Having raised concern about the impact of poor resourcing in planning departments, we were pleased to see that planning fees are to be increased by 20 per cent in the Summer. Whilst the jury is out on the relationship between income and performance, with skills and capacity being of equal concern, the additional income should be a welcome boost for local authorities at least in the short term.
Introducing competition to the planning process
We are glad that our concerns over the operational details of introducing competition into the planning application process have been taken into account, as this will not be taken forward without further consultation. We were particularly glad to see that the Government reported that the majority of respondents cited RTPI accreditation as a vital baseline for any alternative provider of planning application processing.
Many of our suggestions regarding proposals around affordable housing and Starter Homes seem to have been acknowledged, with a decision to roll the policy back; age caps will now be more flexible and the compulsory requirement for Starter Homes across all sites has been removed, in recognition of the potential impact that prioritising one product will have over other affordable housing requirements (although the general Duty to Promote will still exist in primary legislation).
Definition of a “transport hub” and strengthening policy on densification
When responding to the consultation on changes to national planning policy, we argued strongly that as proposed the definition of a "transport hub" was too general, particularly with reference to our study of commuting patterns in the green belt. As a result, the White Paper now makes a number of references (in chapter three) to “making more efficient use of land”; specifically in reference to transport hubs the Government's consultation response mentions that national policy will be strengthened in favour of allowing higher densities around such areas.
Transparency of small site and brownfield data
Linked to our concerns about local authority resourcing we were also pleased to see that small windfall site allocations have been left to local discretion, and proposals for local authorities to maintain a small sites register have not been taken forward, as per our recommendation.
[I]t’s hard to see how [the White Paper] will result in significant systemic changes in the housing market [but] the implications ...for planning practice are, for better or worse, significant.
On the subject of registers, some members will have noticed the absence of any further comment or consultation on brownfield registers and Permission in Principle. Regulations on the latter are expected in the Autumn. The RTPI has always supported the re-use of previously developed land, but we stress how important it is that these sites are actually in the right places. We were pleased then that the Government has acknowledged respondents’ concerns that access to employment and public transport are crucial factors in bringing forward brownfield and new settlements, and that the Government has also adopted this phrasing in the White Paper. Beyond these statements, however, we would like this made this clear in national guidance.
CIL and S106
Having responded to the CIL review questionnaire we were pleased to see the results of the CIL review have been published. The intention to consult further on a separate S106 dispute mechanism is welcome, as we had stated clearly in our response to the technical consultation, it is difficult to see how it could be treated separately from a planning appeal. Members can expect further announcements in the Autumn Budget.
Housing Delivery Test and Duty to Cooperate
The commitment to hold local authorities and developers to account for housing delivery has not been muted. Our main position in response to the consultation was to be realistic about how much responsibility can really fall at the door of local authorities for sites they do not own.
One suggestion of the RTPI’s was requiring authorities to have a buffer of reserve sites as a way to address housing under-delivery; this has been taken forward as one of three different sanctions, depending on the severity of the shortfall, to incentivise delivery. Introducing a requirement for local authorities to produce a statement of common ground, as a push towards more cooperation, is also a theme we have continually put forward, as per recommendations in our policy paper on strategic planning.
Addressing the issue of Green Belts and greenfield housing, our paper on where should we build more homes? suggests that after 60 years it is time to consider whether there should be an additional social purpose for Green Belts. We recommended in response to the changes to National Planning policy consultation that local reviews of strategic planning tools such as Green Belts are not necessarily the best way to address housing challenges. We therefore think it is sensible that the proposal to allow neighbourhood plans to allocate sites for Starter Homes in the Green Belt has been put aside, which aligns with our policy position on this.
Overall, while we have suggested that the Housing White Paper could herald a better debate on planning, it’s hard to see how it will result in significant systemic changes in the housing market along the lines of ideas we have suggested in our #16ways campaign. Nevertheless, the implications of suggested changes for planning practice are, for better or worse, significant.
Planners need to look forward; policy changes will have an impact on the ground. There are still terms of the NPPF, published five years ago, that are the subject of debate in the High Court. We hope that forthcoming changes can be implemented more smoothly, and the RTPI will continue to engage members in our discussions with Government.
Planning Policy Officer, RTPI - @HarryBurchill