by Alister Scott
The media is alive with the sound of planning policy again as the Communities and Local Government Select Committee publishes its report looking into the operation and impact of the National Policy Planning Framework. Using some of the key headlines from the report, I offer my preliminary assessment.
We should ensure that the same weight is given to the environmental and social as to the economic dimension
Economic considerations continue to trump environmental and social matters in decision making through our fetish for economic growth. In particular, the assessment of viability in the NPPF has been too heavily weighted in the developer interest. The lack of transparency in these assessments is a matter of concern as brownfield-first policies and affordability housing quotas can easily be bypassed. It is also equally important to consider environmental and social limits in such decisions where the concepts of natural and social capital provide useful tools for decision making.
All councils must move much more quickly to get an adopted plan in place
Only 41% of local authorities have a local plan in place. At present it is in the developer’s interest for plans to be delayed enabling development to be considered on an ad-hoc, case by case, basis on sustainable development grounds as defined within all 209 paragraphs in the NPPF. This developer free-for-all does not make for good or consistent planning and certainly goes against any form of localism. From my observations at local plan inquiries this leads to developers queuing up to challenge housing need numbers within their own pseudo ‘duty to obfuscate’. This local plan delay is further hindered by the acute lack of planning inspectors after significant cuts to the Planning Inspectorate.
There also needs to be clearer guidance about how housing need should be assessed
At present local authorities are required to undertake objective assessments of housing need. Unfortunately, this new requirement is a statistical minefield, with the key DCLG and ONS data on which such assessments are based, full of statistical anomalies and difficulties associated with the impacts of the recent recession and (im)migration. This leads to excessive dispute about any derived figure by local authorities causing further delays to the local plan process. In my view there needs to be an approved methodology subject to local modifications before housing need assessments are undertaken, thus eliminating disputed figures. Joint initiatives such as the Greater Birmingham and Solihull and Black Country Local Enterprise Partnership joint housing study provide a model here for the way forward.
The replacement of strategic regional planning with the duty to cooperate has been beset by problems. First, is the fetish for housing as the principal driver for the duty to cooperate tests. Other strategic matters such as climate change, energy and infrastructure seem to be bypassed here in favour of only one part of the built and natural environment jigsaw. In my view it is time for a more strategic model of planning to support the NPPF as for example provided by Futures Network West Midlands. At present we are sleepwalking into a half-baked regional model based on local enterprise partnerships and some combined authorities (as long as they follow the government requirement for an elected mayor). This piecemeal, ‘make it up as you go along’ approach is not the way to do proper planning and is an insult to the professional training that planners receive. At the heart of this lies the need for closer integration and collaboration across scales and sectors but without further complicating the many layers of governance we already have.
Local authorities should be encouraged to review their green belts as part of the local planning process
There is clear evidence that the green belt is not fit for purpose. They seem to be all too readily bypassed in some planning decisions whilst they also help fossilise landscape. There needs to be wider recognition of the way a revitalised green space designation can help to maximise environmental and social benefits as opposed to the current fossilization of the landscape with no positive incentive for land management. There needs to be improved leadership here by government to recognise the wider benefits of such a green designation that works with the development needs of an area. The concept of multiple benefits is key here.
Permitted development is the enemy of good planning
There have been a whole raft of recent permitted development changes which are eroding the fundamentals of good planning. This incremental change to planning policy is also unwelcome as it creates further uncertainty and indeed can operate against the main policy focus of an approved local plan such as town centre regeneration. Crucially such provisions have been imposed on local planning authorities challenging any notions of localism. Thus the ability of conversions from employment to residential uses in town centres is leading to the hollowing out of town centres further threatening their viability. The recent changes in rural areas allowing farmers to convert barns to residential uses goes against a firm tenet of countryside policy to avoid isolated development in the countryside unrelated to settlements. The policy on enabling 8m housing extensions also fails to take account of the cumulative impact of such developments on a neighbourhood.
In conclusion the NPPF can do much better and needs to improve the cooperation across local planning authorities on all matters; not just those dealing with housing and employment land. The lack of strategic planning is a serious problem at present and the consistent tinkering with the system in the name of economic growth is simply creating further uncertainty in the planning system. It is this which is the true enemy of enterprise.