Our Comments below & Call to Action ‘CHANGES TO THE CURRENT PLANNING SYSTEM CONSULTATION ACROSS ENGLAND’ by  Central Government

read and respond here  – needs to be responded to by end of September  –  https://www.gov.uk/government/consultations

An interesting take on the document can be found here

Here is our take on the Government’s Consultation which we will respond to as a Civic Society –

  1. This document is to be viewed alongside ‘Planning for the Future’, which needs to be responded to by end of October “Planning for the Future” https://www.gov.uk/government/consultations – read and respond here 
  2. Government wants to improve the planning system but says it can’t be tweaked – needs to be a new creation. Proposals involve fundamental reforms of the planning system to improve its effectiveness; a) Changes to the Standard Method currently used for assessing local housing need; b) Securing of First Homes, sold at a discount to market price for first time buyers: c) Temporarily lifting the small sites threshold below which developers do not need to contribute to affordable housing, up to 40-50 units; d) Extending the current Permission in Principle to major development so landowners and developers now have a fast route to secure the principle of development for housing on sites; e) Including making sure Neighbourhood plans are robust, fit for purpose and respected, the government hopes; f) Overall strategy is too fast enable planning permissions that stand up and don’t have to go to appeals system; g) Numbers are key – no dodging the government’s requirements for a million dwellings during their parliament to be built out; h) The new requirement for fast tracked (30 months) Local Plan development will be the only time for the provision for local consultation and embracing – e.g. Flooding. Once agreed the LP will stand for 8 years unchanged.
  3. The new Standard Method for assessing local housing need wants to identify sufficient land for housing over at least the next 15 years so that the current under-delivery of necessary housing is remedied. A base line is to be established which is the higher of 0.5% of existing housing stock or the latest projected average annual housing growth over a 10 year period. This is then adjusted for market signals such as affordability in certain areas.

By using statistical growth it puts homes where there is current development not where they are needed. Its hypothesis is to over provide on the housing target of 300,000 per annum by giving a mandatory requirement on Local Authorities of 337,000 because ‘not all homes that are planned are built’ and ‘the new Standard Method is designed to provide enough land to account for the drop-off rate between permissions and completions’.

  1. The government’s intention is to provide a minimum of 25% of all affordable housing units secured through developer contributions as first time homes. The adjustment for affordability will never do what it intends. Why would homes be offered at a lesser margin when the build rate can be reduced and homes can be eked out to match demand at higher prices? Surely it is better for Local Authorities to insist that schemes are revised to reflect the demand for affordable houses in each relevant area rather than let developers be granted planning permission for larger dwellings that are unlikely to be built until the demand improves nationally and locally. Developers will be still able to provide contributions for off-site affordable housing but this tends to create ghettos rather than a cohesive mix of dwellings.
  2. It is proposed to introduce an exemption from the Community Infrastructure Levy for first time homes. Small and medium sized developers will be allowed to defer Community Infrastructure Levy payments to assist their cash flow.
  3. It is proposed to raise the small sites threshold to up to 40/50 new homes. There could be an adverse effect if developers attempt to bring forward larger sites in phases of up to 40/50 homes.
  4. It is proposed to grant extension of the Permission in Principle consent regime for major developments. The first stage will establish whether a site is suitable for housing and this will last for 5 years without conditions being attached to it. Unless contested under the new ‘Planning for the Future’ legislation landowners will be able to offer siters up for consideration far in excess of those currently envisaged. At present there are 1,000,000 homes in England for which planning permission has been granted but not built. This, at 300,000 per annum, is over 3 years requirement. This, along with the 187,000 per annum already in adopted local plans, would give more than 8 years supply at 300,000 per annum. The government needs to concentrate on what powers it will give Local Authorities to enforce developers to fulfil their responsibilities. Developers should be given more encouragement to use brownfield sites rather than more easily processed green field sites.
  5. In summary the following should be incorporated into the reform of the planning system.
  • Homes should be built where they are needed not determined by a ‘one size fits all’ formula.
  • Development should be led by plans set by Local Authorities together with their residents.
  • Developers should be forced to build the houses for which they have received planning permission. This is fundamental.
  • Developers’ ability to avoid obligation through viability should be removed.
  • Contributions to build all relevant infrastructure should be established at an early stage of any development. Or be made a pre-condition of approval/commencement.
  • Percentages for affordable homes should be set locally.
  • Any changes to the planning system should require primary legislation.
  • The 5 year land supply should be scrapped.

so there you have it – complicated, incomplete and above all feels rushed – what do you want us to do about this consultation?

Leader of Wokingham Borough Council had this to say in conclusion – “The “Changes to the current planning system” running alongside it has an end date is October 1. This has the meat. No debate! No appeal! It only needs ministerial approval, implementable by a simple decision on his behalf. This paper changes the standard method, allows for fifty homes to be built without affordable housing, extends the permission in principle consent regime and has first time homes discounts. It does all of these within the existing planning system.”  

Another interesting take on the future of Surrey was highlighted recently – concerning how County Level planners come together to develop strategy that affects us all….. hover over the titles to bring up the documents.

Here is another way of putting our concerns –

These proposals change the planning system to one that is led by developers as opposed to by the people through heir local council. This completely undermines localism.

Introducing a new standard methodology for calculating housing need would increase Waverley’s annual allocation for 590 dwellings to 835 dwellings. As usual London and the South East is earmarked as the most concentrated area of growth (London and the South East) however it is also one of the most constrained areas, e.g. by the Metropolitan Green Belt. This puts enormous pressure on the limited areas of countryside beyond the green belt, like Cranleigh. There is no consideration for the consequences of large numbers of houses being concentrated in these ever decreasing areas, not selected because they are sustainable locations but purely because they do not have the policy constraints of the green belt. Developers have no incentive to build excessive housing in these areas as their objective is to maintain high housing prices, they therefore trickle feed the housing which does not match the delivery numbers required by the Gov and forces more planning permissions to be granted as a 5 year housing supply becomes impossible to maintain. This proposal puts even more pressure on small market towns and villages which do not have the supporting infrastructure and effectively creates unsustainable dormitory towns with a heavy reliance on the private car.

It is also difficult to understand why Woking’s numbers will be reduced under this proposal, despite the supporting infrastructure and more urban dense residential areas, and particularly when Waverley’s allocated housing numbers were increased to meet 50% of Woking’s unmet need?

These numbers that will have to be concentrated in small areas across our borough will have a significant and negative effect on our natural environment which is already facing huge challenges with increased growth and climate change. We are already in an area of water stress and this is becoming more apparent each year when residents have repeated interruptions in water supply, necessitating the reliance on deliveries of bottled water. These proposals also do nothing to tackle the substantial numbers of planning permissions nationally and locally that have already been granted and that have not been delivered by developers. In fact the opposite is true, this proposal could facilitate even larger land banks and slower delivery manipulating the housing market for profit but not for the benefit of the wider population.

The new standard methodology does not take account for the impact on the economy and on residents from Covid-19 and it would appear that any methodology based on 2018 figures is now fundamentally flawed. In fact it would seem negligent to even propose altering the planning system under the current circumstances when the future of the economy is subject to so many variables, including a downward trend of house prices or even a collapse, which could result in policy which is not fit for purpose.

The far reaching impacts of the pandemic will begin to become clearer towards the beginning of next year, any review of the planning system should be deferred until these impacts are understood and can be taken into account. This is especially pertinent to affordability criteria which the proposals assume requires intervention by way of higher housing numbers to reduce prices. However this does not take into account the real prospect of a generally weakened economy from Covid-19 and conversely could actually contribute towards the collapse of a downward local market by this constructed intervention forcing over supply.

First Homes just looks like Starter Homes rebranded. There were no homes delivered under the Gov starter homes initiative and it was not even welcomed by the developers. This intervention by Gov in the housing market could have the effect of artificially propping up house prices. It is widely recognised that the need for low income households is for rented homes as this is the cheapest way to keep a roof over people’s heads. This proposal would undermine the delivery of more affordable rented homes and divert support away from those most in need.

Existing shared ownership schemes are more affordable than First Homes and imposing a 25% level of First Homes on development sites would also negatively impact on their delivery. Will be CIL exempt.

Increasing the small sites threshold from 10 to 40/50 dwellings would detrimentally impact the amount of affordable housing that is delivered across the borough. Particularly bearing in mind that areas like ours rely on many small sites to deliver new housing and we don’t have that many very large sites, so opportunities for affordable housing would be limited by this proposal. With this and the First Homes proposal really impacting on the amount of affordable rented homes that can be delivered.

Th proposal to remove the restriction in the current Permission in Principle regulations on major development appears in the main to be linked to the initial cost to developers only. With 9 out of 10 planning applications approved it is difficult to understand why this should be necessary. Major development has far more impact on an area and it is difficult to understand how these impacts can be suitably investigated over the required 5 week decision period. It also limits the ability of local residents to comment on major applications with major effects on an area.

Deadline 1 Oct

 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/907215/200805_Changes_to_the_current_planning_system_FINAL_version.pdf