October 29, 2020

Sebastian Weise

PlaceChangers responds to UK Government consultation on “Planning for the Future”

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Background

The UK Government has proposed wide-ranging changes to the planning system in England and provided those initial ideas in a white paper titled "Planning for the Future". The white paper tackles three aspects of the planning system in England along three pillars, including (1) how developments are approved; (2) how there can be a greater consideration for quality standards; (3) and lastly how infrastructure is funded on the back of development proposals. 

The Secretary of States foreword for the proposals are indicating the governments intent for a better and more equitable system. 

Our proposals seek a significantly simpler, faster and more predictable system. They aim to facilitate a more diverse and competitive housing industry, in which smaller builders can thrive alongside the big players, where all pay a fair share of the costs of infrastructure and the affordable housing existing communities require and where permissions are more swiftly turned into homes.

The government proposes to address the above three elements by a radical shake-up to the way the planning system is working now. On the high-level, this is built around three key aspects

  1. a simplified plan-led system, built around a series of zones that trigger different approval processes for new development;
  2. a codification and greater incorporation of design codes throughout the system; and
  3. a combined or somewhat consolidated infrastructure levy. 

Underlying these proposals, the government also puts a strong focus on complementary and connected digital tools to assist in the preparation of evidence bases, in the vetting of development proposals and plans against requirements.

PlaceChangers has now responded to the white paper consultation. Below we summarise key aspects of our response. 


PlaceChangers response


Timing of public involvement 

The white paper calls for the application of best-in-class engagement tools, but leaves the timing of any public engagement unclear. We suggested:


Development proposals

Design codes alone will not remove critical design choices and will need interpretation at the time of application. In exchange for the greater clarity given to development projects under permission in principle, new laws should ask for more opportunities of residents to be involved in the shaping of the development project, including through (1) an early-engagement stage, and (2) a pre-submission consultation to refine the design. 


Local plans

The proposals recognise engagement only at a call for sites stage and in a formal public enquiry. This is not enough. A background research stage should be introduced and done first (6 months) before the start of the ‘call for sites/ideas’ phase which would include a community engagement programme to help define different development trajectories and priorities.


Digitisation of plans

The plans call for the digitisation of plan-making and a return to spatial form as part of local plans through zoning and site-specific guidances. 

We are fully in support of this proposal. Honing the planning system toward these ends could facilitate collaboration and coordination, as well as increasing transparency and driving public buy-in. It certainly could also shorten turnarounds.

Government guidance should be provided on the level of the structure and format for the data standard.

A stepped approach should be considered whereby standards are developed for a local plan; and separate standards are developed for the structure of development applications; and master plans.


 

Focus on design codes

We support local design codes.

They are helpful to provide developers with a guide as to what is valued locally.

There are issues around codes, however, especially as developers will ask for amendments  based on their default house type standards or the particular scheme. 

PlaceChangers advocates a use of design codes at different levels of specificity, i.e., at high, medium and low levels in order to avoid ambiguity and ensure a comprehensive and coherent strategy-based plan. 

Going in line with comments made regarding public consultation on development proposals, the believe legislation should introduce greater scope for influencing site layouts and details of the proposed design to help translate design code guidance into actual development proposals. 



Neighbourhood plans

We advocate for the continuation of neighbourhood planning. 

Local plan guidelines and standards should be developed in such a way that neighbourhood plans can be prepared using similar approaches.

Neighbourhood plans need to be 'machine-readable' or available in a digital format. As neighbourhood plans could be helping in the establishment of locally-sensitive site-specific policies, and thereby help resource-constrained local authorities on the neighbourhood and local level. 


Consolidated impact appraisal of local plans

Merely asserting that “sustainable development” is “existing and well-understood” doesn’t make it so. The 2018 “Planning 2020” final report for the TCPA Raynsford Review (p43) is forthcoming on this point: “the 2018 NPPF creates its own unique definition of sustainable development which leaves out core internationally agreed principles.”

We believe that, on the contrary, it makes sense to incorporate the requirement for an evidence-based, digital appraisal of the sustainability of the local plan.

The National Government’s role on this point is to fund the commission of that evidence base.

PlaceChangers suggests the inclusion of health impacts as part of a combined impact appraisal, which would capture the particular characteristics of the local population and inequalities in access to key services, which can serve to provide clear targets for improved infrastructure delivery/use of the developer contributions to tackle inequalities and inbuilt health and wellbeing objectives. 


Financing infrastructure and affordable homes

PlaceChangers is supportive of a simplified infrastructure levy for construction and we appreciate the efforts to remove loopholes that exist in S106 and CIL. It’s specifically great to see that the new levy will apply to PDR. 


Timing and capture of levy 

PlaceChangers voiced concern about the move of the infrastructure levy to be charged against the final sales value of the development, as this causes potentially significant financial risk to local government if the market falls and subsequently any money committed to affordable housing from this scheme cannot be covered. 

For substantive projects, which take many years to complete, developers should be committed to pay part of the levy upfront; there should be safe guards against the eventuality of falling house prices. The charging of infrastructure at the point of completion opens the door to speculation for falling house prices, and potential stalling of the development as suitable to navigate infrastructure payments.


Greater transparency and involvement in use of levy receipts

The increase in the value capture should come with greater transparency about what these funds are to be invested for, which can be aided by digital technologies. There should be a greater linkage between the investment and the locality of the development.

And residents would ideally be involved and informed about the use of the contribution as part of early engagement on development proposals. There should be an opportunity for greater up-front discussions about the use of that money.

Again, going along with our call for the reformed law to clarify the engagement stage for all major development, even if ‘fast-tracked’.


Affordable homes

The consolidated levy should aim to secure more on-site provision than S106 currently does.

An in-kind contribution is preferred as it has a greater chance to deliver mixed-tenure developments on site, while also increasing certainty of the timing of provision. 

If affordable housing is provided in-kind by the developer, additional guidelines should be given by law about the following aspects:

  • Definition of a minimum quantum of affordable housing sites.
  • LPAs should have power “to specify the forms and tenures of the on-site provision” is needed as part of the site layout.
  • A minimum standard for quality should apply to the site as a whole and that this should include affordable housing. The Building for Healthy Life or similar criteria should also apply to affordable housing.
  • Definition of standards for master plan quality that uphold access to high-quality infrastructure for affordable homes on the same level as for market housing on site.


Ends 


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