Written evidence submitted by the Royal Town Planning Institute [FPS 113]

The Committee invites evidence on the following issues:

  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?

Despite clear links between the planning system and the country’s sustainable development ambitions, planning services are under increasing pressure and scrutiny. Local Planning Authorities (LPAs) are under pressure to deliver more services with fewer resources. Total expenditure on planning policy has fallen by 22% in England since 2010.

Planning is primarily measured against speed and quantity targets, rather than on the quality of development outcomes. The planning systems are typically judged against their ability to manage applications and grant development permissions quickly. Limiting planning to housing supply and delivery metrics can create a perception that the system is broken, and fails to measure the contribution of planning in enabling quality development outcomes. The RTPI is working with 3 governments in the UK and Ireland to take a hard look at better ways of evaluating their planning systems and will be publishing proposals in early November.

 

There is currently an imbalance in how planning is funded and the planning functions which deliver benefits. The majority of planning expenditure is on development management, and plan-making activities are unable to generate revenue. When plan-making is under-resourced, the framework for making development decisions may not reflect strategic priorities.

 

There is unequal access to good planning services and their benefits. Inequities in LPA resources can deepen regional inequalities. Currently, planning services primarily serve the most well-off areas, despite the fact that planning supports health and housing for all. Local authorities in areas with poor health and social outcomes are also harder hit by budget cuts to planning.

Our members want to work under a better system, but are understandably concerned that the significant resources that are required to make it a success will not materialise. Without this, the sweeping changes proposed in the Planning White Paper create a very real risk of unintended consequences - disenfranchising communities, reducing flexibility, and  undermining our ability to tackle the housing crisis and achieve net zero carbon.

The commitment in the White Paper to deliver a comprehensive resources and skills strategy is therefore fundamental to successful reform. We would welcome publication of the strategy at the earliest possible date, and it must address the current funding issues as well as the requirements of reform.

Government support for planning as a profession is crucial, and we welcome the commitment to Chief Placemakers in every local authority to provide leadership and direction. Crucially, we believe that these should be Chartered Town Planners, who have the appropriate skillset for such a task. Government should also closely examine means of ensuring that those who identify themselves as planners are qualified and held to the standards of their professional body. We would also like to see more support for the talent pipeline—the RTPI currently runs apprenticeship schemes that help broaden access to careers in planning.

In our submission to what was going to be a Comprehensive Spending Review we called for £500 million to  be made available urgently to ensure the planning system continues to function. We proposed this would be divided into a number of subfunds which would be dedicated to specific outcomes such as increasing community engagement, digital planning and plan making. Our research has shown that since 2010 the planning system has increasingly depended on planning fees, which means that non funded aspects such as plan making are declining. This does not bode well in relation to the government’s proposals to place greater emphasis on the local plan.

We support the government’s proposed “Growth” and “Protected” areas (with some reservations) but consider that the concept of “Renewal” areas is too simplistic. It appears that “Renewal” is what is left over when the other two designations are determined. However as envisaged it would cover the entirety of England’s existing built up areas, from long established suburbs to industrial areas actually needing renewal. This would also incorporate a whole range of town and city centres with their complex land uses and important heritage. Most people would live in a renewal area and they would form a key part of the country’s recovery.

Growth areas are important because they would hopefully convey greater certainty on the planning process. Developers find it frustrating when local plan allocations are overturned, and the public is hugely disappointed when sites allocated in plans simply fail to deliver on the promises made when the allocations were agreed.

“Protected” areas must move forward and improve, not just be “protected”. The environmental quality of much of England leaves a great deal to be desired, and people’s need to be able to access open spaces, and to use active travel (especially cycling) to make longer journeys, has been clearly demonstrated in 2020. This is a great opportunity to join up planning reforms with changes in our environmental governance and policy arising from Brexit. We call for single Local Environment Improvement Plans over wide areas which draw together a wide range of planning and funding regimes in the environment sector, and work in alignment with the growth area designations. Planning over wide areas is essential here.

  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?

There has been a sustained increase in the number of planning permissions for housing rising from 187,000 in 2010 to 398,800 in 2019, yet there has been no discernible impact on house prices. Increased planning permissions will not automatically translate to significantly more homes delivered unless the issues around build out are addressed. We must also see safeguards to ensure that difficult brownfield sites are not left untouched in favour of easier sites and that reforms do not lead to unsustainable settlement patterns.

We participated with enthusiasm in the Letwin Review of build out and would endorse many of its recommendations - in particular the emphasis on the need for strong public sector capacity to manage sites after the grant of planning permission.  The planning system (and indeed the planning profession) is not simply here to see that permissions get granted.

 

  1. How can the planning system ensure that buildings are beautiful and fit for purpose?

Planners want to have the levers to be able to demand quality design, with 87% of our members wanting more say in this area. Investment in local authority design capabilities would also be a crucial support for ensuring good design. 

The current developer model of selling homes and not retaining any further connection with schemes does not seem conducive to design quality.  There have been improvements since the 1980s, when the government decided that the planning system had no place in design (Circular 22/80). However there is a lot further to go, as the recent Housing Design Audit published by the Place Alliance demonstrates. The large majority of developments are still mediocre’ or ‘poor’. 

Research about to be published at the Collaborative Centre for Housing Evidence CACHE catalogues the way in which high standards for schemes may be promised when they are first included in local plans, but successive changes of ownership can often lead to poorer outcomes.

It is a general observation that the highest standards of design appear to be demonstrated most frequently in cases where landowners have taken a long term interest. An approach whereby the developers of sites retain an interest in maintaining their long term value (such as proposed by The Stewardship Initiative) could be more widely adopted.

Buildings need to be more than just 'beautiful'. They need to be spacious, filled with light, and designed with the highest standards of energy and water efficiency. They need to have access to green spaces, jobs, shops and services by healthy, sustainable and affordable modes of transport. They need to be ready to receive zero-carbon electricity from a smart and decentralised grid, and built from materials with low embodied carbon.

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

We are concerned that a data-driven formula devised in a single Whitehall department will struggle to embrace all the possibilities inherent in a truly proactive planning process.  Constraints should be determined through the plan-making process, not beforehand - although better upfront data from different sources would help.

If this system of central determination is ever introduced, it must at the very least include demonstrable and transparent input from DfT, BEIS and DEFRA to show how opportunities that result from the changes described above have been factored in. At a national level, the government’s aspirations for levelling up will require input from BEIS and possibly the Treasury.

Affordability calculations should not just lead to a housing target, but to specific targets by tenure (social rent, affordable rent, intermediate rent and affordable homeownership). This should be used to allocate increased public subsidy for affordable housing to local authorities. 

In our response to the Planning White Paper we have proposed that Green Growth Boards comprising key council members should be established voluntarily across wider areas.  These would serve to ensure that interrelated strategies on skills, healthcare, public health, transport, utilities and the environment.

The public health crisis of 2020 has only strengthened the arguments in favour of strong local leadership on these issues and of linking them together. For example strategic greenspace is critical to both health and biodiveristy and may well need planning over wider areas than single local planning authorities.

This approach then enables the following issues to be considered:

       Where transport corridors are being enhanced

       Where corridors for nature improvement will be delivered

       How individual local planning authorities will share housing needs

       How the subregion’s employment needs will be meet

       Will more working from home have an impact

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

The Government’s proposals to take engagement upstream represent a major challenge. For a long time the planning profession has struggled to get people involved in plan making. We welcome the Government’s commitment to this, and consider that there are certain changes to the context which may assist.

       The proposal to make the local plan the last chance to engage, at least in Growth areas

       New digital technology – and the experience of relying on it in 2020

       Increased emphasis on making the Local Plan visual and easy to comprehend

However it is still an enormous challenge to overturn 70 years of people’s expectations that they can be involved in individual planning decisions. At the very least, it will require a national campaign of education plus significant extra resources for community engagement at local level. These are very high prices to pay for the achievement of the principle of early engagement and one might question whether a period of considerable economic uncertainty is the time to try this. The Labour government instituted a minor culture change in 2004 which was not sufficiently resourced, despite the Planning Delivery Grant.

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

The proposed Renewal areas incorporate a whole range of town and city centres with their complex land uses and important heritage. Many high streets and town centres require planned regeneration, while cultural and historic heritage assets benefit from careful management. A greater focus on ‘permission in principle and ‘zoning for growth’ assumes that heritage constraints are well established. Unfortunately many Local Authorities only have limited coverage and increased permitted development rights risk non-designated heritage being lost without due consideration. For example, when last comprehensively assessed, less than 20% of conservation areas had adopted management plans and only a minority of Local Authorities have detailed registers of ‘local heritage assets/locally listed buildings’. The modest coverage of ‘local lists’ is acknowledged in the recent Government work on promoting this area of heritage protection.

 

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

Green Belts were devised as part of city-region-wide growth strategies. The point was to direct growth to New Towns just outside the green belts. At least as much effort and resources should go into the creation of the new communities as in defending the green belts. The concept has not been delivered as it was intended for several decades.

In place of blanket green belts, the RTPI would support broad growth strategies agreed across whole city regions (see Green Growth Boards in q4 above). This enables the identification of transport corridors which can be enhanced and along which development may take place, together with green corridors in which the environment is enhanced for wildlife and accessible walking, cycling and public transport.

  1. 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?

The Government published new National Planning Policy in 2018 which sought to drive down land prices through the strong enforcement of planning policy. At the time Ministers said that paying too much for your land was no excuse not to comply with policy requirements.   (This was a major change of direction from the policy applied after 2010.)

However this firmer approach still does not prevent land owners from simply sitting on land and not seeking planning permission for it, nor does it prevent owners from failing to implement permissions they have been granted. The most straightforward way to both deliver value and also get homes built quickly would be for well-resourced public bodies to acquire land from owners and then involve those owners in profit sharing schemes to share some of the uplift (but probably rather less than some may expect). Otherwise the only recourse is compulsory purchase, which is not straightforward at all.

Moving forward the approach in the White Paper appears to be limited to the proposal for a new consolidated Levy to raise funding for affordable housing and infrastructure. It does not address wider challenges around the integrated planning of infrastructure - a key omission which we cover in the recommendations above, and our research.

While the concept of a single Levy has some appeal, our analysis suggests that it could create an equally complex system, while failing to raise more funding for affordable housing and infrastructure, potentially undermining the levelling up agenda, and holding back development in sustainable locations.

Instead of focusing on yet another reform of the system, we call on government to reduce the overall use of developer contributions to fund affordable housing, in favour of a substantially increased programme of grant funding for direct delivery by councils and registered providers. This should be at a scale which can meet the recognised need for 145,000 social homes each year, including 90,000 for social rent. This would in turn allow local authorities to set lower and more consistent policy requirements for affordable housing: supporting SMEs, incentivising brownfield regeneration, and generally speeding up the delivery of high-quality developments.

Proper funding of affordable housing would enable a greater portion of developer contributions to invest in the infrastructure needed to accelerate the transition to net zero carbon, among other priorities identified in Infrastructure Delivery Plans. Clear and ambitious policy requirements would help to control the increase in land values that might otherwise result from a reduction in requirements to fund affordable housing through S106.

The changes above would need to be coupled with greater certainty on national infrastructure funding, to provide clarity about what infrastructure should be secured through on-site provision versus other sources, and helping developers price land properly.

 

October 2020