Chapter 4
34) Do you agree with the proposed approach to setting a spatial strategy in development plans? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI believes that drafting in S1(1)(a) should be amended to set out what is considered ‘other uses’. Whilst housing is, and will always be, central to the work of planners and the planning system, housing alone does not lead to successful placemaking without a detailed and strategic approach to all other land uses. This reflects our position as set out in response to Q6(a), that the new plan-led system needs to draw fuller association with the range of topics set out in NDMPs.
35) Do you agree with the proposed definition of settlements in the glossary? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
a) Please provide your reasons, particularly if you disagree.
The increased emphasis on settlement boundaries in the proposed Framework will likely draw much debate, legal challenge, and significant resources on a site-by-site basis. It will subsequently likely be a focus of emerging local plans. Fundamentally, if settlements are defined as those with settlement boundaries and we achieve full plan coverage across the country, the RTPI would consider such definition as sufficient and local plans the best mechanism to then define hierarchies.
However, in lieu of full plan coverage and considering the often lack of five-year housing land supply, the RTPI would recommend the strengthening of proposed definitions of settlements in the glossary. This would include a steer on settlement hierarchy, with a clear and unequivocal definition of the difference between villages, towns, and cities. This would better support the application of other policies in determining what quantum of development such settlements can sustainably accommodate. The glossary would further benefit from a clear definition of what constitutes a built-up area.
36) Do you agree with the revised approach to the presumption in favour of sustainable development? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI welcomes the general travel of direction of Chapter 4 which provides more certainty and clarity to decision makers, applicants and communities as to what kind of development is considered appropriate in different locations. However as set out in response to Q35(a), once the locational principle is established, without a clear hierarchy of settlements or adopted local plan providing such, it is difficult to understand the quantum of development which is considered appropriate and proportionate. We also note issues in relation to slight inconsistencies when reading across S2 and S3. For example, S1(1)(a)(i) does not pull through into decision-making policy S3.
37) Do you agree to the proposed approach to development within settlements? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
For clarity, the RTPI would welcome more detail as to what the benefits are considered to be of development proposals coming forward within settlement boundaries in S4.
38) Do you agree to the proposed approach to development outside settlements? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
As set out in response to Q36(a), the RTPI broadly supports the Frameworks provision of clear locational direction as to the general suitability in principle of development proposals. Given proposals are such a significant shift in approach from the previous Framework, it is crucial that this policy provides as much clarity and consistency to decision-making as possible, with the aim of reducing legal challenge. This includes ensuring clear and consistent read across between the constituent parts of the policy, with clarifications in terms of the approach to resolving tensions in the event they arise.
There are also a number of opportunities to provide more detail on matters, whilst recognising the reasonable limits to details that the Framework can cover. For example, S5(1)(h) could benefit from a fuller description of when development proposals are considered to be physically well related and what is considered a reasonable walking distance. This is especially relevant given the detail afforded to the connectivity part of the policy dealt with in footnote 26. Please see our response to Q40(a) for a more detailed consideration of proposed approaches to development around train stations. Whilst we recognise the significant need to re-purpose brownfield sites, and even those sites outside of settlement boundaries, such proposals still need to be balanced against sustainability considerations. Therefore S5(1)(d) may benefit from reference to locational considerations depending on the nature of the development type proposed. In regard to S5(1)(j), the RTPI welcomes provisions for development to be well-located in the event that development comes forward due to evidenced unmet need. However, we are concerned that what is or is not considered unmet need across different development types could lead to considerable debate and challenges. We would therefore welcome publication of additional guidance to support such situations. This would improve the consistency of application of the policy across the country, supporting the Framework’s intention of creating a more consistent approach to consenting more generally.
We note the language used around unacceptable impact is only contained within policy S4 but would welcome a similar approach to drafting S5 to provide a more consistent and coherent approach to the principles of development both within and outside of settlements.
39) Do you have any views on the specific categories of development which the policy would allow to take place outside settlements, and the associated criteria? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons.
No further comment.
40) Do you agree with the proposed approach to developments around stations, including that it applies only to housing and mixed-use development capable of meeting the density requirements in chapter 12? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, including any evidence that this policy would lead to adverse impacts on Gypsies and Travellers and other groups with protected characteristics
The RTPI welcomes the Government’s objectives of better ensuring that development is targeted towards areas well served by sustainable forms of transport. This responds directly to the institute’s Location of Development research, which found that over the past decade, there has been very limited improvement in accessibility from large-scale developments to key sustainable transport nodes in England. Ultimately, the RTPI would promote the targeting of such development through a plan-led system, to ensure that all the services and provisions needed to achieve high quality placemaking are in place. We recognise that many local plans across the country already aim to direct development in such a manner. The lack of consistent outcomes in this area as identified in our research may predominantly result from the lack of up-to-date adopted local plans across the country.
The RTPI greatly supports the Government’s ambitions to move towards a plan-led system but acknowledges that such an outcome may not be achieved quickly. This will therefore necessitate interim provisions to ensure development comes forward that maintains and reinforces sustainable settlement patterns, in lieu of a local plan. We do however note the lack of policy steer for plan making relating to train stations and would encourage one to come forward to better align the separate elements of the proposed Framework.
Acknowledging the clarifications relating to connectedness and walkability discussed in Q38(a) there are a number of other considerations deriving from this key policy proposal. There has been considerable discussion over what factors go into deciding whether a railway station is considered to provide a high level of connectivity to jobs and services and the resulting implications for different geographies across the country. The RTPI notes significant variation in the geographic areas in which such policy will be engaged as a result of the test set out above. This means that some areas could miss out on significant investment and growth opportunities, and we would therefore ask Government to carefully consider whether there will be unintended consequences in terms of amplifying existing regional inequalities. The decision made to draw productivity assumptions using the Gross Value Added of travel to work areas (TTWAs) raises some concerns. Namely over the age of the data, which is over 15 years old, collected from the 2011 census. Given the significant regional impact of this data, the age of the data may not capture areas which have achieved recent increases in economic productivity, or on the other hand areas that have seen decline in this regard.
The approach taken could be overly simplified in terms of achieving successful outcomes. For example, whilst frequency of service is a sensible consideration, there may also need to be some consideration of capacity, with many services in metropolitan areas of the country already struggling to accommodate existing passenger numbers. The RTPI wonders whether elements of the Connectivity Tool could be applied to such criteria. Regardless of the considerations set out above, ultimately the Government needs to settle on an approach and monitor and evaluate it over time. A range of factors could be altered going forward and will depend on the desired outcome, such as train frequency, walking distance to the train station from the development or which TTWAs are considered.
The proposal also signals an enhanced role of train service provision in setting out the suitability of development, vastly increasing the role of network rail and rail operators in the development process. This would include, for example, supporting the need to demonstrate that train stations have a reasonable prospect of being served due to planned upgrades or through agreement with developers. On top of this, if communities are planned at certain points elsewhere on the same rail line triggering a service frequency increase, there may be a cascade of development opportunity. It is also unclear how reduction in service frequency would be captured in the development process, which can occur fairly frequently, resulting from a variety of external factors for example, in recent times resulting from changing work patterns as a result of the COVID-19 pandemic. In the future such matters will to be need factored into the evidence bases of the development plans in preparation and to address this we expect consideration as to the availability of skilled and resourced planning teams in Network Rail to contribute to both consenting and plan preparation. There may also be a role for the recently established Platform4 in aligning housing delivery ambitions along rail corridors, and a need to address existing issues being experienced developing around railways including dealing with the implications of Network Rail’s shared value policy.
There is also a need to ensure that proposals for housing and mixed-use development do not come at the cost of other land uses, especially those relating to minerals, freight, and logistics with a clear and historic association with such locations.
41) Do you agree that neighbourhood plans should contain allocations to meet their identified housing requirement in order to qualify for this policy? Strongly agree, partly agree, neither agree or disagree, partly disagree, strongly disagree.
Partly agree.
a) If not, please provide your reasons
The RTPI notes the significant weight S6 attributes to adopted neighbourhood plans in regard to decision-making, which contain allocations to meet their identified housing requirement. The RTPI wishes to see clarification over how neighbourhood plans will be dealt with through the transition arrangements set out in Annex A. We would welcome confirmation that the same weight to be applied to local plans which contain allocations identified to meet their housing requirement.
Moving forward, the RTPI notes potential difficulties in terms of managing the preparation of local plans without the ability of authorities to observe and encourage general conformity with local plan policies as part of project management. We would welcome more detail and updated guidance on how neighbourhood plans should be progressed in the new proposed planning system.
We would again reassert concern that due to recent decisions to remove funding for neighbourhood planning, such provisions will predominantly benefit affluent communities, with the skills, knowledge, and resource to be able to undertake such work.
