Response to The Planning White Paper
Published: 29 October 2020
Lindfield Parish Council (LPC) welcomes the opportunity to consider changes to the planning system and had hoped that the proposals would provide for delivering housing to address evidenced need alongside improved accountability at a local level, reflecting the desire for open government and underpinning effective democratic accountability. LPC agrees that the existing system is (over)due for updating given its inflexibility and evident limited ability to reflect local circumstances and plans; which had been drawn up following substantial effort by local councils and residents in line with previous government policies. There is a distinct danger that residents will feel further disenfranchised if the changes do not evidence full consideration of the likely impact on existing communities.
It is therefore extremely disappointing that the proposals appear to propose exactly the opposite approach, with less democratic accountability, a simple three tier approach which effectively creates two zones with enhanced scope for developers and a third which, whilst it is proposed will have stringent controls, is limited in its application. The statutory presumption in favour of development envisaged across these Local Plans further undermines the credibility of the proposed approach and, in practice, is likely to ride roughshod over local residents views and indeed, the actual quality and design of housing development.
Perhaps most importantly, the proposals fail to address the key sticking point in delivering additional housing; developers who are sitting on planning permission for a million homes which have already been granted but are not being built. Removing this blockage, which appears to be driven by the developers’ quest to maximise a long term pipeline of profits for their shareholders rather than delivering in line with the government’s wider policy for three million homes over ten years to meet buyers’ needs, is a more pressing issue than as is proposed; reducing residents ability to contribute to local planning and development.
There are a number of specific areas of concern:-
- The removal of sustainability appraisals at the same time as sustainability issues are gaining traction worldwide, increasingly across all generations and, as identified during the early Covid travel restrictions, that reduced commuting and travel could be beneficial to the environment, family life and local as opposed to global businesses. The proposals appear to rely on the passing of a simple test rather than the likely effectiveness of delivery. That carbon reduction, climate adaption and flood resilience are not addressed as part of these proposals is both disappointing and suggests a rushed rather than fully considered approach to the white paper.
- Local plans being reduced simply to design codes as opposed to a full consideration of the needs of the area. At the same time, the proposals lack proper consideration of a strategic and regional plan or the relationship with the National Infrastructure Strategy.
- The central National Planning Policy Framework (NPPF) becoming the primary source of policies for development management, as the Local Plans are further denuded.
- The use of an algorithm to calculate housing needs; whilst appropriate methodology is essential to ensure housing is built where is it needed, as proposed the calculation appears to exacerbate growth where such has been seen in the past, regardless of whether or not that was due to particular local circumstances which may or may not still apply. This approach seems likely to inflict areas of historic high growth with even more growth, whether or not it is appropriate, and condemn areas where growth is sorely needed only to be further restricted, with consequent economic and social damage, potentially further worsening the north / south divide.
- The restriction of community consultation to only the plan making stage as opposed to the existing ability to comment on individual proposals, thereby removing the substantive element of residents’ involvement. Such apparently being further limited to a digital approach, putting those without the necessary IT skills or equipment at a disadvantage.
- The lack of clearly articulated mechanisms to deliver the appropriate infrastructure (e.g. schools, medical facilities, sustainable transportation) at the right time. Similarly there is little clarity on how or whether the proposed infrastructure levy will deliver more than present approaches or will indeed be sufficient to deliver either infrastructure or appropriate levels of affordable housing for those in need.
In LPC’s view the proposals are in fact the antitheses of local democracy and decision making, reducing local involvement to a theoretical housing design role, with all material decisions driven by a policy focussed on central government and supporting developers’ rather than residents’ interests. Accordingly, LPC strongly objects to the current proposals and asks that a far more inclusive approach is drawn up to both provide increased housing in line with properly evidenced need, in the right locations to support both individuals requirements and economic imperatives across the breadth of the country.