IHBC on England’s ‘Planning for the future’: Aspects to be cautiously welcomed but alarm over local plan proposals founded more on legacy of prejudice than power of evidence

Posted on 08/08/2020 by IHBC NewsBlog
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While provisionally welcoming [many] aspects of the England’s White Paper consultation on ‘Planning for the future’ (closing 12 weeks from 6 August), the IHBC has registered its serious concern over a ‘worryingly simplistic’ strategy for local plans highlighted by Robert Jenrick in his recent Telegraph article: Proposal 1’s ‘categorisation of land into areas of growth, renewal or protection’, that seems more of a ‘pickle or perish’ approach rooted in ‘the failed prejudices of the past’, when government should instead ‘pay due attention to the evidence’.

image: Open Government Licence v3.0

…IHBC has registered its serious concern over a ‘worryingly simplistic’ strategy for local plans…

IHBC President Mike Brown said, ‘It is a relief to see government still recognising the importance of heritage protection alongside environmental care and sustainability – especially in its Proposal 17, on ‘Conserving and enhancing our historic buildings and areas in the 21st century.’

‘However it is also essential to recognise that the need for new housing and its infrastructure – identified across the consultation – cannot be met through dismantling a planning system that has done so much in recent decades to marry and resolve development and community pressures.’

…relief to see government still recognising the importance of heritage protection alongside environmental care and sustainability…

‘We can only hope that the consultation’s conclusions will move beyond a reliance on the prejudices of the past and pay due attention to the evidence.  The planning system has granted consent for hundreds of thousands of houses in the last decade, a significant number of which have not been built.  It is not the planning system that is at fault, much though it suits some in the development world to claim so.  A critical eye should be cast over the ‘restricted supply’ policies of some large house builders.’

‘The evidence, which we trust Mr Jenrick will examine, points to the fact that England has always endured inadequate housing whenever it has relied on exclusively private provision.  Price and share values will always trump the housing needs of the wider population.  The lessons of history show that while the actions of 19th century Quakers and philanthropists did much to provide decent housing for a lucky few, for others, trapped within gross social inequality, job insecurity and stagnant wages, it was only the moral forces behind ‘Homes for Heroes’ after WWI and the bi-partisan public housing drives after the Blitz in WW2 that saw decent housing for the majority.’

…England has always endured inadequate housing whenever it has relied on exclusively private provision.

‘A government-led joint strategy linking a properly motivated private sector and a revitalised public sector, might well deliver the desired numbers and quality of homes Britain needs, but would be dependant on a properly skilled and resourced pro-active planning system to deliver it.’

IHBC Chair David McDonald said: ‘We can welcome the consultation headlines that focus on local communities, environmental care and sustainable development alongside conservation.  However, there are also many alarming notes for those of us who consider that planning, including the protection of the historic environment is a complex and creative activity requiring a sophisticated regulatory system that allows these different areas to interact effectively, building synergies and adding value.’

Design codes have a place in planning, but not at the expense of masterplanning and inspired urban design.

‘While we can all understand the need to kick-start the economy following the pandemic, it should not be at the expense of all the lessons that have been learned over the years.’

The local plan categorisation of land into areas of growth, renewal or protection is worryingly simplistic in its approach and seeks to put into separate ‘planning boxes’ activities that are by their nature interlinked. Taking the redevelopment of Kings Cross in London as an example, renewal and protection worked together to produce a development that is admired across the UK and beyond. We should move towards a better post-pandemic planning world by having a system built on new ‘four Cs’ of development: Community, Climate change, Conservation and Creativity.’

…planning, including the protection of the historic environment is a complex and creative activity requiring a sophisticated regulatory system…

‘Design codes have a place in planning, but not at the expense of masterplanning and inspired urban design. Recent and proposed changes to permitted development have shown that prioritising speed of decision-making over quality leads to unintended consequences. The conversion of office blocks to apartments with seriously inadequate residential amenity is an obvious example.’

I would urge the government to re-think these elements of its approach and rather than put areas in categories, (as one of my colleagues suggested) of ‘perish or pickle’, but to improve planning and conservation as holistic and creative activities’.

The Government White Paper ‘Planning for the Future’ writes:

This consultation covers a package of proposals for reform of the planning system in England, covering plan-making, development management, development contributions, and other related policy proposals…

Pillar One – Planning for development

… The starting point for an effective planning system is to establish a clear and predictable basis for the pattern and form of development in an area. The current system of land use planning in England is principally based on local plans, brought forward by local planning authorities on behalf of their communities. But in contrast to planning systems in places like Japan, the Netherlands and Germany, where plans give greater certainty that development is permitted in principle upfront, plans in England are policy-based, with a separate process required to secure permission on the sites that it designates for development.

  • Proposal 1: The role of land use plans should be simplified. We propose that Local Plans should identify three types of land – Growth areas suitable for substantial development, Renewal areas suitable for development, and areas that are Protected.
  • Proposal 2: Development management policies established at national scale and an altered role for Local Plans.
  • Proposal 3: Local Plans should be subject to a single statutory “sustainable development” test, replacing the existing tests of soundness.
  • Proposal 4: A standard method for establishing housing requirement figures which ensures enough land is released in the areas where affordability is worst, to stop land supply being a barrier to enough homes being built. The housing requirement would factor in land constraints and opportunities to more effectively use land, including through densification where appropriate, to ensure that the land is identified in the most appropriate areas and housing targets are met.
  • Proposal 5: Areas identified as Growth areas (suitable for substantial development) would automatically be granted outline planning permission for the principle of development, while automatic approvals would also be available for pre-established development types in other areas suitable for building.
  • Proposal 6: Decision-making should be faster and more certain, with firm deadlines, and make greater use of digital technology
  • Proposal 7: Local Plans should be visual and map-based, standardised, based on the latest digital technology, and supported by a new template.
  • Proposal 8: Local authorities and the Planning Inspectorate will be required through legislation to meet a statutory timetable for key stages of the process, and we will consider what sanctions there would be for those who fail to do so.
  • Proposal 9: Neighbourhood Plans should be retained as an important means of community input, and we will support communities to make better use of digital tools
  • Proposal 10: A stronger emphasis on build out through planning

Pillar Two – Planning for beautiful and sustainable places

… improving the process of planning is only the starting point – we want to ensure that we have a system in place that enables the creation of beautiful places that will stand the test of time, protects and enhances our precious environment, and supports our efforts to combat climate change and bring greenhouse gas emissions to net-zero by 2050….

  • Proposal 11: To make design expectations more visual and predictable, we will expect design guidance and codes to be prepared locally with community involvement, and ensure that codes are more binding on decisions about development.
  • Proposal 12: To support the transition to a planning system which is more visual and rooted in local preferences and character, we will set up a body to support the delivery of provably locally-popular design codes, and propose that each authority should have a chief officer for design and place-making.
  • Proposal 13: To further embed national leadership on delivering better places, we will consider how Homes England’s strategic objectives can give greater emphasis to delivering beautiful places.
  • Proposal 14: We intend to introduce a fast-track for beauty through changes to national policy and legislation, to incentivise and accelerate high quality development which reflects local character and preferences.
  • Proposal 15: We intend to amend the National Planning Policy Framework to ensure that it targets those areas where a reformed planning system can most effectively play a role in mitigating and adapting to climate change and maximising environmental benefits.
  • Proposal 16: We intend to design a quicker, simpler framework for assessing environmental impacts and enhancement opportunities, that speeds up the process while protecting and enhancing the most valuable and important habitats and species in England.
  • Proposal 17: Conserving and enhancing our historic buildings and areas in the 21st century
  • Proposal 18: To complement our planning reforms, we will facilitate ambitious improvements in the energy efficiency standards for buildings to help deliver our world-leading commitment to net-zero by 2050.

Pillar Three – Planning for infrastructure and connected places

… securing contributions from developers and capturing more land value uplift generated by planning decisions to deliver new infrastructure provision – is key for both new and existing communities. It is also central to our vision for renewal of the planning system….

  • Proposal 19: The Community Infrastructure Levy should be reformed to be charged as a fixed proportion of the development value above a threshold, with a mandatory nationally-set rate or rates and the current system of planning obligations abolished.
  • Proposal 20: The scope of the Infrastructure Levy could be extended to capture changes of use through permitted development rights
  • Proposal 21: The reformed Infrastructure Levy should deliver affordable housing provision
  • Proposal 22: More freedom could be given to local authorities over how they spend the Infrastructure Levy

See the White Paper ‘Planning for the Future’ consultation launch notice

See the consultation

Download the most accessible text of the White Paper

For the Telegraph article (Restricted access) see Telegraph article

See also (Some restricted):

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