the Government’s White Paper on proposals for the reform of the planning system in
England.
The current local strategic planning system is failing in its need to be comprehensible
to the general public. We agree that Local Plans should be simplified.
But not at the cost of genuine public involvement, and robust, locally appropriate
development plans. In the best case, we believe it is possible the proposals included in the
Government’s White Paper could create development plans that are responsive to local
needs and concerns, deliver beautiful, well-built and designed homes and communities, and
protect the natural environment.
Yet we are concerned about the worst-case scenario: that these proposals would lead
to Local Plans promoting large scale, ill-considered developments that do not respond
to the wishes of the existing community, and which do not allow for nuance and
variation within the existing built-up and green areas of our rural district.
We are anxious that Local Plans need to be based on solid data, subject to genuine
consultation with local communities, and robust enough to stand up to legal challenge.
We welcome the early input of residents proposed in this White Paper, but consultation
also needs to be possible at a later stage of development - and it should be made
clear to residents how much impact they can expect to have at each stage.
We do not support the proposal to fast track ‘beautiful’ design. We believe that all
buildings should be designed and built to be as handsome as possible. We are
sceptical that local planning authorities - or, worse, a centralised national body - can
pre-determine ‘beautiful design’. We fear that would be too prescriptive.
Architecture has to be appropriate to the precise location and topography - and that cannot
be prescribed by a kind of design algorithm.
Perhaps our greatest concern about these proposals relates to the scale of
development that may be imposed upon our rural district. We do not have faith
in a centrally devised algorithm calculating housing numbers in our district. We are pleased
that, since the consultation closed, the Government has announced it is revising the
proposal for a growth algorithm; and we await more information on this with keen interest.
All our subsequent comments should be read with this strong reservation in mind.
Subject to local planning authorities having adequate time and resources, we are open-
minded about the concept of identifying Growth areas. But we are very concerned that the
30-month timeframe is not adequate. We still believe that the new settlements they comprise
must be subject to close scrutiny from the local planning authority. As we accept the need
for new homes in this cycle, we welcome the ambition of speeding up development in sites
identified for housing growth. But by both significantly curtailing the process for identifying
those sites and then also significantly
streamlining the process for giving planning approval,
we are concerned that these proposals will lead to a loss of local expertise and democratic
oversight. Speed must not compromise quality.
The proposals for Renewal areas are problematic for us, and we would need to see
more detail about how they might work in our market towns and villages before we could
support them. We would resist suggestions about the ‘statutory presumption in favour of
development being granted’ as this indicates little or no detailed planning permission would
be required. Yet we know that building development within existing settlements inevitably
impacts on existing residents, and that permitted development already causes resentment
and anger. Residents’ opinions about the detail of proposed development need to be taken
into account. If Renewal areas are to be included in the final proposal of these reforms, the
areas would need to be identified in the Local Plan with great detail.
The proposals for securing planning permission in ‘Protected’ areas seem appropriate.
More practically, we are nervous that the massive changes proposed in this White
Paper would just not be manageable in the timeframe envisaged here. We question
how long it would take local planning authorities to develop the expertise, and for the
various digital technologies to be embedded and sufficiently tested. And we fear that
any shortcomings that come from applying the new systems too quickly would leave
all parties exposed to lengthy and expensive legal challenge, and local communities at
risk of unsustainable development.
While we welcome the proposal to allow for some of the uplift in the value of land
designated for development to be levied by the local authority to pay for
infrastructure, we are disappointed that the White Paper is silent on powers the local
planning authority might have to encourage developers to build-out sites on which
they have planning consent.