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RTPI's detailed response to planning reforms announcement

10 July 2015

Janet Askew, President of the Royal Town Planning Institute (RTPI) said: 

Janet Headshot“Central and local government need to prioritise planning within their spending plan in order to deliver vital housing through local plans. It is encouraging that the government remains committed to the plan-led system and to community involvement. We welcome proposals to speed up plans and will continue to discuss these with government, but are under no illusion that close attention to the real drivers behind the issue of speed and commitment must be paid. The reasons for slow local plan delivery are complex.” 

 This is what the government's media briefing last night said about some of the key proposals.

General comments on the Productivity Plan:

  • As a founder member of the Homes for Britain (HfB) campaign, the RTPI is welcomes further action being taken to address the housing crisis. Our institute was founded to deal with a previous housing crisis in 1914 and this matter is of utmost concern to us.  However sorting out the crisis of housing affordability goes far beyond the mere generation  of permissions for housing units. Otherwise the granting of permissions of 261,000 units in the last year would have solved many of the problems.
  • We welcome Sajid Javid’s statement this morning that “every part of government will be involved.” This has not been the case in the past. It is vital that shortages of infrastructure, especially in schools, health and transport, are addressed, so that when land is allocated or permitted it can be developed properly and promptly, and places fit for the future are created. Planning services have also undergone dramatic cuts since 2010 and this is another issue which needs to be addressed.
  • We are also strongly supportive of moves to increase the productivity of England, and in particular the core cities. If these were raised to the national mean, there would be an increase in English GDP equal to the state of Denmark. We agree that devolution to cities and counties is important in both raising productivity and increasing housing supply. With housing being linked to so many other budgets, local decision making over more budgets should assist getting stalled sites working.
  • The government’s Productivity Plan is confusing in relation to territorial designations. For example in chapter 9 on housing, it would help if the plan made it clear at the beginning that it is not about “the UK” as it says in paragraph 9.1 but about England only.
  • Quoting selective research on “the costs of planning”, as the productivity plan does, repeating many similar statements by the Treasury, is a highly selective argument from a particular viewpoint and not helpful. Proper planning has “benefits” as well as “costs” and ensures the coordination of infrastructure investment and housing growth. Absence of this coordination is continuing to be a serious problem which contributes to the opposition to housing development.

Plan making

The government will publish league tables, setting out local authorities’ progress on providing a plan for the jobs and homes needed locally. Where they are not, the Secretary of State for Communities and Local Government will arrange for local plans to be written, in consultation with local people. The government will bring forward proposals to significantly streamline the length and process of local plans.

Central and local government need to prioritise planning within their spending plans, in order to deliver vital housing through local plans. It is encouraging that the government remains committed to the plan-led system and to community involvement. We welcome proposals to speed up plans in England and will continue to discuss these with government, but are under no illusion that close attention to the real drivers behind the issue of speed and commitment must be paid. The reasons for slow local plan delivery are complex and include lack of resources, and lack of prioritisation. A key problem is that adopted local plans do not cause the release of resources for schools, health and transport, so making the case for them is difficult at local level.

The government will strengthen guidance to improve the operation of the duty to cooperate on key housing and planning issues.  

We welcome the government’s commitment to cooperation between English local authorities to provide sufficient housing land. However again this needs firstly to be coordinated with the activities of Local Enterprise Partnerships, and then incentivised through careful use of City Deals and Growth Deals to reward it as we argued in Planning in the next Parliament

The government will consider how policy can support higher density housing around key commuter hubs.

Transport hubs do indeed provide suitable locations for higher density development as we have identified in our research. But the government should go further and be committed to using development as a means of funding additional capacity, not simply reacting to existing transport infrastructure.

Additional storeys on homes

Working with the Mayor of London, proposals to end to the need for planning permission for upwards extensions for a limited number of storeys up to the height of the adjoining building in the capital.

Over the past few years there have been numerous amendments to the permitted development regime. The RTPI calls for stability in the planning system and does not think it is necessary to make further changes to the regulations.  This kind of proposal could profoundly change the character and face of London with undesirable and ugly streetscapes, and objections from neighbours.  We understand that these proposals currently will require no objection from neighbours. There is also a risk that – as with other permitted development changes – the burden of work reduces little for local authorities but the fee income is considerably reduced. We will examine these proposals very carefully.

Central and local government need to prioritise planning within their spending plan in order to deliver vital housing through local plans.We welcome proposals to speed up plans and will continue to discuss these with government, but are under no illusion that close attention to the real drivers behind the issue of speed and commitment must be paid. The reasons for slow local plan delivery are complex.

Brownfield Land

The government will legislate to grant automatic permission in principle on sites identified on statutory registers of brownfield land suitable for housing.

The need to establish the principle of development is helpful. However a lot hangs on the definition of “suitable”. A lot of brownfield land is by no means suitable – being in remote locations. And just because land is suitable in principle for development does not mean that development at any scale would be suitable. There needs to be some ceiling on the scale set out in the register and there needs to be a means by which the impact on neighbours and the contribution to infrastructure is handled. Mere entry in a register is insufficient. The government referred in the past to the use of Local Development Orders and this seems a useful concept to explore.

The government is considering the case for these additional compulsory purchase reforms to further modernise the system. Certainly the use of CPOs is hugely daunting to local authorities and yet a more proactive role for land assembly is one of our housing recommendations. Improving the process will help, but so will spreading good practice.

National Infrastructure

The government will publish a new long-term National Infrastructure Plan for the key economic infrastructure sectors – transport, energy, flood defences, water, waste, communications and science.  

We have welcomed these plans in the past (which are a little confusing on the definition of “national”). However, in future it is vital that they must look carefully at the spatial implications of these public investments. We have said that this investment should be tied much more closely to evidence of joint plans to deliver the housing needed to support it.

Vehicle Excise Duty will be ring fenced in a Roads Fund. 

Road traffic generates substantial negative externalities which must be accounted for somewhere. Will this Fund include a mechanism for achieving this?

Devolution

The government is working towards further devolution deals with the Sheffield City Region, Liverpool City Region and Leeds, West Yorkshire and partner authorities, and has made substantial commitments to Greater Manchester.

We welcome the reference to housing and planning within some of these arrangements, as without coordinated action on this front no progress on productivity will be lasting.

Development Control

General points: 

We have previously argued that the NSIP regime should be extend to mixed use schemes so support this move. We maintain that there is a lot more to quality in development control than simply “processing applications”. (This extremely limited view of planning as simply regulatory cost with absolutely no benefit continues to carry extraordinary weight in the Treasury.) We support however the prompt operation of development control and urge councils to provide sufficient funds to enable the development control system to function. They may need also to look to the development industry to assist here.  Planning services has been cut by 40% since 2010 and it will struggle to achieve these performances measures if this is not addressed.

The government will implement regulations to exempt starter homes from the Community Infrastructure Levy, and re-affirming through planning policy that section 106 contributions for other affordable housing, and tariff-style general infrastructure funds, will not be sought for them.

This proposal ignores the impact that any new homes have on infrastructure and no proposals for making up this loss have been put forward. Whilst a commendable goal, it risks creating undesirable side effects.

The government has said that it will not procede with the zero carbon Allowable Solutions offsetting scheme or increase on-site energy efficiency standards.

Allowable Solutions had been introduced in the 2015 Infrastructure Act, and this sudden change in direction will undermine the Zero Carbon Homes agenda and create uncertainty for house builders. The Government must ensure that existing energy efficiency standards are sufficient to meet commitments under the Climate Change Act and the EU Energy Performance of Buildings Directive, and that sufficient investment is in place to support low-carbon energy infrastructure for both new and existing buildings.

Skills and human capital

The government says it wants:

  • A highly skilled workforce: including introducing a new compulsory apprenticeship levy requiring large businesses to invest in their own future, and radically streamlining further education qualifications.
  • World-leading universities, open to all who can benefit: including removing the student cap and ensuring the sustainability of investment in universities by replacing maintenance grants with loans for new students.

Future PlannersTown and spatial planning is now one of the top 10 University courses for getting a job within 6 months and a key professional activity in delivering the right type of developments. 

The RTPI welcomes the proposals on apprenticeships in England as the Institute is already looking to diversify access into the planning profession.  Our Town Planning Technical Support Apprenticeship framework is being piloted in a number of locations from September 2015.

We are already engaging with government and starting the conversation with employers and university partners on options for degree level apprenticeships and future RTPI accreditation.  The RTPI therefore welcomes the opportunity for professional institutions to design qualifications alongside employers at the new ‘Institutes of Technology’. Government proposals for streamlining the number of professional and technical qualifications could link to the Institute’s ongoing Routes to Membership project.

We note the proposed extension of undergraduate, postgraduate and research loans but university education must remain affordable and attractive for home students.

The RTPI Future Planners bursary scheme is in operation with sponsorship from universities, the private sector and Scottish government.  

More information

Read the government’s productivity plan “Fixing the foundations: Creating a more prosperous nation.”

Read the government press notice