BaSRAG Response to the Government’s “Planning for the Future” White Paper

The consultation on the ‘Planning for the Future’ White Paper ends on Thursday 29 October.

Shown below is our response to the consultation. Please feel free to ‘borrow’ parts of our response if you agree with our position and wish to add your voice to the views expressed by the public.

We believe the proposals in the White Paper are fundamentally flawed for the following reasons:

– It is assumed that delays in housebuilding are due to faults in the planning system. It is the responsibility of planners to make housing land available, but it is the housebuilding industry that is responsible for building the houses. There are planning permissions for over one million houses which have not been built. These proposals do nothing to address that developers will wait until the most advantageous time for them to build.

– The new laws will make the provision of much needed low cost and affordable housing even more limited.

– The public will have much less opportunity to meaningfully scrutinise future plans. It provides a broad brush approach to planning, effectively reducing the opportunity for local communities to shape their own area. You refer to the TCPA, RTPI and the GBC as providing evidence, yet all these bodies are critical of significant elements of the White Paper, specifically that it is not likely to achieve its specific aims.

– In addition to those mentioned above, diverse and key bodies such as RIBA, CPRE, Friends of the Earth and the Local Government Association have significant and legitimate concerns about these proposals and the views of these experts must be taken into account.

– The proposals largely ignore the importance of countryside in addressing the climate emergency, biodiversity, wildlife and other government commitments, for example to increase tree coverage.

– The proposals for the change to the new Standard Method should have been included within this White Paper and not the subject of a separate and shorter consultation.

– The new Standard Method would lead to a greater volume of housebuilding in the South, perpetuating the North-South divide.

– Additionally, In our area (Stroud District), the fact that the AONB would be (correctly) protected, would put impossible pressure on the rest of the District if the new algorithm is instituted.

– The current proposals will pressure local authorities to meet a significantly enhanced housing requirement forced on them by the Standard Method algorithm without taking into account what we need and what makes our area special. The assessment of housing need and capacity should consider local landscapes, environmental designations, conservation, flood plains, the LNP tree strategy, demographic factors and varying components of household projections which can impact the algorithm affordability calculations, infrastructure and services.

– It is highly likely that to meet the proposed algorithm’s housing requirement, properties would need to be built on flood plains. This is unacceptable, unnecessary and immoral.

– The intention of the new affordability adjustment is to identify undersupply where high house prices signify an imbalance between supply and demand. It is also to put more pressure on authorities which have seen worsening affordability over a 10 year timeframe. There is no evidence to suggest the proposals will have the desired impact on property affordability or the supply of homes for those in a housing crisis.

– Whilst there is probably an overcomplicated series of assessments currently required, we have significant concerns about replacing the existing tests of soundness with a Sustainable Development test, and abolishing the Duty to Cooperate.

– We agree that only those who are truly committed engage with the consultation process, but these proposals will not make it easier to do so. In some ways, opportunities will become much more limited.

– It is a stated aim that the proposals will favour the small builder and SMEs, but our reading suggests the opposite, and will be beneficial for the big players.

– The overall thrust of the proposals places any meaningful opportunity that the public has to influence planning decisions at the Local Plan stage and not when a specific development is being considered. Yet the public will only have 6 weeks in which to consider a draft Local Plan, at the same time as which it has been submitted to the Secretary of State for Examination.

– We agree that the current system for developer contributions to affordable housing and infrastructure is not adequate, but no evidence as to how these proposals will improve this situation.

In conclusion, we find that the proposals lack specificity, and details are replaced by assertion and rhetoric. However, the laudable aims stated in the PM’s introduction – encouraging sustainable and beautiful development, making it harder for developers to dodge their obligations, and giving the public a greater say over what gets built in their community – are not met by these proposals.

Our local Conservative MP, Siobhan Baillie, has written to the Minister with her concerns. 

The current planning system is far from perfect, but this affront to local democracy is not the answer. No attempt is made in these proposals to force developers to proceed with building once permission has been granted, which is probably the single most significant cause of housebuilding targets not being met.