You will no doubt have seen in local and national media that the government is consulting on radical changes to the current planning system whose framework was established by the 1947 Town and Country Planning Act.
The proposals and the consultation, open until 29th October, can be found here:
We will be responding to the consultation and we would encourage you to look at the proposals and submit your views. Our overall comments follow below.
Robert Jenrick, the Secretary of State for Housing, Communities and Local Government, says that the current system is complex and a barrier to building the homes people need. He has said that the changes will sweep away an outdated system, remove red tape and will build better, faster.
Others, such as The Town and Country Planning Association (TCPA) say that there is no sign that the planning system is standing in the way of delivering homes; they point out that more than 80% of around 400,000 annual planning applications are granted with under 0.5% going to appeal. And there are more than 1 million unbuilt homes with permission approved. Evidence to justify the proposed changes is largely absent from the proposals.
Changes are needed to the current planning system, for example, to ensure high quality, carbon-neutral, healthy homes and places. But we are concerned that the proposals will undermine local democracy and fail to achieve the high-quality places that we all want to see.
The main proposed changes are:
- Simplified zonally based Local Plans are to be established within 30 months.
- Areas will be defined as for Growth, Renewal or Protection.
- Outline Permission will be automatically given in Growth areas. In Renewal zones, permission will be given in principle subject only to basic checks.
- Local plans will set local design codes defining the standards and requirements for development.
- More emphasis on community engagement at the plan making stage.
- Design and sustainability changes:
- All new homes will be required to be carbon neutral by 2050.
- Automatic permission given for proposals with high quality developments
- Community Infrastructure Levy and section 106 agreements to be replaced by a new Infrastructure Levy with a nationally set charge.
It is not clear how these new proposals will work across all levels: strategic planning is not discussed, and neighbourhood planning is mentioned but how it will fit in is not covered.
One issue is clear – with the zonal Local Plans public consultation will only happen when the Plan is being drawn up. Once the Plan is approved then there will be no consultation on planning applications. This has been described as a ‘Developers’ Charter’ and is a significant loss of democratic involvement in the planning system.
Currently planning applications are assessed against a local plan on a case-by-case basis decided by a democratically elected planning committee of local councillors. Under the proposed changes planning permission will be awarded automatically if certain criteria are met. Whilst we do not always agree with the decisions of the planning committee, it is simply not acceptable that the public would not be able to comment on any planning applications and that they would not be subject to democratic oversight.
The scope of the proposed design codes is not given. Will they be just about aesthetics (the proposals mention ‘beauty’ in several places), or will they also cover matters such as light, space, access to play and freedom from pollution as advocated by the TCPA? Good design will not result from the automatic application of codes; and good planning is about much more than design.
There is undoubtedly significant unmet housing need, particularly of social rented and affordable homes. But there is nothing in the proposals that guarantees that the shortage of affordable housing will be addressed.
The current system is highly permissive and generally produces outcomes that favour the interests of property developers. What we need is more planning, not less. We need a system focussed on climate change, health, well-being and the powers needed to create high quality developments with sufficient decent and affordable housing.
Whilst we would support some of the points proposed, we fundamentally disagree with their broad thrust; namely the significant reduction in democratic accountability and the assumption that a more permissive approach with standardised codes will result in private developers providing more high-quality places and homes. Previous deregulation of planning control (such as granting automatic rights to change the use of buildings) has led to the production of sub-standard housing that lacks basic amenities and is poorly connected to jobs, schools and other facilities.
You can see the views of the TCPA and other planning experts at the following links:
TCPA press release following the publication of the proposals:
The views of Hugh Ellis, TCPA Policy Director:
The views of a group of planning academics and researchers:
The full report from this group: