RTPI response to the Land Use Consultation

About the RTPI

The Royal Town Planning Institute (RTPI) champions the power of planning in creating sustainable, prosperous places and vibrant communities. We have over 27,000 members in the private, public, academic, and voluntary sectors. Using our expertise and research we bring evidence and thought leadership to shape planning policies and thinking, putting the profession at the heart of society's big debates. We set the standards of planning education and professional behaviour that give our members, wherever they work in the world, a unique ability to meet complex economic, social environmental and cultural challenges.

 

1. To what extent do you agree or disagree with our assessment of the scale and type of land use change needed, as set out in this consultation and the Analytical Annex?

Strongly agree
Agree
Neither agree not disagree
Strongly disagree
Don't know

The RTPI agrees that the scale of land use change required to deliver 1.5 million homes and infrastructure is generally small, particularly if we are able to coordinate land use to achieve multi-functionality.

This coordination role should be the long-term goal of the Land Use Framework, alongside other national-scale spatial plans, such as the Strategic Spatial Energy Plan and other sectoral plans for infrastructure. To this end, the RTPI calls for a National Spatial Framework for England to mediate between these different plans and to resolve conflicts.

This is also in line with existing evidence, such as research by RSPB (2024, ‘Ambitious onshore renewable energy deployment does not exacerbate future UK land-use challenges’).

2. Do you agree or disagree with the land use principles proposed?

Strongly agree
Agree
Neither agree not disagree
Strongly disagree
Don't know

We support all of the five principles proposed.

Particularly on co-design, vertical alignment between the national, regional and local scales of spatial plans will be important. This should go beyond top-down requirements for local and regional spatial plans to align with the Land Use Framework. Instead, there should be bottom-up opportunities for these smaller scale plans to feed into the Framework. Communities should be given opportunities and support to engage with the vision shaping for future land use.

On responsive by design, standardisation and sharing of data, this is a challenge in planning that needs to be addressed before the Land Use Framework can be truly responsive to new data. As such, we support MHCLG’s current work on data standardisation and sharing for local authorities’ planning departments. 

On ‘playing to the strengths of the land’, clarification is needed for the meaning of ‘priority’ – for example whether it refers to greater protection. The term ‘spatially sensitive’ can also benefit from clearer definition.

3. Beyond Government departments in England, which other decision makers do you think would benefit from applying these principles?

✓ Combined and local authorities (including local planning authorities)

The Government has set out its plan for local government reorganisation and strategic planning in the English Devolution White Paper and the Planning and Infrastructure Bill. The expectation is that there will be full coverage of Spatial Development Strategies across England, prepared by combined authorities, combined county authorities, upper-tier county councils or unitary authorities.

These principles would be relevant to the preparation of Spatial Development Strategies and local plans.

The current consultation does not set out how different tiers of plans should interact with each other. The Land Use Framework and its associated principles should have effect on each layer of plans but requirements should be proportionate to scale, i.e. those for combined authorities and local authorities should be different.

The principles will also be relevant to the preparation of Local Nature Recovery Strategies. By applying the principles of ‘multifunctional land’, ‘playing to the strengths of the land’ and ‘decisions fit for the long-term’,  LNRSs could evolve into Local Environment Improvement Plans in the long run, taking a holistic view towards nature, climate change and the environment.

✓Landowners and land managers (including environmental and heritage groups)

Others (please specify)

4. What are the policies, incentives and other changes that are needed to support decision makers in the agricultural sector to deliver this scale of land use change, while considering the importance of food production?

Policies should take a holistic view of the agricultural sector. The considerations should go beyond food production fields but also cover topics such as built structures (e.g. glass houses), energy use and infrastructure serving the area (e.g. transport). This would allow us to recognise the agricultural sector as one that encompasses communities living and working in the area, with diverse needs.

This would then unlock multifunctionality thinking, making sure we consider how we use our land to support the many activities in these environments. To this end, policies on land use should be connected to the wider policies on housing, nutrient neutrality, water and flooding. This will help decision makers mediate between competing objectives.

The Land Use Framework should have weight in planning policies. This would ensure decision makers in planning take a holistic view in the delivery of housing, infrastructure and amenities to the agricultural communities. Lessons can be learnt from Scotland, where the Land Use Strategy was referred to in the nation’s National Planning Framework 4. Implementation is further secured through Regional Land Use Partnerships.

 

5. How could Government support more land managers to implement multifunctional land uses that deliver a wider range of benefits, such as agroforestry systems with trees within pasture or arable fields?

Government should encourage regenerative practice to secure multiple benefits, such as biodiversity net gain, effective use of land and maintenance of soil quality.

Currently these initiatives are funded through siloed pots of money, such as the Landscape Recovery scheme under the Environmental Land Management schemes. These schemes have provided valuable support for land managers – particularly at the beginning stage of a long-term initiative (see Nattergal as an example). However, more permanent, stable availability of funding will be crucial to scale these initiatives up. Such long-term funding will also recognise the role of the current generation as custodians of land and our natural environment.

Local Nature Recovery Strategies (LNRSs) provide an excellent framework for coherent delivery. As such, government schemes and support should be linked to the relevant LNRS. This will help us move away from a market-led approach, as seen in BNG requirements, which tends to lead to patchy results [see evidence gathered by Chapman, Tait and Postlethwaite (2024), ‘Lost Nature’].

 

6. What should the Government consider in identifying suitable locations for spatially targeted incentives?

‘Spatially targeting incentives’ in this consultation document refer to those concerned with food production. As mentioned in our response to Question 4, agriculture extends beyond food production and as such this spatially targeted thinking should also cover the wider activities that communities participate in.

 

7. What approach(es) could most effectively support land managers and the agricultural sector to steer land use changes to where they can deliver greater potential benefits and lower trade-offs?

As mentioned in our response to Questions 3 and 5, Local Nature Recovery Strategies can be a powerful tool to steer land use changes conducive to multifunctionality of land and manage trade-offs.

At a broader scale, there should be a mechanism to mediate between the Land Use Framework and other national-scale spatial plans such as the Strategic Spatial Energy Plan. This can come in the form of a National Spatial Framework, as the RTPI has long called for. Such a framework will help coordinate competing land use demands to achieve the country’s nature, housing and energy ambitions.

8. In addition to promoting multifunctional land uses and spatially targeting land use change incentives, what more could be done by Government or others to reduce the risk that we displace more food production and environmental impacts abroad?

No comment.

 

9. What should Government consider in increasing private investment towards appropriate land use changes?

The RTPI supports a strategic approach towards nature recovery and recognises the potential of the Nature Restoration Fund in the coordination of private investments. There are two areas that the government should consider to maximise the potential of private investments:

• Monitoring and enforcement
  Ecological enhancement measures promised by private investors are not always delivered on the ground (Chapman, Tait and Postlethwaite (2024), ‘Lost Nature’). To achieve the intended outcomes, measures need to be in place to ensure progress is monitored and conditions are enforced. To this end, relevant support needs to be given to local authorities, especially on planning enforcement, which has been chronically under-funded (RTPI, 2023, ‘State of the Profession’; RTPI, 2022, ‘Planning Enforcement Resourcing’).
  
  
• Linkage to other plans and strategies
  Local Nature Recovery Strategies can play a key role in coordinating actions, as mentioned in our responses to previous questions. Linkage between the Land Use Framework, LNRS and Spatial Development Strategies will also be key to steering investment towards areas most needed.

 

10. What changes are needed to accelerate 30by30 delivery, including by enabling Protected Landscapes to contribute more?

✓ Strengthened Protected Landscapes legislation (around governance and regulations or duties on key actors) with a greater focus on nature.

The activities on Protected Landscapes are largely managed by private landowners. At the moment, the status of Protected Landscape does little to prevent management practices harmful to nature. To achieve 30 by 30, legislation needs to be strengthened to prevent harmful activities, as well as to require demonstration of management effectiveness. Legislation should also take into account the impact of climate change on existing conservation objectives.

Tools: such as greater alignment of existing Defra schemes with the 30by30 criteria (for 30by30 criteria and next steps see: https://www.gov.uk/government/publications/criteria-for-30by30-on-land-in-england/30by30-on-land-in-england-confirmed-criteria-and-next-steps)

✓Resources: such as funding or guidance for those managing Protected Landscapes for nature

As mentioned in our response to Question 5, the current funding landscape is siloed and complicated. To encourage investment and ensure that the delivery of 30 by 30 is economic, the funding landscape needs to be simplified and come with clear objectives – so different funding streams will not be pitching against each other. 

Other (please specify)

11. What approaches could cost-effectively support nature and food production in urban landscapes and on land managed for recreation?

Community-led initiatives can be a cost-effective approach to not only support nature recovery, but to deliver better health, environmental and economic outcomes for communities.

In southern Scotland for example, the Langholm Initiative acquired 2,100ha of grouse moor and woodland on behalf of local community. The intention is to transform the land into the Tarras Valley Nature Reserve and build a ‘nature-based economy’ that will generate jobs and incomes for the local community.  

In England, the Cambridgeshire and Peterborough Future Parks Partnership offered small grants from £250 to £750 to local communities applicants to undertake nature recovery on local and accessible open space. The projects undertaken include planting and rewilding initiatives, as well as improvement works to local environmental amenities. The project found communities to be resourceful, creative, enthusiastic and motivated, and the experience will inform the biodiversity policy and the town and parish councils.

 

12. How can Government ensure that development and infrastructure spatial plans take advantage of potential co-benefits and manage trade-offs?

As mentioned in our response to Question 6, to achieve co-benefits and manage trade-offs, there needs to be a coordination mechanism at the national scale in the form of a National Spatial Framework. The development of the Land Use Framework, 10-year Infrastructure Strategy and the government’s ambition to update all National Policy Statements offers a good opportunity for joined up thinking and the development of such a mechanism.

There also needs to be a recognition of the knock-on implications of a decision to other areas (e.g. if all sites are taken up by housing, there will be less land available for other essential infrastructure). This will allow us to think of development in a more holistic manner.

At a sub-regional level, Spatial Development Strategies should play a key role in identifying areas of potential co-benefits and trade-offs.

Communities should be involved in these discussions. There needs to be clear communication to communities so they understand the benefits of engaging with these conversations early. They should be given support to participate in decision making in an informed manner. This will help build consensus amid potentially difficult decisions.

 

13. How can local authorities and Government better take account of land use opportunities in transport planning?

Land use opportunities can be maximised through putting the right development in the right place. This will lead to better transport outcomes, minimise the amount of land taken up by roads and deliver better outcomes for communities.

RTPI research ‘Location of Development’ shows that there has been limited improvement in connectivity between major housing developments and local facilities across England from 2012 to 2021. This is despite the NPPF’s stated aim of promoting sustainable development.

The explicit reference to the ‘vision-led approach’ to transport planning in the revised NPPF should help address the problem, alongside the Department for Transport’s work to update the Transport Assessment Guidance.

The reintroduction of strategic planning and broader local government reforms will also help better align transport planning and land use planning at a larger-than-local scale. There should be provisions in emerging Spatial Development Strategies for transport and spatial plans and policies to refer to each other.

14. How can Government support closer coordination across plans and strategies for different sectors and outcomes at the local and regional level?

Coordination at the local and regional level will require strong national steer. The publication of the Land Use Framework and sectoral spatial plans for infrastructure will provide that steer – provided that there is horizontal coordination between these national-scale plans and vertical coordination between different tiers of plans.

Horizontal coordination can be achieved through the development of a National Spatial Framework (RTPI 2024). There should be a requirement for the Land Use Framework and other national-scale plans to form part of the evidence base for Spatial Development Strategies.

On nature and the environment specifically, there are currently a range of different plans and strategies working in silos. There is scope to build on LNRSs to consolidate all these different regimes to take a holistic approach towards nature, the environment and climate change. This would involve LNRSs evolving into Local Environment Improvement Plans in the long run (RTPI 2021, ‘Planning for a better future’).

 

15. Would including additional major landowners and land managers in the Adaptation Reporting Power process (see above) support adaptation knowledge sharing? Please give any reasons or alternative suggestions in the text box below.

No comment.

16. Below is a list of activities the Government could implement to support landowners, land managers, and communities to understand and prepare for the impacts of climate change.

Please select the activities you think should be prioritised and give any reasons for your answer, or specific approaches you would like to see.

✓ Providing better information on local climate impacts to inform local decision making and strategies (for example, translating UK Climate Projections into what these mean in terms of on-the-ground impacts on farming, buildings, communities and nature) (Met Office UK Climate Projections available at https://www.metoffice.gov.uk/research/approach/collaboration/ukcp)

✓ Providing improved tools and guidance for turning climate information into tangible actions (for example, how to produce an adaptation plan for different sectors)

✓ Developing and sharing clearer objectives and resilience standards (for example, a clear picture and standards of good practice for each sector under a 2°C climate scenario: the climate changes we will experience if there is 2°C of global average temperature increase above pre-industrial baselines by 2100)

✓ Other: Promotion of innovative approaches to adaptation

We support all the activities listed above. Particularly on the first point, better communication to the public about the impact of climate change and how it can be managed through land use will be essential. This should go beyond broad narratives but contain concrete examples of how people’s daily lives and costs of living may be affected.

We would like to add the promotion of innovative approaches to adaption as another priority. While it is important to direct or incentivise developments to locate in resilient places, the ability to adapt to climate change, particularly for existing developments, is also key. This will require innovative practices and these approaches should be encouraged.

 

17. What changes to how Government’s spatial data is presented or shared could increase its value in decision making and make it more accessible?

✓ Updating existing Government tools, apps, portals or websites

We are aware of work being undertaken by the MHCLG on this. This needs to be a cross-government effort to bring the work being undertaken by different departments together.

Changes to support use through private sector tools, apps or websites

✓ Bringing data from different sectors together into common portals or maps

Data needs to be consolidated into common portals and maps, which users can access via a single point of entry. This can be done by a research institution.

✓ Increasing consistency across spatial and land datasets

✓ More explanation or support for using existing tools, apps or websites

Greater use of geospatial indicators such as Unique Property Reference Numbers (UPRNs) and INSPIRE IDs to allow data to be more easily displayed on a map

Other (please specify)

18. What improvements could be made to how spatial data is captured, managed, or used to support land use decisions in the following sectors?

✓ Development and planning: such as environmental survey data

It is currently difficult to draw out data from individual planning applications for purposes of data sharing and for developing an understanding of the bigger picture. Local authorities are collecting environmental data in silos. Going forward, consolidation of all these different sources of data into a single authority will aid land use decision making.

For larger scale projects (such as NSIPs), data collection is often expensive for applicants and there will be implications to intellectual property rights. This is a significant challenge to data sharing. The right incentives need to be in place for applicants to participate in data sharing.

A plausible way of tackling this challenge is stronger state involvement in data collection, where applicants will be able to buy data from the government.

Farming: such as supply chain data and carbon or nature baseline measurements

Environment and forestry: such as local and volunteer-collected environmental records

Recreation and access: such as accessible land and route data

Government-published land and agricultural statistics

19. What improvements are needed to the quality, availability and accessibility of ALC (Agricultural Land Classification) data to support effective land use decisions?

ALC data has not been kept up to date and this has posed great challenges to renewable infrastructure development, particularly solar. For the data to be of meaningful use, it needs to be updated.

The subdivision of Grade 3 land into 3a and 3b causes confusion as 3a land is considered ‘Best and Most Versatile’ while 3b is not. This has caused issues in decision making in relation to land use planning.

20. Which sources of spatial data should Government consider making free or easier to access, including via open licensing, to increase their potential benefit?

See our response to Question 21.

 

21. What gaps in land management capacity or skills do you anticipate as part of the land use transition?

✓ Development and planning

There is a significant ecological and biodiversity skill gap among public sector planners, with the RTPI finding 81% of public sector planners needing more guidance on BNG and 72% of local planning departments reporting to MHCLG a skill gap in the area.

Almost half of England’s local authorities reported a skill gap in landscape architecture and digital planning.

These gaps in specialist knowledge is coupled with a general lack of resources in local planning departments, with a quarter of planners having left the public sector between 2013 and 2020 (RTPI 2023, ‘State of the Profession’).

Better central government funding is needed to improve resourcing in local planning departments and recruitment. Government should also provide funding for the development of training and guidance on specialist knowledge.

Farming

Environment and forestry

Recreation and access

Other (please specify)

 

22. How could the sharing of best practice in innovative land use practices and management be improved?

There are currently not enough provisions for the sharing of best practices among local authorities. The reintroduction of strategic planning presents a good opportunity to improve that. For example, instead of having an ecologist or a planner with ecological knowledge in each local authority, these specialists can sit within a strategic authority and their skills shared across all constituent authorities.

 

23. Should a Land Use Framework for England be updated periodically, and if so, how frequently should this occur?

Yes, every 5 years

Yes, every 3 years

✓ Yes, another frequency or approach. Please provide details.

Ideally the Land Use Framework should be a live document. Data should be updated continuously. This will allow the preparation of Spatial Development Strategies and other planning documents to rely on up-to-date data, avoiding the situation of, for example, ALC data not having been updated for decades

No

Don't no

 

24. To what extent do you agree or disagree with the proposed areas above?

Strongly agree
Agree
Neither agree not disagree
Strongly disagree
Don't know