Written evidence submitted by CPRE [FPS 077]

 

1.              CPRE, the countryside charity, campaigns for a beautiful and thriving countryside that enriches all our lives. As well as the national charity, we have 60,000 members and supporters, a network of 43 county-based charities and more than 200 district-based groups across England. Our members and supporters, including around 1,600 parish councils, are actively involved in local planning issues relating to the communities and wider countryside where they live.

2.              CPRE welcomes the opportunity to submit evidence. We have had a long interest in the overall spatial pattern of development in England. We are particularly concerned about using land effectively for housing and other forms of new development so that we can have:

Executive summary

 

  1. 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?
  1. Overall, CPRE believes that the planning system is working reasonably well in terms of protecting important areas of countryside and green space contained within Green Belts and protected landscapes, although we have concerns about the amount of development allowed as exceptions to current policy in both cases. (See Questions 6 and 7 below.) The public availability of planning information has improved in the past two decades. A steady stream of land is being made available for new housing development. There are however major questions as to whether the kind of housing that is actually urgently needed is being provided, and in a sufficiently timely fashion. (See Question 2 below.)
  2. There are aspects of the planning system that need to be reviewed and improved. In particular, and in line with some of the issues that government proposals wish to address, we have long campaigned for a better plan-making system as well as for much better up-front engagement in Local Plans and Neighbourhood Plans, thereby reducing reliance on the discretionary stage of the system as a way to account for community concern.
  3. Our 2020 What’s The Plan report looked into the difficulties that come with preparing and getting a plan approved, as well as keeping it up-to date, and found that under current NPPF requirements, only 30% of Local Plans can be classed as “up-to-date". This is due to the fact that a Local Plan is currently rendered out-of-date by default after 5 years (unless reviewed for consistency with updated evidence and national policy) and that it will also be considered out-of-date at any point in time (even shortly after its adoption) if it does not identify sufficient land to provide 5 years of housing development.
  4. This means that 70% of Local Plans currently have no guarantee that the policies and proposals they contain will actually be upheld, which significantly undermines the democratic accountability of our planning system and its ability to secure the right type of development in the right places.
  5. CPRE believes that the plan making system needs to be more strategic but also carry more political legitimacy and be more transparent. (See also 4 below.) CPRE believes that the legitimacy of plans could be boosted by involving MPs and local authority councillors in a more structured way; possible pointers lie in the parliamentary procedure for National Policy Statements (NPSs) in the Planning Act 2008, or in the role of the London Assembly planning committee in the production and scrutiny of the London Plan.
  6. There is scope to improve timescales for plan production in the system. Any reforms need to include statutory provisions to hold developers and local decision makers to account at both the policy and project stages. CPRE does not believe that this should involve greater use of Ministerial interventions under the Planning Act 2008 nationally significant infrastructure project (NSIP) process, particularly because most decisions on planning for housing should be taken locally. We do however think that there is scope to learn from the experience of the process of preparing NPSs (see above), but also from the use of development consent orders; these follow statutory timescales, and incorporate mandatory pre-application consultations (see also our response to question 3 below) and a number of consents in addition to planning permission. 
  7. The Government’s current proposals do not take the right approach. The 30-month timetable for new style Local Plans is wholly unrealistic, particularly if plans are also intended to carry the additional burden of granting outline planning permission and setting detailed design codes for major housing development sites. In addition, many local authorities will face considerably increased housing targets if the Government’s proposed new standard method for calculating housing need is included within the national Planning Practice Guidance, and generates binding local housebuilding targets as the White Paper proposes.
  8. The proposals currently only specify one, 6-week public consultation window in the plan-making process, which cannot possibly be enough to gather the necessary evidence and build consensus. What is particularly missing, at Stage 1 or before in the new plan-making process, is the opportunity for stakeholders to help shape a spatial vision for their area. Local authorities also need continued freedom to set local policies in line with this vision. For example, the Arnside & Silverdale AONB DPD contains locally-set development management polices specifically designed to conserve and enhance the AONB's special qualities, as part of upholding its statutory purpose. This is a good example of a policy covering topics on which current Government policy and guidance are insufficient. There may be scope for greater use of nationally drafted model policies, an option floated in the White Paper.

 

  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?
  1. CPRE does not believe that the planning system is the greatest obstacle to building 300,000 houses a year, and we would question whether it is even an obstacle at all. The principle issue in our view is clearly one of build-out. The considerable body of evidence amassed by Sir Oliver Letwin’s 2018 Review of Build Out in this regard has continued to be reinforced by relevant trends since.
  2. There is plenty of development land in the system. Much of this is suitable brownfield (previously developed) land: CPRE analysis in October 2020 of brownfield registers prepared by local planning authorities shows that brownfield plots available and suitable for housing could provide over 1,061,000 homes; of these, there is some form of planning permission for 565,000 homes. On top of this, Local Government Association analysis of land with planning permission suggests that there are at least a further (assumed to be on greenfield sites) 470,000 permitted plots in the pipeline that have yet to be built out. The combination of brownfield and other unbuilt plots with permission alone could suffice in meeting government’s target of 300,000 homes a year for the rest of this Parliament at least. There is therefore no need for hasty, improperly thought through reforms to the system; and particularly no need to diminish the scope for public participation in the misplaced expectation of time and cost efficiencies.
  3. The subsequent build-out of properties with permission is a key obstacle in seeking to build 300,000 homes a year. Partly this is due to the dominance and practices of large housebuilders, who have increased their level of control over the supply of suitable development land. Since 2011 Government policy has aimed to boost the supply of new housing and encourage the release of more land. CPRE analysis of the landbanks of major commercial housebuilders going back from 2016 to 2011 found that the leading 10 housebuilders have increased their short-term land banks (land mostly with an outline planning consent or better) by just under 90,000 to 398,704 plots, while completions by the same builders have only risen by 26,541 to 74,782.
  4. Sir Oliver Letwin’s 2018 Review of Build Out found that the median build out period on investigated large sites was 15.5 years. The report concluded that the fundamental drivers of the slow rate of built out are the homogeneity of the types and tenures of the homes on offer on these sites, and the limits on the rate at which the market will absorb such homogenous products.
  5. Much land with planning designation or consent for development is poorly located, and is unlikely to be realised without either major environmental damage or significant mitigating investment in sustainable transport options. Many of the schemes being taken forward in the Government’s garden village programme are a case in point, and a June 2020 report by Transport for New Homes argued that 20 of these schemes will between them generate 200,000 car dependent households.
  6. Consequently, the real question related to the planning system is not about whether it is an obstacle’ to housing development, but about how to make it more effective at delivering development in areas that can be made sustainable through provision of transport options other than the private car, and securing more diversity in the types and tenures of new development.
  7. CPRE is increasingly of the view that radical land reform is needed to address the major failings of housing supply in this country. (See our response to Question 8 below.)

 

  1. How can the planning system ensure that buildings are beautiful and fit for purpose?
  1. We agree with many of the White Paper proposals on design, in particular the call for a new body to provide advice on design quality. Urgent improvement in this area is clearly needed. We would argue however that the White Paper is deficient on one of the most critical elements of design – energy efficiency. The proposal to only reduce current emissions from new homes by 75-80% by 2050 represents more than thirty-four lost years in tackling the climate emergency, given that the former Code for Sustainable Homes aimed to achieve zero carbon new housing by 2016.
  2. The 2020 Housing Design Audit for England found that 75% of recently completed large housing schemes should not have been permitted if current design guidance had been respected, and as much as 94% in rural areas. [1]
  3. Key recommendations for Government include:
  1. The 2020 report provides powerful backing for the greater use of design codes as the most effective means to positively influence design quality. There are also proven methods of enabling the public to be involved in preparing and shaping design policies. Village Design Statements, such as the one within the made Neighbourhood Plan of Quorn, Leicestershire, often provide site-specific tools with contextually appropriate designs respecting the local vernacular and materials.
  2. However, the use of such tools and the sorts of design ambitions that they will espouse should be made clear in policy, well in advance of sites coming forward for development. Design codes in themselves cannot guarantee the design quality of future development. This can be exemplified with the case of Alconbury Weald, a mixed-use development built on the site of a former airfield in Cambridgeshire. Although working to the same design code developed by the owner Urban & Civic and agreed with the local planning authority (Huntingdonshire) for the first phase of development, different housebuilders produced markedly different qualities of places. Figures 1, 2, 3 and 4 show the results produced by a middle-sized regional developer and reflecting the local vernacular of East Anglia.

 


  1. Figures 5, 6, 7 and 8 show another part of the development undertaken by a national volume housebuilder, which compares poorly.