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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.

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.

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.

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