Written evidence submitted by Abri [FPS 078]


About Abri

As one of the south of England’s largest housing providers with some 80,000 customers across 35,000 homes Abri plans to further invest in its homes, customers and communities. In 2020 we announced our commitment to invest £15m in our communities over the next five years.


We also plan to:


You can also learn more about why we are called Abri and how that links to our mission to build more, invest more and help fix the housing crisis, by watching this really short video (it’s fab you should give it a quick watch).


Why we are responding

Abri is submitting evidence as the planning system impacts everyone including our customers. We’d like to see a planning system that while being efficient, also has our customers and communities – the end users – at the forefront of the changes being made.

We firmly believe that more homes need to be build effectively but in a sustainable way without compromising on quality or design. A change to the planning system could fundamentally make this happen.

We also believe that the feedback and input from local communities is essential when bringing forward planning applications. 

We aim to build houses that people want to live in, that provide a safe, secure and warm environment and contribute to sustainable and strong communities. There is no incentive to build otherwise as people won’t want to buy them or live in them.



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?
Homes are being built, in numbers ever greater than before. In that sense, it’s a success. It is though still overly challenging, with opposition to development/redevelopment of sites an anticipated occurrence.

Communities feel disenfranchised (in terms of the planning system) and the only way they feel they can respond is to oppose individual schemes.

Perhaps more effort to include communities in the formulation of Local Plans (and from the very beginning) so that they buy into the process and the outcome – a simpler, less opaque and off-putting process. And it needs to be much shorter. HMG is proposing a 30-month process which we welcome.

The proposed new zonal system (areas identified for growth, renewal and protection) will potentially help with the front end but communities are as interested in the detail of design as they are in the principle. While the zonal system will potentially make the front end simpler, there is no guarantee of success at the other end as no changes are planned to the current system of determination of applications.


The proposed extension of Permission in Principle to cover major developments is welcome. This will help to smooth the path for applications on sites on the brownfield registers. We welcome the proposal for zoning and growth areas, with automatic grant of outline planning permission for the principle of development.


The proposed design codes for each local authority will present issues not just for major housebuilders (who use standard house designs) but also for SMEs. They will likely encourage communities to advocate for all manner of bells and whistles and will make the application of standard house types more difficult. There is potentially a need for national oversight. Design is subjective and we wonder if a local Design Code will therefore satisfy anyone? It might be better if Homes England were given a role in this and could give greater weight to design quality in its programmes.


The lack of resources within planning departments of local authorities continues to frustrate: meetings are hard to arrange, responses to queries are delayed, discharge of conditions takes far too long. The inconsistent application of local policies within an individual local planning authority continues to frustrate. This can be in terms of materials, mix, affordable housing and open space provision.



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?
The biggest hurdle is obtaining planning consent. It is expensive and carries risk, due to the Committee system. Some SME housebuilders are dissuaded from bringing applications forward on anything other than those sites with minimal or zero risk, which reduces diversity and opportunity. Fewer, bigger sites do not lead to accelerated housing delivery; we need a range of sites driving demand.

Engagement with some statutory consultees can also be very slow as can consultation with certain utilities.

Once we have consent, we want to build out as swiftly as possible. The land will be a cost that we need to reduce as swiftly as possible. The only reason we won’t build out straightaway will be discharge of pre-commencement conditions.

We’re pleased to see a move towards a Local Plan system that identifies land for development, with planning decisions to focus on resolving outstanding issues, not principle of development. There also needs to be a move to delegate more decisions to officers, especially where principle of development has been established. An easily accessible database of decisions taken by a local authority – enabling developers to challenge requests/requirements would be welcomed too.



How can the planning system ensure that buildings are beautiful and fit for purpose?
We aim to build houses that people want to live in, that provide a safe, secure and warm environment and contribute to sustainable and strong communities. There is no incentive to build otherwise as people won’t want to buy them or live in them.

A proposal for general presumption in favour of development in renewal areas with automatic approval if schemes meet design and other approval requirements could be an option.


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

It should be determined locally, using a nationally agreed set of criteria. There was unhappiness previously when regional spatial strategies led to a top down approach and there is unhappiness again now with the proposed standard methodology for calculating housing need figures.


The methodology seems more about achieving 300,000 homes per annum than addressing local need. This only serves to bolster objections from the local community. More effort could be made to conduct accurate local housing market needs assessments which would enjoy local support and inform the Local Plan.



What is the best approach to ensure public engagement in the planning system? What role should modern technology and data play in this?
Technology has moved on considerably during lock down, to ensure public consultation can continue. Online consultations are now available in different formats. As these are more technologically advanced, and flexible, it has opened up the consultation process to a wider demographic base than that experienced in the traditional ‘local hall with stands for people to read’. Wider and different audiences are being reached now by greater use of targeted social media. However, face to face consultation does still have its benefits and is still a preferred option to many people.

Simplification of the process and the language so that people feel comfortable with participation in the Local Plan review and start to understand the need to plan. In addition:




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

By building protections into local design guides this can ensure that any development brought forward in these areas is sympathetic to local heritage and environmental assets.

The planning system needs to ensure that any future changes to the planning system do not promote the concept of automatic blanket protections for these areas but encourages local authorities to take a flexible approach.

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

The Green Belt plays a key and enduring role in preventing urban sprawl and keeping land permanently open. However, it should not remain a static feature and a review of its effectiveness locally should be undertaken at the time of a Local Plan review.



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?

No comment


Affordable housing provision via developer contributions – current proposals in White Paper

HMG’s proposal is that S106 obligations should be removed and funds raised through the new Infrastructure Levy (replacing CIL) to secure affordable housing. This could be through in-kind provision on site or through purchase of stock elsewhere. Under this approach, a provider of affordable housing could purchase the dwelling at a discount from market rate, as now. However, rather than the discount being secured through Section 106 planning obligations, it would instead be considered as in-kind delivery of the Infrastructure Levy. In effect, the difference between the price at which the unit was sold to the provider and the market price would be offset from the final cash liability to the Levy. This would create an incentive for the developer to build on-site affordable housing where appropriate.


First Homes, which are sold by the developer direct to the customer at a discount to market price, would offset the discount against the cash liability.


An alternative option would be to require developers to offer a set proportion of units to the local authority or any RP ‘first refusal’ at a discounted price for affordable housing. Where such units were purchased, they could be used for affordable housing or sold at market value and the money reinvested in affordable housing elsewhere.



October 2020