Claire Stafford is a Planning and Policy Advisor at the RTPI
The RTPI Policy team has had a busy time responding to the Labour Government’s first big planning reform proposals, intended to “kick-start economic growth”. The wide remit of this consultation covers everything from housing, brownfield and greenfield development, infrastructure, individual council’s Local Plans and planning application fees.
Our response was formally submitted today and was greatly influenced by expert input collated from our various regional roundtables held up and down England. This was a mammoth effort to consult our membership to ensure that we soaked up the regional variations for the potential implications of these wide-ranging reforms.
This vital outreach work revealed the extent to which our members feel this is an important moment for the planning system to regain the trust of the public, however, crucially, if these significant reforms are not implemented correctly, it is felt that this trust could be severely damaged, given the scale of proposed development.
Planners have been placed at the forefront of Labour’s growth agenda, with the proposed housing figures on a scale not witnessed since the post-war period. This gear change in approach provides an opportunity for planners up and down the country to take the reins. However, this comes with huge responsibility and the pressure will be on planners to deliver the Government’s ambitions in a way which still upholds the principles of sustainable development.
Positive direction of travel
The reforms, when taken as a whole, represent a positive direction of travel that our members strongly welcome.
Rolling back last December’s changes to the National Planning Policy Framework (NPPF) has received widespread support across the industry. We were very critical of these changes when they were proposed. They gave Local Planning Authorities (LPAs) too many excuses to not meet their housing need by previously stating that the outcome of the standard method was an advisory starting-point for establishing housing requirement and by providing further context on where alternative approaches may be appropriate in exceptional circumstances. We were concerned that this change would increase uncertainty and ultimately lead to reduced pressure on LPAs to fully meet their localised need.
Similarly, the clear move towards strategic planning is great to see, as we see this approach of operating at the city-region level as key to addressing many of the issues facing the planning system, especially in terms of distributing ambitious housing targets in a more manageable and sustainable manner and in line with planned infrastructure. The ‘messy’ transition period prior to the upcoming legislation to formally embed new strategic planning in governance arrangements is discussed below.
Another positive facet of the consultation that perhaps has received less attention is the shift to ‘vision-led’ transport planning. The move away from the traditional ‘predict and provide’ model, (whereby current trends are used to inform future provision), is long-awaited within the industry as a way to encourage collaborative innovation away from car-dependency, although this change must be supported by robust guidance as to what this will mean in practice for planners.
Scepticism around the numbers of homes derived from the new standard method
We support the Government’s ambition to build 1.5 million homes over the next parliamentary term, however, our roundtables strongly revealed the scepticism around whether a) the level of housing proposed will be possible to deliver, particularly within northern authorities who have seen their figures grossly inflate, and b) whether they are reasonable and actually linked to need. Some areas are seeing huge increases in their housing targets, despite facing significant local constraints on delivery and/or low demand.
Indeed, a key enabler in reaching these numbers is the number of planners within the system working to deliver the housing targets, albeit, there are many external levers affecting development that lie outside the planning system’s control, and more planning permissions do not necessarily equate to more homes being built. We will touch on these wider factors in a separate blog post.
Caution over the transitory period
Given the significant increases in housing targets, local authorities will face a challenging interim period over the short-to-medium term. Many authorities without up-to-date Local Plans will inevitably face a surge in speculative development under the presumption of sustainable development. There is a risk that public perception of planning outcomes may be affected. However this is out of planners’ control. Wider issues within the planning system still remain and will hinder planners’ efforts to meet these challenging figures. Notwithstanding these wider factors, there will be an unavoidable lag in the build-out owing to the time needed to go through the planning and construction phases.
What is clear is that full strategic planning is needed to deliver these housing targets in the longer term. This will be crucial to enable the allocation of housing targets in a way that properly responds to needs and local constraints, to deliver services more efficiently and to ensure the effective management of the green belt.
Inevitable increased building on the green belt must be caveated to ensure sustainable locations and that it is in the public interest
Within the consultation, perhaps the topic which has gained the most attention is the introduction of the ‘grey belt’ concept. This new term is useful in unlocking discussions around reviewing and releasing green belt land, and it is positive that the proposed definition is tied closely to the existing five purposes of the green belt; this aligns with our view that the green belt should retain its tight focus as an urban containment policy.
In our consultation response, we welcomed the hierarchical approach to development, with the presumption in favour of brownfield development, followed by ‘grey belt’ and finally green belt land.
In light of the high housing figures authorities will face, it is inevitable that LPAs will quickly go through their brownfield and ‘grey belt’ sites and will therefore end up at the green belt (particularly those with out-of-date Local Plans and not subject to any devolution deals with planning powers). Within the context of the national housing crisis, it is reasonable to trade green belt for housing development in policy terms. However, it will be crucial that the Government tighten the emphasis on ensuring the sustainable location of sites and that development is in the public interest. We cover the green belt in more detail in this blog post.
Affordable housing should be set through Local Plan policy
The proposals include new ‘golden rules’ to ensure that major development on land released from the green belt benefits both communities and nature. We strongly support the requirements for necessary improvements to local or national infrastructure and the provision of new or improved local green spaces accessible to the public.
Our membership was clear however that the proposed standardised requirement of 50% affordable housing is simply not viable across the country, notwithstanding variations within individual authorities.
We welcome the increased commitment to deliver more genuinely affordable housing through a mix of tenures, but we have cautioned that affordable housing should be locally-determined through Local Plan policy (that is backed up via national policy requiring 50% where possible). This Local Plan policy would then be viability tested during examination.
Looking ahead
In tandem with the new Government’s commendable ambition and a solid start to planning reform, we must recognise the enduring constraints within the current system that will create obstacles in the interim period as development gears up.
The proposals for higher householder planning application fees are something we previously called for, however, the scale of effective resourcing within the system remains significant. There is more to be done on this front.
As an important first step, given the uncertainties and changing goalposts created by these reforms, our membership was adamant on the need for a roadmap outlining timescales for progressing formal strategic planning.
