also subject to environmental regulation, through Environmental Impact Assessment (if above the threshold) and Habitats Regulations (if near a Natura 2000 site). From October 2023 development management staff will also have to assess the new biodiversity management plans brought in by the Environment Act.
So what would our solutions to this be?
Local Environment Improvement Plans would build on Local Nature Recovery Strategies to bring all the current plans on the environment (the various water plans, shorelines, catchments, air quality, LNRS) into a single place.
The Government proposes “Environmental Outcomes Reports” to replace both SEA and EIA. Despite putting this idea in a Parliamentary Bill last May on the grounds that the current system is onerous, we have not yet seen any evidence of that, nor what the Government proposes in its place. Any replacement for these systems of assessment must both include the consideration of alternatives and must honour our commitments as a signatory to the public engagement obligations under the Ȧrhus Convention.
We have expressed grave concern about the resource implications of the introduction of Biodiversity Net Gain in October 2023. After a fairly long delay, the Government has released information regarding how it will fund BNG. Funding for an average of 2.8 staff per county or unitary authority has been made available until November 2023, or until the second month of operation of the system. This is welcome, but the system needs permanent funding.
It was indeed a privilege to be in front of MPs and peers in the venerable Palace of Westminster, representing our Members' views. The RTPI’s engagement with Parliament will continue after the Levelling-Up Bill receives Royal Assent, as these Committee appearances attest.
