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Photo: cyclists seen from above

‘Beauty’ alone won’t solve the climate crisis

This guest blog by Cycling UK’s policy director Roger Geffen argues that the Government’s draft National Planning Policy Framework makes it commendably easy for councils to reject planning applications which aren’t ‘beautiful’, but creates massive hurdles for councils wishing to reject developments that would entrench car-dependence. The blog was first published on the Cycling UK website.

“The Government is strongly in favour of ‘beauty’. And who wouldn’t be? I certainly am. It’s one of those motherhood-and-apple-pie things that surely everyone agrees with.

In recent years though, ‘beauty’ has become something of a ministerial obsession. Some ministers seem to think you can build pretty much anything, pretty much anywhere – motorways, coal-mines, airports, power stations – so long as they are ‘beautiful’.

I recall a recent transport minister opening his address to a meeting of environmental campaigners by declaring: “I am an aesthete”. He wanted to build lots of roads, but he also wanted them to be in tune with nature – which meant providing plenty of trees and badger crossings, and even cycle crossings (so that kept me happy!). He wanted to build the most beautiful roads possible. I recall an energy minister saying something similar about nuclear power stations.

Two years ago, the Government set up the Building Better, Building Beautiful Commission. It was co-chaired by the late Professor Roger Scruton and Nicholas Boyes Smith, founder of the charity Create Streets. Its final report to Government, Living with Beauty, was published 2 years later, and makes some very sensible recommendations.

It talks about the importance of creating places (not just houses), integrating nature into the built environment, regenerating ‘left-behind’ places, the importance of local democracy, and the achievement of ‘gentle densities’, where people live close together without requiring high-rise blocks, and where it is therefore easy to get around without depending on cars.

“Highway design can help reclaim streets for people, with the provision of cycle infrastructure or public transport supporting more humane and popular places. This now needs to become the norm, not the exception”
– ‘Living with Beauty’ report by the Building Better, Building Beautiful Commission

It notes how “highway design can help reclaim streets for people, with the provision of cycle infrastructure or public transport supporting more humane and popular places. This now needs to become the norm, not the exception.”

Unfortunately ministers have taken the report’s title and shorn it of much of the excellent supporting argument. Instead, they proposed in the Planning White Paper that any development deemed to be ‘beautiful’ should get a near-automatic pass through the planning system, almost regardless of where it is located.

This is an absolute recipe for entrenching car-dependence. As I said in a previous blog on the Government’s planning reforms: “A beautiful development in an unsustainable, car-dependent location is still an unsustainable development”.

This flawed thinking also reappears in the Government’s draft National Planning Policy Framework (NPPF). It is instructive to compare the paragraphs from the chapters on design and on sustainable transport, setting out the grounds on which local councils can or should refuse planning permission.

In the design chapter, paragraph 133 is admirably clear: “Development that is not well designed should be refused, especially where it fails to reflect local design policies and government guidance on design.” It goes on to say that “significant weight should be given to […] outstanding or innovative designs which promote high levels of sustainability”. This is all good stuff.

However, contrast this with paragraph 110, the equivalent paragraph in the sustainable transport chapter. “Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.”

In essence, local authorities cannot refuse planning applications, even where the development’s location means that there will inevitably be significant increases in traffic, unless they can prove that the “residual” impacts (even after providing improved public transport etc) would be “severe”. This is a very high hurdle.

Councils know that if they try to reject an application due to the extra traffic it would generate, the developer would probably use these words to bring a legal challenge, and would probably win. Very few councils have the strength to stand up to car-dependent developments.

So the growth in car-dependence continues. And we hurtle on, out of control, into an increasingly urgent climate crisis – not to mention the crises of urban congestion and pollution, physical inactivity, road danger and lack of mobility for children and other non-drivers.

Cycling UK’s consultation response to the draft NPPF and the accompanying National Model Design Code (a much better document) contains several recommendations for improvements. However, if I could have just one change, it would be to reword paragraph 110. It needs to say, as clearly as paragraph 133 does, that developments whose location is likely to increase dependence on motor-vehicles should simply be refused.”

Roger Geffen, Cycling UK

Cycling UK recently signed a joint letter to Housing Secretary Robert Jenrick – together with Transport for New Homes and other organisations – asking the Government to focus its planning reforms on reducing car dependence.

Homes Without Jams

Planning reforms risk adding “a tide of car traffic” to crowded roads, Housing Secretary told

As the Government prepares for a Planning Bill to be announced in next week’s Queen’s Speech, ten organisations have written to Housing Secretary Robert Jenrick urging changes to the Government’s proposed planning reforms to avoid adding a tide of car traffic to already overcrowded roads and undermining the Government’s wider social, economic and environmental goals.

Organisations including CPRE, RAC Foundation, Sustrans and the Transport Planning Society caution that new housing is being sited in places that cannot be served well by public transport, are inaccessible on foot or cycle and often have few or no local facilities. In addition, the design and layout of many developments inhibit walking, cycling and bus service provision; some developments even have no pavements. The Government’s proposed reforms to the planning system do not address this, and threaten to increase car dependence, air pollution and carbon emissions.

Jenny Raggett, coordinator of Transport for New Homes, which organised the letter, said:

“At present, sustainable transport is all too often treated as an afterthought or even ignored when new housing is being considered. Our on-the-ground research shows that this results in estates where people have to drive everywhere, because they have no alternatives. Future lifestyles are then built around the car. The Government’s planning reforms are an opportunity to address this and create attractive places for people to live with good public transport and local facilities that people can walk or cycle to rather than soulless car-based estates.”

The letter calls upon the Government to focus its planning reforms on reducing car dependence, by:

  • Revising the National Planning Policy Framework to give much more weight to developments around public transport and with good local services, and to discourage car-based developments.
  • Revising the housing targets system so as to locate more development in urban areas and close to public transport.
  • Bringing planning and transport closer together: integrating local plans with transport strategies.
  • Making funding available, including through the Housing Infrastructure Fund, to support sustainable transport for housing rather than big new roads and junctions.

Steve Gooding, Director, RAC Foundation, said:
“However ambitious the government’s targets are for the construction of new housing it will only ever be a fraction of the total housing stock year-by-year, but surely it is incumbent on us to ensure that whatever and wherever new housing is built it does not perpetuate the problems of the past? The worst – yet still avoidable – outcome would be to end up with cars parked in ways that obstruct walking, cycling and buses because the design of new developments has been poorly thought through, and for whose residents the alternatives to driving aren’t available because their location leaves them with poor connectivity to the services they need.”

Sarah Mitchell, Chief executive, Cycling UK, said:
“Last year, the Government set out a bold vision to make cycling and walking the norm for day-to-day local journeys. Yet the planning system is still providing housing in remote car-dependent locations, with dangerous road and junction layouts, making it difficult for people to get by without a car. This must change if we are to tackle the crises of congestion, pollution, inactivity-related ill-health and the climate, while enabling children and other non-drivers to get around independently.”

Paul Tuohy, Chief Executive, Campaign for Better Transport, said:
“Planning reforms must ensure that new developments do not lock in car-dependency. New housing should have basic amenities within easy walking distance and connectivity to employment, shopping and leisure by public transport, walking and cycling, creating healthier communities for generations to come.”

Mary Creagh, Chief Executive, Living Streets, said:
“The Planning Bill provides us with an opportunity to bake walking-friendly design and sustainable transport into new housing developments. We should build towards a green recovery from COVID-19, not stumble back into car dependency.”

Chris Todd, Director, Transport Action Network, said:
“History has shown us that we cannot build our way out of congestion. The current approach is creating a vicious circle as more roads lead to more car-based developments, leading to calls for more roads. This is fuelling a climate and health emergency. More cars result in more carbon emissions, more pollution, fewer and smaller areas for green space and increased sedentary lifestyles undermining quality of life and growing pressure on the NHS.”

Crispin Truman, chief executive of CPRE, the countryside charity said:
“Planning and transport should be two sides of the same coin. By ensuring all developments include low carbon public transport and active travel infrastructure that fit into people’s lives, we can begin creating healthy, carbon neutral communities. But right now our planning system is doing the opposite, producing dislocated, car dependent and land-hungry developments, especially in the countryside.
“These ill-conceived developments lock in car dependency and drive up carbon emissions that fuel runaway climate change. But there is a golden opportunity in the upcoming planning bill to change this approach and ensure all developments put public transport links, walking and cycling firmly ahead of road building. It’s high time the government steps up and locks in low carbon public transport for the nature friendly and healthy homes communities are calling for.”

ENDS

Notes to Editors

1) The letter to Robert Jenrick has been signed by Transport for New Homes, Campaign for Better Transport, CPRE the countryside charity, Cycling UK, Living Streets, Possible, RAC Foundation, Sustrans, Transport Action Network, and Transport Planning Society and can be read in full here.

2) Transport for New Homes’ “Homes Without Jams” campaign aims to reform the planning system so that new housing is built around sustainable transport. A crowdfunder to support the campaign closes in 5 days.

3) Transport for New Homes believes that everyone should have access to attractive housing, located and designed to ensure that people do not need to use or own cars to live a full life. Transport for New Homes is funded by the Foundation for Integrated Transport, a registered charity (115 63 63).

Three changes we’d like to see to the plans for the planning system

By Steve Chambers and Jenny Raggett, Transport for New Homes

When the government consulted on proposed upcoming changes to the planning system in August 2020 we responded based on what we’d learned from our visits to new housing estates, which is summarised in our 2018 and 2020 reports.

We don’t think the current planning system is working, especially when it comes to transport, so we were excited to learn what the government planned. But we had some concerns about the policies proposed. In short, we didn’t think they would make things better.

The government has now suggested that proposals as consulted are far from the final outcome and the new planning system is as yet unwritten. With that in mind we thought we’d bring together the most important changes we think should be brought forward in upcoming planning reform.

1. Change how infrastructure is funded

When new buildings are proposed the planning system ensures any negative impacts are mitigated by planning obligations and contributions. This should ensure that new homes have pavements and other transport options available as soon as they are occupied. This is either provided by an obligation where the developer provides the infrastructure or a cash contribution that funds the work being carried out by or on behalf of the local authority.

The consultation suggested the replacement of planning obligations and contributions with a flat rate infrastructure levy. This change might have brought simplicity but it would also have created inequity. New communities or extensions of old ones would be built without the most basic infrastructure because of lack of contribution and mitigation from developers. For example we already see new homes built without pavements connecting up to nearby bus stops and shops. Further reducing planning obligations and contributions risks exacerbating this problem.

Whilst we do not think the infrastructure levy could ever be a complete replacement for existing systems of planning obligations and contributions, we do think transport provision at new homes must be properly funded. Local and combined authorities should be able to set appropriate local rates of levy in order to fund sustainable transport. Whereas the flat rate system would have ignored local context, the setting of infrastructure levies locally would ensure local needs are met.

And what do we mean by infrastructure? Many people take ‘infrastructure’ to mean ‘roads’ and indeed we have seen how new or wider roads are assumed to be essential to take the new traffic generated by large greenfield housing estates. This emphasis we think is associated with an outdated model of development and future investment needs to be different. This could be the basic things like connecting smaller urban extensions to town centres by safe and convenient end-to-end walking and cycling routes or more ambitious plans like rapid transit systems for significantly expanding towns and cities. When we looked at garden towns and villages these were the top two shortcomings of them. The money wasn’t there. Light rail and rapid transit are especially important to pull together newly built and existing urban areas. However substantial funding is needed. If central government cannot supply the funds, then a local level levy with contributions pooled from several large developments may be a way forward.

2. Give the chance to consider developments so that sustainable transport is not forgotten

One of the aims of the reformed planning system is to build more homes and quickly. Whilst this is a laudable approach in a housing crisis, we already know that lack of proper planning consideration is causing developments to be built in the wrong places far from basic amenities and without sustainable transport options.

Several mechanisms have been proposed to streamline planning. These include moving the decision-making part of planning to be much earlier in the process, at the local plan stage, or instructing local authorities to designate areas for growth where scrutiny will be reduced.

Typically under the current system a larger site is considered three times in the planning process: at the local plan stage, at outline planning permission and at final planning permission. Each stage operates at a different scale and provides opportunities to ensure the development integrates well with existing towns and villages. Removing any of these strategies entirely runs the risk of forgetting about sustainable transport. New roads and easy access are often top priority but the walking, cycling and public transport connections in and out of the estate are considered secondary or left out completely.

We propose that the future planning system continues to provide opportunities for consultation and deliberation of development at the local plan, outline and final permission stages in relation to frequent and modern public transport and safe overlooked walking and cycling routes in and out of the development, even if the principle of new housing on the site has already been agreed.

3. Improve the local plan making process

New technologies could make plan making better, but proposed changes to the plan making process could jeopardise the opportunity.

Planning new homes and other development is often done piecemeal with several large new housing estates proposed without consideration of the interactions between them, other kinds of development, and nearby urban areas.

Plans often stop at the local authority border rather than being genuinely coordinated with those of neighbouring authorities. The result may be several large new urban extensions or ‘garden villages’ in the countryside uncoordinated in terms of better public transport provision or cycling and walking routes.

Each development comes with a complex transport assessment which models the effect of that development on the road system, and to a very limited extent, sustainable transport. However, the way people will travel around the area as a whole without a car, is not considered.

This uncoordinated approach is something which our future planning system may correct by the use of technology.

One of the most promising parts of the planning proposals is the use of data and geographic information systems (GIS). This, the government suggests, should inform every part of the planning process. By using maps in combination with data, different scenarios can be tested and a proper perspective achieved on a whole area, with the maps working seamlessly across local authority boundaries and the ability to zoom in and out to understand the implications of new build, whether it is in the right place, and how to get the associated infrastructure right. In terms of sustainable transport, the coordination of land use with new stations and/ or rapid transit can then be examined and options for where to build logically decided. The cycle network needed for a whole area can be discussed and mapped out with clarity. The disadvantages of choosing the wrong parcel of land to build on become apparent and mistakes avoided. With GIS the process of planning can become much more accessible to ordinary people because a shared interactive map means discussions can take place in an open way.

GIS has the big advantage over paper in that it can bring into focus a number of datasets and overlay them graphically. In terms of building in the right place and in the right way, data from many sources can be taken into consideration and viewed together. These datasets might cover anything from wildlife records to sustainable transport, from landscape to favourite walking areas, from air quality to type and density of housing. Maps can test out different scenarios so that the knowledge and expertise of our planners can be put to good use and the public can genuinely participate. The availability of data and GIS gives the opportunity to make much better decisions about planning generally, and especially about sustainable transport.

But planning authorities will need adequate time and resources to take advantage of these new technologies. Otherwise the opportunity to make better local plans will be lost in the rush to comply with arbitrary deadlines.

The planning system is in need of reform and new housing is desperately needed. But speeding the process up won’t necessarily make things better. In order to get more equitable and sustainable outcomes from the planning system we need to see infrastructure properly funded, automatic permission tempered by realistic expectations about transport provision and a plan making process that has the power to guide the places that are created.

We are crowdfunding for our Homes Without Jams campaign, which works to influence the government’s planning reforms, making the case for a green transport future for new homes. Please support our crowdfunder which closes in a matter of days.

Support the crowdfunder

Support the Homes Without Jams crowdfunder!

Are you concerned about the Government’s proposals to reform the planning system? Worried that the outcome will be more sprawling, car-dependent housing estates in the countryside connected by more roads?

We have the opportunity right now to make the case for a better way. The Government’s planning reforms are about to pass through Parliament, and there’s a broader debate happening too, about how we build a better future after the pandemic. But we must act now, before proposals become law and we’re locked into a future of car-dependence.

So today we’re launching a crowdfunder which we hope you’ll join.

If we can raise £6,000 together, our Homes Without Jams campaign will work to influence the Government’s planning reforms as they pass through Parliament, making the case for a green transport future.

We know that real change comes from the grassroots as well as from Government, so we’ll help local campaigners oppose car-dependent housing plans with a new campaigning guide.

And we’ll raise awareness among the public of the need for Homes Without Jams with a campaign video.

Transport for New Homes is a non-profit campaigning group which works to shine a spotlight on the problem of car-dependent new housing. In the past, our campaigns have featured on the Today programme and in the Times, the Guardian and the Telegraph. We’ve met with the Government’s Department for Transport and Ministry of Housing, Communities and Local Government and been cited by the Committee on Climate Change. So – with you on board – we know we can bring attention to this issue.

Please support our crowdfunder. Any amount that you can afford – large or small – will help towards our £6,000 target. Together let’s campaign to reform the planning system so that new housing is built with local shops, pubs and cafes at its heart… With a network of safe cycle routes and bike parking for every home… And with new stations, trams, modern bus routes and transport interchanges making public transport the easy choice for longer journeys.

Thank you.

For housing fit for the future, let’s get these policies right

The Government is consulting on changes to the National Model Design Code and National Planning Policy Framework. Together, these documents will set the direction for the housing that we build in the near future. With hundreds of thousands of new homes needed, it’s vital that these two documents take transport properly into account: we must do much better at building housing around local amenities and sustainable transport.

Transport for New Homes has responded to the Government’s consultation, which closes on 27 March. We’ve summed up our views below. If you have views on housing and transport, please respond to the consultation here.

National Model Design Code

Jenny RaggettTransport for New Homes Project Coordinator Jenny Raggett writes…

Transport for New Homes is much concerned with the quality of new housing developments. We were therefore interested to read the proposed National Design Code and associated Guidance and can see much good material with respect to the design and layout has been incorporated. However, we believe that unless the National Design Code goes further and addresses the wider issues of location of development and its orientation around sustainable transport modes, its intentions regarding good design will often fail ‘in real life’.

The draft National Design Code looks at new development in terms of different ‘contexts’: ‘town/city centre’, ‘urban neighbourhood’, ‘suburbs’, ‘outer suburbs’, ‘local centres’, ‘villages rural settlements’ and ‘industrial areas, business, science or retail parks’.

Once the context has been established, there follows a discussion for each regarding movement, nature, built form, identity, public space and so on as applied to that context. In terms of ‘movement’ the guidance has sections on subjects such as connected streets, junctions and crossings, car parking, cycle parking, density, gardens and balconies, meeting places, local services and so on.

So far, all well and good. But Transport for New Homes, has found an important omission in the Design Code. The ‘context’ most commonly chosen to accommodate housing targets in Local Plans, are the greenfield urban extension and the garden village. Yet these have been left out of the National Design Code completely. The Code does not cover the urban extension or the garden village as a ‘context’.

Does this omission matter? We think it does because it will mean that many developments being progressed in Local Plans are likely to fail most of the guidance straightaway, because of their location and their car dependency. The fine words describing green and well-designed places with pleasant local centres, meeting places, gardens and so on, and even good public transport links, are great. But if you are building (a) in a place that cannot be connected to existing streets to an existing town (b) around a new road system because you travel nearly everywhere by car, then the rest of the Guidance is hardly likely to be implemented.

The problem is ‘double trouble’. On one hand it is the excessive influence of the car and the sheer amount of space devoted to roads, parking and driveways in housing that we have seen in the places we have visited, in turn means less greenery, often tiny gardens and little space for urban trees. On the other hand it is the lack of modern public transport alternatives to enable people to avoid having to travel everywhere by car, and the lack of local shops and community provision to walk to. These also become univiable in a place where people are encouraged to just drive out.

In conclusion then:

  • The National Design Code needs some kind of explanation about mistakes made in the past and how and why changes are needed.
  • The Code needs to be better supported by the NPPF when it comes to sustainable transport provision, parking and the layout of estates.
  • There needs to be more discussion about how the right location is important and that certain locations are unsuitable.
  • Urban extensions and garden villages are two contexts that are omitted and these need their own sections in the National Design Code Guidance.
  • There needs to be more made of the way that stations, busways, tramways and cycleways are key components in the section on movement, and need early consideration in terms of the overall and local layout and design of an area.

National Planning Policy Framework

Steve ChambersTransport for New Homes Sustainable Transport Campaigner Steve Chambers writes…

Rather grandly the National Planning Policy Framework (NPPF) is now proposed to include the 17 Global Goals for Sustainable Development. We note Goal 11: Sustainable Cities and Communities says “By 2030, provide access to safe, affordable, accessible and sustainable transport systems for all, improving road safety, notably by expanding public transport, with special attention to the needs of those in vulnerable situations, women, children, persons with disabilities and older persons”.

We know from our research that planning outcomes currently fall far short of these goals. In particular we have found that new housing developments are predominately car dependent and lacking in sustainable transport systems, such as good walk and cycle provision as well as public transport. The NPPF should give stronger weight to the necessity of these features to ensure that only development that is compliant with these goals receives consent.

We are concerned with what the proposed revision to the NPPF doesn’t say. It is a missed opportunity to bring land use and transport planning together at the local level. It emphasises “sustainable development” throughout, but nowhere is this defined. The UN goals are mentioned, but these cannot be readily interpreted at the local level.

It doesn’t acknowledge that transport is inextricable from spatial planning. Demand for travel is derived from the spatial arrangement of activities/facilities. It has no independent function. Transport must therefore be integrated with the land use planning process.

Chapter 9 (Sustainable Transport) has not been revised, and remains very weak. It is insufficient for transport issues to be merely “considered” (para 103). This section is therefore now inconsistent with the strengthened paragraph 11. The proposed revision does not include any requirement to prioritise development within the existing urban envelope, over and above greenfield sites or previously used sites that are remote from the urban envelope (for example, and especially, airfields, which are almost by definition remote from urban areas).

It does not explicitly require local planning authorities to designate land for development that is accessible by sustainable modes of travel, or to exclude land that is not. Most fundamentally, the absence of sustainable transport provision is not given as a reason for the refusal of planning applications.

The NPPF has been revised, it appears, mainly in response to the report from the Building Better, Building Beautiful Commission. Around half of all the proposed new words are in chapter 12 “Achieving well-designed places”. It is to be hoped that NPPF will be further revised in the short term, specifically to address the issue of integrated transport and spatial planning.

It claims that “the planning system should be genuinely plan-led” (page 8, para 15). We agree that it should be. However, the present planning system is to a great extent led by, or at least heavily influenced by developers and landowners, not by plans that have been carefully devised to meet sustainable development objectives. In particular, development sites are selected from those offered by the private sector, not from those that can meet public (and other sustainable) transport accessibility criteria.

You can find our full response here.

If you would like to respond to the consultation you can do so here before 11:45pm on 27 March 2021.

Main photo © Stephen Craven (cc-by-sa/2.0)

Cafe

If conservation areas can have a mix of homes and amenities, why can’t newly planned communities?

We’re concerned that a proposed change to ‘permitted development rights’ would make it harder for local authorities to plan communities with a mix of homes, shops and services.

Our Homes Without Jams campaign is all about ensuring changes to the planning system result in new homes being built in the right locations with good transport options, and with all the things residents need at hand so they don’t need to rely on a car.

We responded to the 2020 Planning for the Future white paper and outlined our concerns about proposed changes we thought could make things worse and not better for transport options at newly built homes.

But planning reform is not a sleeping beast and although the planning white paper talked about upcoming radical changes, it is likely we will see incremental reforms proposed in the coming months. These smaller changes could add up when it comes to deciding what kind of new homes are delivered.

The government is consulting on one such change right now, an update to permitted development rights that would come into effect later this year.

Permitted development rights (PDR) speed up the planning process by giving blanket prior consent for changes to building use. Perhaps the most widely known PDR is the ability to convert office buildings to residential. Although this makes it easier to create more homes, questions have been raised about the quality of the homes and their location.

The consultation that is currently out proposes to allow many more buildings to be converted into residential.

In 2020, as a precursor to this, the government made another change to the planning system that consolidated the way we categorise buildings. This is a system known as use classes. The change took a very wide range of land uses, from offices to shops, restaurants, medical and light industrial and put them in a new unified commercial, business and service use class E.

This change allows a lot of flexibility for high streets and town centres. If a local authority designates the buildings in a neighbourhood centre for use class E it means all sorts of amenities and trip generators such as employment and retail/hospitality can set up without the need for a planning application to change use class.

However, the latest proposal to add the permitted development right to residential for all of use class E means it will be very difficult for local authorities to plan communities with a mix of homes and amenities. Although planning permission might be granted for a hub of use class E surrounded by new homes, it would be very easy for the developer to exercise the new PDR right to convert those amenities to residential.

In our 2018 and 2020 reports we found that new communities are being built without basic facilities like local shops, which means the only way to do anything is to drive.

The government consultation suggests an exemption might be possible for conservation areas. But why an exemption there and not for newly planned communities?

We are concerned that this new PDR will remove the ability to plan for communities where residents can easily walk and cycle to basic amenities and live fulfilling, healthy lives without the need to own a car. We think this change will result in more estates with nothing but houses.

The consultation is open until 28 January 2021.

To be kept up to date with the Homes Without Jams campaign please sign up here.

Together with 18 other organisations we have had a letter published in the Telegraph on this issue; the text of the letter can be read here.

Our joint letter to the Telegraph about high street planning

On 18 January 2021 our joint letter, written together with 18 organisations, was published in the Telegraph:

Sir

We urge the Government to think again about its proposals to allow high street businesses to be changed to housing without full planning permission. Based on recent experience, we believe that the proposals, if enacted, will lower housing standards and accessible, natural green infrastructure provision, extinguish local democracy, and end public participation.

Permissions for over one million new homes are already in place but these have not been built out, according to the Local Government Association. There is little case to be made that the current system does not deliver consent for development.

We believe that local people and businesses are best placed to lead the change in town centres – for example, in providing more space for health and wellbeing purposes.

The planning system needs to ensure: local, democratically accountable decisions; the right to have a say over all development decisions; more genuinely affordable homes for local people; environmental protection and recovery for biodiversity; heritage protection and provision of accessible green space and conservation; and strong climate mitigation and adaptation duties.

Miriam Turner and Hugh Knowles
Co-Chief Executives, Friends of the Earth

Hugh Ellis
Director of Policy, Town and Country Planning Association

Crispin Truman
Chief Executive, CPRE

Ian Harvey
Executive Director, Civic Voice

Julie Hirigoyen
Chief Executive, UK Green Building Council

Craig Bennett
Chief Executive, The Wildlife Trusts

Beccy Speight
Chief Executive, RSPB

James Cooper
Head of External Affairs, The Woodland Trust

Peter Hinton
Chief Executive, Chartered Institute for Archaeologists

David McDonald
Chair, Institute of Historic Building Conservation

Neil Redfern
Executive Director, Council for British Archaeology

Anna Liberadzki
Senior Campaigner, SumOfUs

Tom Platt
Director of Advocacy and Engagement, The Ramblers

Kit Stoner
Chief Executive, Bat Conservation Trust

Nicola Hodgson
Case Officer, Open Spaces Society

Fiona Mathews
The Mammal Society

Tony Gent
Chief Executive Officer, Amphibian and Reptile Conservation

Steve Chambers
Sustainable Transport Campaigner, Transport for New Homes

Naomi Luhde-Thompson
Director, Rights Community Action

This letter was first published in the Telegraph.

Homes Without Jams

Planning white paper risks more car dependent sprawl

Our country needs more homes. What we don’t need is more sprawling, car-dependent estates far from town centres and public transport links. The proposed planning reforms will cause the same problems as the current system when it comes to transport and new housing.

At Transport for New Homes we looked at the proposed reforms and considered what would be different on the ground if they were implemented. We considered the places we examined for our 2018 and 2020 research reports. We concluded that planning reform must take transport seriously or it will result in more traffic jams and air pollution, carbon emissions and unhealthy, isolated living.

We had several concerns with the reforms as proposed. The first, and for us most concerning, is that the proposals barely mention transport at all. We need to address how we will provide and fund public transport to the new places we plan to build.

We thought the division of all England into three categories: ‘growth’, ‘renewal’ and ‘protected’: is just too simplistic. The classification of most of the countryside as ‘growth areas’ would lock in a future of car-based sprawl around major road construction.

The proposals around local plans concerned us. Combined with the proposal to eliminate the outline planning permission stage from ‘growth area’ developments puts undue burden on the local plan stage and will not provide good outcomes. Removing cross-boundary planning responsibilities makes it even harder to properly plan transport at a relevant scale.

We thought the proposals around digital planning were interesting, but would do little to improve the quality of planning if the reforms were implemented as proposed.

When asked what one thing we’d like to see changed in order to stop the unsustainable tarmac estates, we usually point to funding. We need funding for sustainable transport. Walking and cycling infrastructure, bus services and new railway stations and lines. The infrastructure levy proposals do nothing to fix this problem and will almost certainly make things worse as transport has to fight with affordable housing and other development mitigation.

Are we defending the current system? No. Do we think these proposals would be better? Also, no.

Other organisations share our concerns

We were pleased to see our research was cited in the consultation response of the Royal Town Planning Institute (RTPI), Railfuture, Cycling UK and the Chartered Institution of Highways & Transportation (CIHT). The RTPI echoed our concern that car dependent sprawl would continue unabated by the proposed reforms. CIHT highlighted our findings about choice of remote sites for new housing development and how this has caused places with no pavements or public transport. The proposed new system doesn’t offer anything to help with that and could make things worse.

Join our campaign for Homes Without Jams

Planning needs to be reformed. But not like this. Our Homes Without Jams campaign will pursue the Government’s proposals through Parliament, making the case for a better way.

Join our Homes Without Jams campaign

This article was first published (in a slightly different form) in The Planner.

Image: roundabout in new development

The Planning White Paper – how to respond

Sorry, this consultation has now closed.

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.

Sorry, this consultation has now closed.

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