Question 3. Our proposals will make it much easier to access plans and contribute your views to planning decisions. How would you like to find out about plans and planning proposals in the future? [Social media / Online news / Newspaper / By post / Other – please specify]
Our current planning system is not engaging to a diverse audience. It aims to be participatory but often reaches only those who have the time to engage, often overrepresented by certain groups (old white men) and underrepresented by other groups.
We object to the notion of ‘streamlining’ as it seems to be a move away from in person representation in the planning process. When what we need is greater representation and greater reach.
Localism aims to engage people more in their local environments, and this is not reflected in the White Paper. Participation should not be limited to Local Plan stage only but fully embedded in all stages of the planning process to enable local people to fully engage with the climate and biodiversity emergencies and to seek collaborative solutions to these issues.
The aim of expanding communication channels is welcome but a wholesale change to the system of participation in planning is required.
Question 4. What are your top three priorities for planning in your local area? [Building homes for young people / building homes for the homeless / Protection of green spaces / The environment, biodiversity and action on climate change / Increasing the affordability of housing / The design of new homes and places / Supporting the high street / Supporting the local economy / More or better local infrastructure / Protection of existing heritage buildings or areas / Other – please specify]
The UK Government has committed to a reduction in CO2 emissions to net zero by 2050. The planning system must prioritise this aim. This priority is an opportunity to remodel our democratic and economic systems to work for the benefit of planet, biodiversity and people. The White Paper does not go far enough in helping to achieve these aims and indeed in some cases may be damaging to this priority. The three top priorities should be aligned with the Government's climate commitments
Priority 1: Prioritise a green recovery to create green construction industry jobs, retrofitting and improving the existing stock
Priority 2: Do no harm. Embed carbon analysis in all planning decisions and incentivise zero carbon development with planning gain.
Priority 3: Increase biodiversity. Incentivise development that increases biodiversity.
Question 5. Do you agree that Local Plans should be simplified in line with our proposals? [Yes / No / Not sure. Please provide supporting statement.]
Local Plans involve extensive research, consultation and thought and describe the ambitions of the locality. The role of the Local Plan is not to ‘identify land for development’ and should not be limited to setting out ‘site- or area- specific parameters and opportunities’.
Development does not simply occur ‘on Land’ but is often part of a complex existing (urban) environment, within and around existing buildings and within an existing environmental context, community, heritage etc. Planning policy (both design guides and Local Plans) must include legally binding minimum standards for environmental performance, both whole life carbon and ecological improvement (as opposed to current impact assessments).
The retention of existing buildings and structures has the potential to be hugely beneficial to reducing embodied carbon in the built environment (an average of 45% of a building’s emissions are caused during construction) and prioritising the retrofitting of existing buildings within planning policy is a straightforward means to helping to reach the government's environmental commitments.
The White Paper is not clear on how the proposed changes (to Local Plans) will deal with the impact of development on the climate.
Question 6. Do you agree with our proposals for streamlining the development management content of Local Plans, and setting out general development management policies nationally? [Yes / No / Not sure. Please provide supporting statement.]
Policies should be determined at a local level, reflecting local need and local aspirations. Local Authorities should be able to be more ambitious within local policy than baseline national targets. Many councils have declared a climate emergency and set a target date of 2030 to achieve Net Zero Carbon for example well beyond the ambition of the national government.
Question 7(a). Do you agree with our proposals to replace existing legal and policy tests for Local Plans with a consolidated test of “sustainable development”, which would include consideration of environmental impact? [Yes / No / Not sure. Please provide supporting statement.]
The main objectives of the Planning White Paper should be Net Zero Carbon and net biodiversity gains. There are not enough details regarding the sustainability test, so it is very difficult to respond to this question and indeed the consultation in general which feels more like a brainstorming exercise than a serious and considered policy document prepared by Her Majesty's Government.
Any sustainability test must conform to a rigid methodology such as RICS Whole Life Carbon Assessment and include biodiversity improvement targets as standard. The standards must be in support of achieving Net Zero and the WHite Paper should set out a clear timeline for how this will be achieved.
Question 8(a). Do you agree that a standard method for establishing housing requirements (that takes into account constraints) should be introduced? [Yes / No / Not sure. Please provide supporting statement.]
The lack of affordable housing in the UK is not simply a result of high land values but is affected by long term government policy and issues such as viability assessments which all too often are used to reduce a developer’s affordable housing contribution, land availability also plays a factor, as do other complex issues.
The suggestion of the standard method in the White Paper is an oversimplification of a complex issue and would result in more development but not necessarily the right development. Apart from the green belt the proposals do not limit the development of greenfield sites so the proposal would result in more greenfield sites being developed.
Question 8(b). Do you agree that affordability and the extent of existing urban areas are appropriate indicators of the quantity of development to be accommodated? [Yes / No / Not sure. Please provide supporting statement.]
This is a simplification of the issue. The underlying issue is a disparity in wealth between different areas of the country creating concentrated areas of demand in housing. We should prioritise the retrofitting of existing housing stock to high environmental standards to create sustainable affordable homes and to provide jobs.
Question 9(a). Do you agree that there should be automatic outline permission for areas for substantial development (Growth areas) with faster routes for detailed consent? [Yes / No / Not sure. Please provide supporting statement.]
Automatic permission will risk development being built which does not meet adequate environmental or quality standards which are currently dealt with through a thorough and detailed planning process.
Question 9(b). Do you agree with our proposals above for the consent arrangements for Renewal and Protected areas? [Yes / No / Not sure. Please provide supporting statement.]
In a climate emergency new development should be encouraged only if appropriate stringent regulations are in place to ensure its environmental standards are high and in line with the carbon reduction targets we need to meet within the next ten years.
Question 10. Do you agree with our proposals to make decision-making faster and more certain? 33 [Yes / No / Not sure. Please provide supporting statement.]
Granting automatic permission based on 'meeting targets' will prioritise developer profit over community benefit and will undermine trust in the planning system.
Question 12. Do you agree with our proposals for a 30 month statutory timescale for the production of Local Plans? [Yes / No / Not sure. Please provide supporting statement.]
Preparing Local Plans is often a complex process which may well require more than 30 months. An arbitrary cut off point could lead to poor quality or rushed plans which do not adequately serve their communities.
Q15. What do you think about new development that has happened recently in your area? [Not sure / indifferent, Beautiful / well-designed, Ugly / poorly-designed, There hasn’t been any, Other]
Much new developer led development is poorly designed and of poor quality as the developer chases their profit margins due to exceedingly high land values. Until the issues surrounding high land value which is linked to the planning system are fixed we will not be able to achieve the highest quality of new development.
Question 16. Sustainability is at the heart of our proposals. What is your priority for sustainability in your area? [Less reliance on cars / More green and open spaces / Energy efficiency of new buildings / More trees / Other – please specify]
The top priority must be to address the current climate and biodiversity emergencies, and reduce CO2e emissions to net zero. The White Paper uses the term ‘sustainability’ but does not give any clear definition of what this is so it is difficult to understand. None of the listed answers to this question alone will address the climate and biodiversity emergencies. A holistic approach to sustainability is required with clear regulation and targets needed. The RIBA and LETI have conducted extensive research to demonstrate how the industry can meet the challenges of achieving net zero and this should be reflected in the policy. The Building Better Building Beautiful report has many good recommendations which are also not reflected in this White Paper.
Question 19. Do you agree with our proposal to consider how design might be given greater emphasis in the strategic objectives for Homes England? [Yes / No / Not sure. Please provide supporting statement.]
As an architectural practice this goes without saying - without good design we will not be able to meet the challenges of building beautiful sustainable buildings which address the climate and biodiversity emergencies. Good design must first be sustainable, and the planning reforms should set clear targets for achieving this.