Written evidence submitted by Andrew Longley MRTPI, Head of the North Northamptonshire Joint Planning and Delivery Unit [FPS 147]
Response to the Select Committee’s questions
1.1 While there is scope to improve the planning system, we do not accept the central premise of the White Paper that the planning system is failing. This is not the case in North Northamptonshire. As set out above, we have well-established joint working arrangements, with an up-to-date and ambitious Joint Core Strategy. The Partner councils have adopted or are well advanced in preparing their Part 2 Local Plans to provide important local detail. Our high-performing development management teams consistently achieve top-quartile performance, and our design work has been widely recognised as good practice, resulting in our selection for the national ‘Future Place’ initiative in 2019. This positive planning framework, together with support from Homes England and the Government’s Garden Communities Programme, has helped us to deliver a nationally significant scale of growth. We have an ambition to continue to do this as part of the Oxford-Cambridge Arc.
1.2 We therefore consider that the focus of the White Paper on deregulating and simplifying the planning system in favour of the development industry is misplaced. Greater attention should be given to creating the conditions for growth through investment in infrastructure, jobs and the environment, and to measures to ensure that the development sector builds out consented sites without delay.
1.3 The White Paper proposes a radical overhaul of the planning system but gives little detail of how proposals would work in practice. This will create considerable uncertainty and disruption, which could impede rather than speed up development. We would prefer a refinement/ evolution of the existing planning system and the NN JPC response suggests potential improvements to some of the measures in the White Paper.
1.4 Our response to the White Paper highlights proposals that we support. These include some elements of streamlining local plans, the strong emphasis on design, greater digitisation of planning processes, and a resources and skills strategy for the planning sector. Significant resources will be required to implement these proposals and we welcome the Government’s commitment to provide financial support to enable local planning authorities to transition to the new planning system as part of the next Spending Review.
1.5 Our response raises some significant areas of concern with the White Paper, including:
2.1 In North Northamptonshire the greatest obstacle is subsequent build-out of properties with permission.
2.2 The planning system in North Northamptonshire is not a significant constraint on housing delivery. Over 13,000 new homes have been built between 2011 and 2019 and capacity is identified for over 30,000 more (including over 22,000 plots on sites with planning permissions). This high volume of planning work puts substantial pressure on the local planning authorities and ongoing support through the Garden Communities programme and other funding streams is essential.
2.3 The promoters of the Garden Community sites (with total capacity for 25,000 homes) report that viability constraints and delays in delivering key infrastructure (examples include junction 10a on the A14, the Isham-Wellingborough Improvement) are the main factors that will impede progress as these developments are built out. Support from Government and its agencies will be vital in overcoming these constraints.
2.4 We would also encourage Government to identify and introduce a range of measures (both incentives and penalties) to encourage the faster build out of consented land and to prevent developers from land banking and slowing the release of consented housing land to maximise sales values and/or increase their chances of achieving planning permission for other speculative sites. It is disappointing that the recommendations of the Letwin Review do not feature in the White Paper proposals.
3.1 We support the strong emphasis that the White Paper puts on design. We have concerns that further deregulation of the planning system is at odds with the objectives of promoting high quality design. It is however important that the important that the concept of “beauty” is properly understood as the aesthetics of individual buildings is only one ingredient of successful placemaking.
3.2 Design codes should not become catalogues for pastiche designs; nor should they stifle innovation and creativity in design. The design process, particularly for large sites, needs to be iterative and flexible in order to respond to changes in circumstances including changing demands, viability and technology. It is unrealistic to assume that the developer or local planning authority will be able to resolve all design issues at the Local Plan stage.
3.3 The NNJPDU monitors the quality of new housing development using Building for Life 12, and we will be using its update, Building for a Healthy Life 2020, as a key tool in assessing and shaping development proposals. It is noted that the NPPF recognises Building for Life at para 129 and it would be helpful if Building for a Healthy Life 2020 is similarly endorsed in national policy.
3.4 There is too much scope within the current planning system for developers to drive down quality to maximise profit. Recurrent design issues that need to be addressed in most schemes audited against BfL 12 in North Northamptonshire relate to lack of connectivity and legibility, poor street scene, lack of character and sense of place, car parking and bin storage.
3.5 Further national policy and guidance on design issues, including an updated Manual for Streets, will be helpful in raising design quality but the key to delivering good design is the capacity and skills available at the local level (both for plan making and in development management). The NNJPDU provides a shared design resource for the partner LPAs and we utilise Design Midlands for design reviews. However, we are still reliant on consultants for the capacity to address an escalating workload. We therefore welcome the commitment in the White Paper to a resource and skills strategy for the planning sector and look forward to seeing further detail of this.
4.1 A standard methodology provides a useful starting point for setting housing requirements in a Local Plan but should not be binding and it is essential that the methodology is robust.
4.2 The proposed Standard Method for assessing housing numbers in strategic plans recently consulted on is fundamentally flawed. It gives a high benchmark for North Northamptonshire based on household projections (which, unlike most of the country, have risen due to strong housing delivery). 65% is then added because increases in local house prices have outstripped household incomes (ignoring the fact that North Northamptonshire is one of the most affordable areas in the Oxford-Cambridge Arc and wider SE).
4.3 Household projections are a useful indication of demand but using them as a minimum benchmark for mandatory housing requirements would “bake in” previous performance, ensuring that places such as North Northamptonshire that have delivered significant housing growth must continue to do so, and places that have accommodated less can continue to do so.
4.4 The proposed standard method is also simplistic in its assumption that declining levels of affordability are due solely to under-supply of housing. This is clearly not the experience in North Northamptonshire, where high levels of housing delivery have been achieved (over 13,000 completions 2011-19), substantial amounts of housing land are committed (capacity identified for over 30,000 homes), but affordability based on local incomes has worsened
4.5 The Borough of Corby is a case in point. It has been the second fastest growing local authority outside London yet has also seen the third highest level of house-price inflation in the year to April 2020. This is in part due to the ongoing regeneration of the town making it more attractive to moving households. Local incomes have not kept pace with rising house prices, resulting in deteriorating affordability to local households, but not for the reasons anticipated in the standard method (constrained supply).
4.6 The issue of affordability for existing North Northamptonshire households will not be addressed by increasing the amount of land available for market housing. Households on the councils’ housing needs registers are priced out of the private housing market by virtue of relatively low or insecure incomes and/or lack of savings for a mortgage deposit. They require bespoke affordable housing products such as rent-to-buy in order to access home ownership. Coupled with opportunities for higher paid employment (as sought by the JCS focus on higher skilled jobs), this will be the most effective way of improving the affordability of market housing for the existing community.
4.7 The proposed standard method would result in a LHN for North Northamptonshire of 3,009 homes p.a., which is 72% more than the adopted Joint Core Strategy requirement. This would penalise North Northamptonshire for achieving significant growth and regeneration, with an unrealistic housing requirement that would frustrate proper spatial planning linking housing, jobs, and infrastructure.
4.8 The LHN for North Northamptonshire would be the highest of any authority in the Oxford-Cambridge Arc. This is nonsensical when we are peripheral to the main growth opportunities presented by the significant investment in east-west connectivity across the Arc, and our main towns are secondary economic centres. It would result in unsustainable patterns of development, highly dependent on out-commuting.
4.9 Our preferred approach is for LHN to be determined taking account of the wider context provided by the emerging Spatial Framework for the Oxford-Cambridge Arc, where it can be considered alongside employment provision, strategic infrastructure, and varying constraints, opportunities, and ambitions across the Arc.
4.10 If the Government persists with a top-down formula, it should at least be amended to remove the affordability adjustment in high-delivering areas such as North Northamptonshire, where housing land constraints are clearly not a major factor in local house prices.
4.11 In any event, we request that the Government amends or disapplies paragraph 73 of the NPPF to ensure that adopted Local Plan housing requirements in the Ox-Cam Arc remain in force until replaced by new plans prepared in the context of the Arc Spatial Framework.
5.1 There is no one size fits all for properly engaging with all parts of the community on all aspects of planning. An increased use of social media and digital tools is supported and may help to engage with younger people but could exclude others. For planning applications social media, online news and site notices are effective. For the plan making process these methods need to be supplemented by more proactive methods such as workshops, exhibitions and other consultation events.
6. How can the planning system ensure adequate and reasonable protection for areas and buildings of environmental, historical, and architectural importance?
6.1 We consider that the current system provides sufficient measures to achieve this. We have concerns that proposed changes and further deregulation through Permission in Principle, increased permitted development, etc may undermine these protections.
7. What changes, if any, are needed to the green belt?
7.1 North Northamptonshire has no green belt designations.
8. 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?
8.1 A simpler, more certain system of ensuring that the infrastructure and mitigation made necessary by development is provided is supported in principle. This includes the principle of an infrastructure levy to replace s106 and CIL, provided that this would give greater certainty over funding (preventing renegotiation on the basis of viability), and that it will secure more infrastructure funding and affordable housing than current arrangements. However, the White Paper provides insufficient detail to reassure the Joint Planning Committee that the proposed approach will secure more infrastructure funding and affordable housing than current s106 arrangement.
8.2 It is important that any levy reflects local variations in values. In areas where land values are relatively low, some or all of the value generated by the development could be below nationally determined thresholds and so not subject to the levy. In these circumstances it is difficult to understand how the necessary infrastructure would be provided. This is not acceptable and is a significant concern for parts of North Northamptonshire with lower land values and where viability is often cited by developers. The resulting infrastructure funding gap results in increased pressure on infrastructure and is one of the reasons there is often local opposition to growth, as existing local residents feel they are on the receiving end- more congested roads, larger class sizes, more difficult to access timely health care, etc. Whatever system is introduced must provide local areas with assurity that the infrastructure funding gap will not be increased and that the Government will continue to play its part in funding infrastructure.
8.3 Payment of any levy would need to start from the first completion on a site, as this is what drives demand for infrastructure. Any backloading of contributions will widen the funding gap.
 established by SI 2005 No 1552
 BCW were runners up in Planning Team of the Year in this years’ Planning Awards 2020
 the 2018 household projections use rates of household formation between 2001 and 2011, during which time three of the four North Northamptonshire authorities were in the top 20 fastest growing in the country
 ONS population growth 2013-18
 Land Registry
 we recommend that this applies to areas delivering 1% or more net addition to housing stock pa