Written evidence submitted by Neighbourhood Planners.London [FPS 032]
"I want to raise the importance of neighbourhood planning, not diminish it. To give neighbourhood plans more teeth & more breadth"
Rt Hon Robert Jenrick MP, Secretary of State for Housing, Communities & Local Government, September 2020
“Neighbourhood planning clearly provides benefits to communities and the built environment where conditions are supportive”
Impacts of Neighbourhood Planning in England, Final report to MHCLG, University of Reading, October 2020
1. Neighbourhood Planners.London exists to support neighbourhood planners in London and raise the profile of neighbourhood planning in the capital. We're a voluntary initiative set up in 2016 in response to direct experience of the first wave of neighbourhood planning in London. We maintain the definitive MAP and LIST of what is going on with neighbourhood forums and areas across London, publish research, convene events, inform public and policy debate, provide informal advice and keep neighbourhood planners in touch with each other.
2. The Planning for the Future White Paper provides the opportunity to take stock of the impact and role of neighbourhood planning in its first ten years and this is the focus of our evidence to the Committee. A strengthening of neighbourhood planning is an essential part of a wider strengthening of the planning system. Our thesis is that neighbourhood planning has confirmed the belief that by giving local communities more power and the right to plan their neighbourhood they will deliver positive change. As our State of Neighbourhood Planning in London shows neighbourhood forums have been established and neighbourhood plans made in most parts of London. They embrace a diverse range of communities and localities from inner to outer London and from the most affluent to those experiencing significant deprivation. The Government now needs to build on this progress by providing new foundations to, as the Secretary of State has expressed it, “give neighbourhood plans more teeth and more breadth” for the coming decade.
3. As good neighbourhood planners this submission is based on both a sound evidence base and strong engagement with the neighbourhood planning community. It is informed by a range of our own primary research and a virtual gathering of neighbourhood planners with 100 registrations, 35 neighbourhood forums and contributions from MHLCG officials and the Government’s former Chief Planner. The detail of this submission has been shared in draft with hundreds of neighbourhood planners in London for their input, including neighbourhood forum volunteers, local authority officers, consultants and others. It is informed by their direct experience.
Building on success
4. Our starting point is that:
Wider planning reform
5. Neighbourhood planning can only be effective when it is supported by the wider framework for the planning system. Neighbourhood planners are concerned by a general trend which is taking important decisions further away from local communities:
6. We support the principle that policies in both Local Plans and neighbourhood plans should not duplicate the National Planning Policy Framework. Local Plan policies should be pitched at a “strategic” level and with a requirement for general conformity with national and London-wide policies. Similarly neighbourhood plan policies should continue to be in general conformity with “strategic” policies set at Local Plan (and London Plan) level. While such principles were embedded to an extent in the 2012 NPPF, and have been made more explicit in recent iterations, our experience is that most London planning authorities have failed to respect the NPPF distinction between “strategic” and “non-strategic” policies. The White Paper also needs to clarify the future of the London Plan and ensure that it is both truly strategic and enabling of neighbourhood planning.
Giving neighbourhood plans more teeth
7. The future planning system can embrace a more significant role for neighbourhood planning in the following ways:
8. We note with concern the White Paper’s statement that “we will want to consider whether their content should become more focused to reflect our proposals for Local Plans” and welcome the Secretary of State’s contrary ambition for neighbourhood plans to have “more breadth”. There is a need to redress the balance between Local and neighbourhood plans as set out above. We share the conclusion of the Local Plan Expert Group to “limit the scope of local plans to strategic issues, thereby creating a clear role for Neighbourhood Plans”. This is essential if the added complexity in Local Plan preparation within a reduced time period envisaged by the White Paper is to be achieved. It is also essential that just as neighbourhood planning needs to work within an agreed strategic context so Local Plans need to be better informed by local considerations. This includes decisions over the new categories of land identified in the White Paper.
Strengthening neighbourhood planning
9. We have three priorities for improving the way neighbourhood planning is undertaken:
a) Reformed support programme – the support programme is critical to the growth of neighbourhood planning but needs to be overhauled and expanded to reach its full potential. The scale of the programme should be at least doubled – it provides unquestionable value for money and needs to be set in the context of the significant “new burden” support being provided to local planning authorities. The reform priorities we provided during the last review of the Support Programme remain valid and we identify the following as key:
b) Removing the headwinds – too much neighbourhood planning is despite rather than because of the support of others and the process through which it is managed. We identify the following priorities for reform:
c) Changing the culture – with important and valued exceptions, the culture within London Boroughs and the GLA and Mayoral Development Corporations has been antipathetic at best to the evolution of neighbourhood planning. There are too many cases of active hostility. This culture of delay, obfuscation and resistance is evidenced in our work on Community Infrastructure Levy, the role of Local Plans, Statements of Community Involvement, representations on the London Plan and a commissioned report on the potential of neighbourhood planning in deprived parts of London. It is also evident in the report and hearing session held by the GLA Planning Committee into the progress of neighbourhood planning. The London Mayor has also repeatedly failed to offer support for neighbourhood planning or design it into his programmes for the capital. One of the outcomes is that it is taking on average 49 months to progress from designation to a made plan in London and there are nine Boroughs categorised as neighbourhood planning “deserts” with no designated forums. The number of new forums being designated in London is significantly slowing down. Just as the White Paper “supports culture change” in the planning profession and seeks “world class civic engagement”, so it should result in a growing tide of support for neighbourhood planning in our urban areas as an outcome.
Engagement – learning from neighbourhoods
10. The White Paper states that “local councils should radically and profoundly re-invent the ambition, depth and breadth with which they engage with communities as they consult on Local Plans. Our reforms will democratise the planning process by putting a new emphasis on engagement at the plan-making stage.”
11. We ask that this radical re-invention learns the lessons from the best of neighbourhood planning and designs processes which are:
as an alternative to the complex, text heavy, jargon ridden, turgid, legalistic, remote, slow and inaccessible approaches run by local planning authorities that are regularly experienced by local communities. The Local Plan of the future needs to focus on strategic policies and address these at a local level which is meaningful and relevant to people and communities wanting to engage in the process.
12. We also speak from experience that the majority of community engagement in planning decisions takes place around planning applications and not forward plans. This will always be the case because of the nature, complexity and meaning of the issues involved. The White Paper’s welcome support for a radical and profound re-invention of community engagement in Local Plan preparation needs to be extended to planning applications. It is contradictory to think that community engagement can simply be moved upstream in the planning process.
13. We welcome the commitment to better planning through greater use of digital technology. It can play a key role in strengthening engagement, using data, increasing transparency and through mapping and the spatial expression of planning policies. Neighbourhood planning has been a significant source of innovation in the use of digital in plan making and we have run events and published a range of blogs on the approaches being used. Improving the planning application process and making documents digitally accessible (including via online maps) is a key starting point in harnessing digital, although it is important not to straitjacket the format being used by volunteers developing neighbourhood plans. The National Information Requirements for planning applications should be extended to require fully navigable 3D models of proposals that require a Design and Access Statement. Neighbourhood forums should have free, shared, online access to all data used by local planning authorities in preparing development plans and supplementary planning documents. Accessible summaries of key plans and proposals are also needed.
14. It is important that, if adopted, a “digital-first” approach complements and enhances public and community engagement in planning. Digital tools and approaches can engage new and larger audiences and bring fresh insights but this must not be at the expense of other traditional approaches and voices who do not engage digitally or the depth and detail that comes from face to face engagement. Improvements in digital engagement cannot compensate for the White Paper’s anticipated loss of opportunities for public and community engagement in planning applications, with the right to participate in individual development removed in 'growth' and 'renewal' areas. Nor can improvements in digital engagement provide an alternative to established methods, including basic publicity such as site notices and notification in local papers. There is also scope for making much better use of neighbourhood forums (and other local groups such as civic societies) as a means of publicising planning proposals. We support a blended approach which embraces on- and off-line engagement and which includes participation in both policy development and development management. The power of neighbourhood planning lies in geographical proximity.
Making the change
15. The White Paper is rightly provoking discussion and debate. This is unsettling for neighbourhood planners and this aspect of the planning system is highly dependent on volunteers making decisions about how best to use their time. The lack of detail in the White Paper and the widespread commentary that the role of neighbourhood planning is to be diminished is already resulting in volunteers choosing not to get involved. Some Forums report a “chilling” effect, especially from concern at the thought of having to produce a new neighbourhood plan shortly after an existing one to take account of any reforms. As a result plans are stalling and applications to establish new neighbourhood forums are being put on ice. To address this disruption we believe Ministers should: