Home » Planning process

Tag: Planning process

Image: roundabout in new development

The Planning White Paper – how to respond

The government is consulting on proposals to reform the planning system in England. Unfortunately, Transport for New Homes is concerned that the reforms are likely to encourage more car-based sprawl.

Read the ‘Planning for the Future’ White Paper

If you share our concerns about the transport implications of the White Paper, please respond to the consultation. Here are two ways to respond:

  1. You can respond in detail via the government’s online questionnaire. Below you’ll find Transport for New Homes’ suggestions for things to include in your response.
  2. If you’re short of time, you can respond quickly and easily using our short form instead.

Things to include in your response

If you would like to respond via the government’s online questionnaire, here are some suggestions. Our concerns about the White Paper fall into 10 categories. You’ll see that we’ve included reference to the questionnaire questions which we think are particularly relevant to these concerns.

Concern 1: Transport is left out of the planning white paper – hardly a mention (Question 5)

Planning and transport fail to come together in the white paper, with transport hardly mentioned. It is fundamental that you need to consider development and transport together. It’s common sense.

Location, location, location. Building in the wrong location will lead to more traffic, car-based living, more isolation and less walking or cycling. We shouldn’t be forcing people to live car-based lifestyles in the future.

The white paper needs to address how we will provide and fund public transport to the new places we plan, and to build where people can walk and cycle in and out of new housing areas.

Concern 2: Division of all England into three categories: ‘growth’, ‘renewal’ and ‘protected’: too simplistic (Proposal 1, Question 9a, Question 9b)

The ‘zoning’ idea in the white paper, whereby England is divided into just three categories fails to capture the physical, social and environmental aspects of the country and is wrong.

The white paper is clear: ‘All areas of land would be put into one of these three categories’ . Much countryside without a national designation will likely be in the ‘growth area’ even if valuable in other ways. Use of maps and data should reflect a proper evidence base for more intelligent planning, with land uses and transport detailed so that people can see where best to develop.

The division of England into just three categories for the purpose of planning is not useful to planning properly.

Concern 3: More development in the countryside – more car-based sprawl (Proposal 1)

The classification of most of the countryside in many local authority areas as ‘growth areas’ is concerning in terms of future car-based sprawl around major road construction.

A combination of high housing targets for rural and semi-rural areas, away from jobs and services is likely to lead to even more urban sprawl, traffic, severance, pollution and sedentary and isolated lifestyles. This is not a model for a low carbon future.

Concern 4: Fewer local planning policies for your area – central government to take more command (Proposal 2, Question 6)

Local policies on housing, employment, biodiversity, landscape, flooding, transport etc. are proposed to be much reduced in local plans. The National Planning Policy Framework (NPPF) then becomes the primary source of policies for your area.

Although local plans are often too verbose and complicated, and take a long time to agree, planning reform should not mean less local input and local data shaping an area. The white paper hinges on a new centrally produced planning policy in the form of the NPPF. But we do not know what the new policy will be.

It is hard to judge what is really on the table and whether sustainable transport will really feature with firm language to make its importance plain. Consulting on a white paper with an important component in the form of the NPPF missing, makes it hard to make an informed response.

Concern 5: Local sustainability tests scrapped in favour of single central government test (Proposal 3, Question 7a)

The sustainability appraisal currently used in local plan development looks at housing, transport, biodiversity, carbon, flooding, water and much more. This is proposed to go, replaced again by a single ‘sustainability test’ devised by central government.

The risk is that many local aspects of planning will receive less thought, and that the definition of what is ‘sustainable’ will be centrally specified in ways that might pick up sustainability issues in a local area. It is unclear at this stage what would be deemed as ‘unsustainable development’ yet this is key to responding to the white paper.

The white paper without detail on the sustainability test is not a coherent document. We need to see what this sustainability test will contain because it’s absolutely critical and will be used to judge local plans.

Concern 6: A local authority is not an island. But cross-boundary planning is missed out (Proposal 3, Question 7b)

Less coordination in planning across a wide area is a mistake. The duty to cooperate with adjacent authorities on planning is removed and it remains unclear how adjacent local authorities should plan together to build targets for new homes and plan a wider area intelligently.

The white paper concentrates on local authority areas and misses out the benefits of wider ‘strategic’ planning, which is essential. Only with a wider view can developments be coordinated along public transport routes.

Planning across a wide area can test out different scenarios to see where best to build, considering transport, job density, service provision, ecology, favourite countryside etc. It can’t be left out – that’s bad geography and will result in uncoordinated sprawl.

Concern 7: Housing targets without geography, let alone transport. (Proposal 4, Question 8a)

High housing targets are proposed for rural and semi-rural areas which are already being covered with car-based sprawl will lead to the wrong pattern of development. Targets neglect to take into account the locations of jobs, services and amenities, or the right places to build for sustainable transport. We need to build close to major areas to enable people to travel where they want to without long journeys by car.

As further high housing targets are given to rural and semi-rural areas it looks like a recipe for even more car-based sprawl. We need a more measured consideration of how much to build where, putting proximity to jobs, increasingly centralised services and community provision rather than building ‘out in the sticks’.

Concern 8: Missing out the outline planning stage means a lack of scrutiny at a critical stage in the local planning process. (Proposal 5, Question 9a)

The white paper indicates that development in a ‘growth area’ will be fast-tracked and that developments will get automatic outline planning permission. At an outline planning everything from transport and access, to community provision, ecology, flooding and supply of utilities are considered.

Missing this stage out will result in mistakes being made and will fail to locate the transport and other needs of a large site. Especially if the local plan was produced some while ago, the development needs review closer to its actual build date.

Concern 9: Digital mapping needs to be more than a presentational tool (Proposal 7, Question 11)

The white paper talks about the use of digital mapping to show people what is planned for their area. This is an exciting idea, but it depends how and for whom the system is set up.

Digital mapping as a planning tool for everyone’s use is a great idea but what will the maps show and how will they be used? Will they work cross-boundary, enabling zooming in and out to see both development and transport infrastructure and services in the next local authority area?

How will maps be used to decide where best to build? What data sets will be shown in the different layers and will all be available to the public to look at? It is important to think now about the role of digital maps much more clearly.

Concern 10: Less money for pleasant, walkable and vibrant places to live (Proposal 19, Question 22a)

The new infrastructure levy to replace developer contributions risks being split too many ways. It is needed for affordable housing but then there will be less in those places for community provision and other infrastructure.

It is unclear how we can build pleasant places to live which are also affordable without adequate funds. There is a risk that pavements, urban trees, cycleways, gardens and community provision will not materialise for many new areas. The funding and provision of public transport remains unknown. The idea of ‘beauty’ of place as described many times in the white paper comes with a price tag – will it be for the few or the many?

How will beautiful places be made if each home has parking for two or three cars with the usual roundabouts, access onto a bypass and so on? What is to say that we will not just build more ugly tarmac estates as opposed to mixed walkable neighbourhoods that form a real community?

Thank you for taking the time to read our suggestions and respond to the ‘Planning for the Future’ White Paper.

Riverside development

Planning reform is on the way

Planning reform is on the way. But will it lead to better development in the right places, and stop car-based sprawl?

From the point of view of Transport for New Homes, and the many others who are appalled at the spread of car-dependent new housing dominated by roads and parking, planning reform should be about enabling positive planning. It should be aimed at bringing about new development in locations where it will be well served by, and will encourage the use of, sustainable transport – walking, cycling and public transport – and where people will not feel dependent on using cars to meet their everyday needs.

So far, however, the reform the Government has in mind is focused on getting more homes built, and involves the slackening of planning controls to make this happen. This might well boost the housing numbers, but will it address the problem of poor quality?

Transport for New Homes agrees that more housing is needed, much more. The shortage of homes, and especially affordable homes, is clear. But boosting the numbers is not enough by itself. We are pressing for quality as well as quantity, namely:

  • Building in the right places, with good public transport connections
  • Creating mixed communities with a good range of local facilities
  • Ensuring that people are not dependent on the car
  • Designing places that are attractive for all stages of people’s lives, not soulless estates dominated by roads and parking

Delivering this kind of diverse and high-quality growth does not have to involve more planning, but it does need the right kind of planning. The most important requirement is for development to be in the right place. That means having a plan which coordinates development with sustainable transport options, and prioritises sites within existing urban areas over greenfield sites. The drive for sustainability requires compact development, not suburban sprawl or remote estates. It also requires the building of communities, not just houses.

Making it easier for developers to convert offices and other buildings to residential use could have a positive impact, re-purposing space made redundant by increased home working since COVID-19. Such conversions are also likely to be in locations well served by public transport. But controls are needed to ensure that we don’t end up with sub-standard, cramped flats without adequate daylight or outdoor space or facilities. If anything, new homes will need to be bigger, to provide for greater homeworking.

At the moment, the planning system is largely reactive to private sector initiatives and lacks ways of coordinating development with sustainable transport measures. At a minimum, reform of the planning system needs to address this problem. Under the current system transport considerations are mostly confined to building road capacity to deal with extra traffic from new developments. This is completely at odds with avoiding car dependent housing, and decarbonising transport to meet climate change targets.

A way must be found to plan sustainable transport measures alongside new developments, on the same timescale, and with coordinated and fully committed funding. It is not rocket science, nor does it need to involve more bureaucracy and red tape. It does mean creating more certainty in what gets built where, and when. The benefits of this approach can be seen in other countries. Transport for New Homes have visited, for example, Copenhagen (Denmark), Freiburg (Germany), Montpelier and Nantes (France), and Almere and Ijberg (Netherlands). In these places new developments follow an integrated transport and land use plan, based on high quality public transport such as tram or urban railway. Even in some car-dependent north American cities we can see a move towards this approach.

Local authorities should certainly facilitate housing growth, but they should also be required to determine what gets built where. Instead of waiting for landowners and developers to bring forward development sites that suit their interests, local authorities should be given powers to assemble sites in accordance with their plans. Local Plans should be prepared and scrutinised alongside Local Transport Plans, and funding should be arranged to fit the timetable for transport and development schemes. The plans themselves should be based on the principles of “brownfield first”, and transit-oriented development (TOD). This means developing in locations that are or will be made accessible by public transport. In areas of high growth especially, there should be statutory plans covering wider areas, with a duty on local authorities to agree both the spatial distribution of future development and the transport facilities that will serve it.

We are therefore calling for reform of the planning system that will rectify deficiencies in the current system. In particular:

  • End the reliance on centrally-determined housing targets that pay no regard to transport or other impacts;
  • Decide development locations based on actual or planned accessibility, rather than wherever land owners are willing to sell at huge profit, and private developers see a market;
  • Integrate planning processes that currently are carried out in separate silos, in particular the planning of sustainable transport and land use;
  • Fund active travel and public transport facilities in advance of development taking place, not just roads.

This programme of planning reform is urgently needed to bring development practice into line with environmental and community objectives. It does mean wider powers for local authorities, but it shouldn’t mean adding layers of bureaucracy. Instead the focus of planning effort should shift from the scrutiny of private sector proposals towards pro-active involvement in the location and shaping of new development.

Meanwhile, plans for hundreds of new car-dependent housing estates (including those dressed up as “garden villages”) remain on the table, and are in need of urgent review.

By Tim Pharoah, Transport and Urban Planning Consultant

Roof trusses

Planning and COVID-19

Back in the early days of the COVID-19 pandemic we noticed that planning and development were continuing. We asked you to get in touch about what was happening in your local area, to tell us how decisions were being made about new housing. We worried that changes to oversight of planning might mean that proper transport provision for new homes might be neglected.

Thank you to the many of you who got in touch. We had replies from all over the country. You told us that councils approached the problem of planning in different ways. Some moved to online planning committee meetings right away and others delayed decisions. It was difficult to keep up with the volume of applications for some authorities, so more decisions were delegated to officers.

Online planning committees were sometimes reserved for the biggest applications. As we were busy finalising our Garden Communities report we were interested to know if any of them were going through planning and affected by COVID-19. Many Garden Towns and Garden Villages are progressing through the planning system.

Just before our report launched a planning inspector approved some and threw out other new Garden Communities as part of a local plan in Essex. On the day our report launched, Buckinghamshire Council met to approve the garden town plan in Aylesbury.

One thing many of you told us that is concerning was the reduction or complete elimination of the opportunity to speak at planning committee because of COVID-19 and remote working. The reasons for this varied from the limited amount of time available, technical limitations or because a decision had been delegated to officers.

Overall, we found a mixed bag of council planning responses to COVID-19. But what linked them all was a reduction of the ability for residents to make their voices heard. It is harder now to make the case against car-based sprawl and for sustainable transport. We think councils should return to their previous ways of working as soon as is practical and restore public involvement as soon as they can.

Building site

Let us know how changes to the planning system are affecting your area

Planning and the making of planning decisions have not stopped because of the COVID-19 (Coronavirus) crisis. The Coronavirus Act 2020 gave councils the ability to run planning committees remotely. However, even before this legislation became law many authorities were making new arrangements for planning decisions, including delegating decisions to officers and council leaders rather than scheduling committee meetings in a council chamber where the public could submit questions and statements and also speak.

Councils are acting under pressure from central government to keep planning consents and development going. You might have seen in the news or noticed in your own community that site work continues. This is because planning and development are not on hold.

We know that good planning decisions with committee scrutiny and public involvement are crucial for getting new homes with good sustainable transport. We are concerned that changes to the system might have an impact on the quality of what gets built.

Can we ask you to spend a few minutes answering some questions about how your local council is adapting their planning decision making process? If you let us know about any big developments that are due to be decided soon that would really help too.

Once we’ve got a picture of what is going on we hope to produce some advice on challenging large developments that come through planning at this time, with a view to ensuring sustainable transport isn’t forgotten when new homes are built.

It would be great to get your input by 18 May.

Sorry, this form has now closed.