Written evidence submitted by St Albans Civic Society [FPS 057]



I am responding to the call for evidence on behalf of St Albans Civic Society, an amenity charity. The Society aims not only to protect the important architectural heritage of the historic city of Britain's first Christian martyr but also to promote the highest quality of design and build of new developments within the city. The Society engages with the planning process at both preplanning application consultations and the planning application stage. It has a Design Advisory Group that is composed of architects and a planner with academic experience and it has a separate long-standing Planning Advisory Group, which scrutinises all planning applications and submits objections to those that are considered unworthy or fail to meet the policies outlined in the St Albans City and District Local Plan.

The Society has over 350 signed up members who were invited, along with affiliated bodies, to give their views on the proposals in the White Paper.


       Is the current planning system working as it should do? What changes might need to be made? Are the Government’s proposals the right approach?


The Society shares the view that the present planning system is too complex and, therefore, tends to exclude local participation while at the same time allowing developers to build, too often, poor quality designs. There is a lack of transparency and meaningful engagement in the present system. There is a perceived lack of intelligent planning decisions – a product of a lack of skill and a gatekeeper rather than partnership culture in LPAs.

Though many of the general objectives of the While Paper are laudable in sentiment, the lack of practical details raise many concerns, especially with regard to the level of local input and in what could result in a very top down system. An overall criticism would be that while identifying problems in the existing planning system the White Paper proposals fall short of coming up with credible solutions in meeting the objectives of a faster, more transparent, simpler, democratic process that will produce affordable high quality build and protect communities' existing heritage.


  1. In seeking to build 300,000 homes a year, is the greatest obstacle the planning system or the subsequent build-out of properties with permission?


It seems that the underlying premise of the White Paper is that an outdated planning system is not fit for purpose and is a primary cause of the failure to build enough homes for a growing population. This is not an entirely fair analysis, as a lack of strategic thinking has also contributed to the housing crisis. The reliance on market forces to entirely solve the shortage of homes has been misguided and has created a dearth of appropriate residences, especially in regard to affordable and social housing.

A million homes waiting to be built is unacceptable when there is a shortage of housing so the imposition of tighter regulations and penalties should be imposed when approved applications are not implemented fully. At the same time it is important that infrastructure issues are dealt with early on so that local services are not put under exponential strain.

       How can the planning system ensure that buildings are beautiful and fit for purpose?


              Past emphasis on quantitative measures rather than aesthetic quality has marred development in the UK. It is recognised there are many subjective elements in making judgments about 'beauty' and it should not be forgotten that architectural icons like the Sydney Opera House and London's Tower Bridge were initially slated by the public. The development of design codes and the appointment of Chiefs of Design in LPAs is a step in the right direction. However, they should not be so prescriptive that they introduce an era of pastiche and stifle innovation. A careful balance needs to be drawn between standardisation and uniqueness, which will require both imagination and flexibility.


      4.  What approach should be used to determine the housing need and requirement of               a local authority?


              The recently proposed algorithm exposed the inappropriateness of assessing housing need through a mechanistic process. While understanding the desire to have a standardised method it is essential that there is flexibility that takes into account the local context and balances demand with infrastructure constraints.


       What is the best approach to ensure public engagement in the planning system? What role should modern technology and data play in this?


              It is important, in order to ensure public trust in the planning system, that community engagement has some statutory force. At present at the local level this is embodied in Neighbourhood Plans (NPs). There is concern that the proposals in Planning for the Future will weaken and diminish NPs so that their function will be merely to draft local design codes. Furthermore, at present, where there is no town or parish council, the regulations for establishing Neighbourhood Forums and preparing NPs are complex and onerous. The system needs to be simplified so that NPs can be put in place within a reasonable time scale (not five to six years that can be the case) and at an affordable cost.

              While welcoming more electronic communication to create greater access  to the planning process, the physical notification of planning applications is still a very important means of reaching some segments of the community so there needs to be a well-planned period of transition in terms of increasing any dependency on electronic communication in the planning system.


  1. How can the planning system ensure adequate and reasonable protection for areas and buildings of environmental, historical, and architectural importance?


              The present legislation covering Conservation Areas and Article 4 give LPAs powers to protect heritage but there tends to be a lack of protection because there is a failure of enforcement. Our experience is that all too often developers pay scant attention to imposed conditions as they are aware the LPA will not enforce or resist a challenge in the courts (often because of the financial implications).


  1. What changes, if any, are needed to the green belt?


              It has become a mantra that the Green Belt is sacrosanct but it is crucial that that this               tenet is observed.

              According to the NPPF, there are five stated purposes of including land within the green               belt:


              There are enough 'build-out' and brownfield sites to tackle the housing crisis without building on the Green Belt but it does require a strategic plan that does not just deal with housing on its own but takes into consideration economic factors to help balance demand.


      What progress has been made since the Committee’s 2018 report on capturing land value and how might the proposals improve outcomes? What further steps might also be needed?


              It is recognised there needs to be a balance between the incentive for developers               and the infrastructure requirements. A standard approach could be to put a percentage               tax on every square metre. However, our own particular concern about the issue is               related to St Albans'  proximity to London and the extra strain that puts on infrastructure               including the need for affordable homes. To ensure trust with the public any levy should               be hypothecated and not seen to be channelled elsewhere. 




              We believe that Civic Societies, like that of our own in St Albans, with their local knowledge and pool of expertise can help and support the planning process from the initial development to the planning application stage. Their commitment to creating 'better places' make Civic Societies powerful allies both in engaging local communities and insisting on high quality developments.




October 2020