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