Written evidence submitted by the National Trust [FPS 157]

 

With our staff, members, volunteers and supporters, the National Trust is the biggest conservation charity in Europe. We protect and care for places so people and nature can thrive. Many millions share the belief that nature, beauty and history are for everyone. So we look after the nation’s coastline, historic sites, countryside and green spaces, ensuring everyone benefits. For everyone, for ever.

 

Introduction

 

  1. The National Trust welcomes the opportunity to respond to this call for evidence, on the future of the planning system in the UK. As the UK’s largest private landowner, planning law and processes affect our work. From managing our own land and buildings and ensuring the highest standards of sustainable development for new builds on our own land, to making sure we contribute constructively and effectively to development proposals submitted by our neighbours and government.
  2. The planning system that we have, when operating at its most strategic and effective, can be a force for significant good, and impact positively on our individual and collective wellbeing in a range of ways - our health, our economy, and our ability to live, work and relax. Our environment has a huge effect on our health, wellbeing and prosperity. High quality places are those that make the most of local heritage and nature offer distinctive and beautiful, healthy environments, that people want to live and work in. Access to green space, history, culture and nature bring substantial economic and social benefits, contributes to the regeneration of high streets and towns, promotes individual wellbeing, and forms the backbone of the visitor economy.
  3. It is for these reasons that the National Trust takes great interest in the future of the planning system in the UK. We support the principle of an effective and proportionate planning system, that integrates and balances economic, social and environmental concerns, and we have welcomed the Government’s ambitions to do this in their White Paper. However, we do have some fundamental concerns around the White Paper, and the risks posed to heritage and nature.

Summary and Q.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. The planning system is the nation’s most important tool for shaping the physical environment and creating a positive future. An effective system should deliver appropriate development in the right places, provide communities with necessary services and infrastructure, safeguard our environmental future, and enhance and conserve our historic and natural environments to create great places to live for everyone’s benefit. It also needs to be balanced, and capable of delivering multiple benefits. It must work at a range of scales from the fine grain of the urban environment, to that of the open landscapes, catchments and ecosystems that are critical for future sustainability and survival. It must be adaptive, able to anticipate and respond to climate and other forms of change, and it cannot be a ‘standalone system’ but must operate in conjunction with other policy, regulatory and fiscal tools to deliver holistic outcomes.
  2. From short to medium term shocks like the Covid-19 pandemic and the uncertain impact of EU exit on the economy, to longer term nature and climate crises, the challenges we face as a nation are greater than ever, and we need a planning system that supports us to respond. The National Trust agrees that we must ‘build back better’, and would like to see a recovery that respects and makes best use of our past, allows equal opportunities for people to thrive and enjoy our present in nature and culture, and secures our future with action on climate and the environment.
  3. This means an approach that delivers long-term social and environmental improvement as well as short-term economic gain; that puts a priority on enhancing the health and wellbeing of individuals and communities. Long-term planning cannot be about short-term economic growth alone. Our goals should be to build social, cultural and natural capital, drive a low carbon transition, and deliver climate resilience and mitigation alongside economic gain. Putting the right conditions in place to drive sustainable economic activity and job creation that meets the needs of the future should be a key aim.
  4. We should also recognise the opportunity to use the planning system to help address inequalities of ‘place’. The Covid-19 pandemic has not impacted everyone equally and has thrown into sharp relief how those living in lower quality environments, without access to nature or cultural facilities, have been particularly affected. Our goal should be to create more high quality, locally distinct places so everyone can enjoy nature-rich, green spaces on their doorstep, access to local heritage and shared cultural spaces that help bring communities together.
  5. There are a number of principles we think should be at the heart of any changes to the planning system to support these ambitions. These include:

 

 

 

  1. The very significant changes proposed in the Planning White Paper to a system which, while not perfect, has served us well for almost 75 years, demand close measured scrutiny. Not just in terms of how to implement the proposals well, which in itself is important, but also to ensure that we understand precisely what the changes will mean in practice. The complete overhaul of our planning system is too important to take lightly or to rush. Anything less risks potential negative impacts for generations to come.
  2. The single biggest risk with the White Paper is that in the quest for speed and simplicity it simply does not adequately address enough of the above. The extent of the planning reforms being put forward by the Government are sweeping, but light on practical detail. At a high level, we can see how they might produce some appropriate development decisions. Our overarching concern is that, with its headline approach of boundaries and subdivisions, tick box codes and automatic permissions, the Planning White Paper as currently conceived misses the bigger point. Our aim should be something at once smarter and more ambitious.
  3. There is currently little detail in the consultation on how the Government proposes to implement its proposals, which to some extent limits our ability to assess whether or not they will ultimately deliver the right outcomes for people, heritage and the environment. However, we summarise below the what the Trust would like to see addressed as proposals are further developed. This is not an exhaustive list but does represent some key elements. We build out many of these points later in our submission:
  1. The next steps in shaping and developing these proposals will be crucial. In order to fully understand the implications and potential unintended consequences of these reforms, and to ensure that the right safeguards, processes and guidance are in place, there needs to be additional and detailed consultation with the sector.

Q.2 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. The National Trust fundamentally disagrees with the idea that the planning system is the sole blocker to bringing forward housing delivery, growth and development in general. The latest figures around unimplemented planning permissions from the LGA are revealing.[1] These figures show that 2,564,600 units have been granted planning permission by councils since 2009/10 while only 1,530,680 have been completed. The number of planning permissions granted for new homes has almost doubled since 2012/13 with councils approving 9 in 10 applications. While there is a time lag between permission being granted and homes being built, new build completions have only increased by half as much in that time. LGA research also indicates a 52 per cent decrease in house-building work starting and a 62 per cent decrease in homes completed in April to June 2020 compared with the same period last year.[2]  When these figures are coupled it builds a compelling case indeed for recognising that more needs to be done to implement permissions already granted, and to support continued housebuilding in uncertain times. Arguably, the planning system is being effective in consenting housing schemes.
  2. We note that the Government’s Independent Review of Build Out conducted by Sir Oliver Letwin concluded the Government should introduce a new set of planning rules requiring those developing such sites to provide a diversity of offerings. We would like to understand what progress has been taken in implementing the proposals of the review.
  3. The chronic under-resourcing of local authorities also has an impact. Fewer, less experienced staff in Local Authorities are managing increasing numbers of planning applications and this will inevitably have an impact on the service offered (as we discuss in more detail later in this submission).
  4. We recognise that the challenges are complex, but they are issues that the Government will also need to address to achieve its aims. In recommending the 300,000 homes per year target in 2016, the House of Lords Economic Affairs Select Committee highlighted that the Government must recognise that these wouldn’t be delivered by the private sector as currently incentivised. Instead, it would also depend on incentivising and enabling delivery by local authorities and housing associations, with them making a much bigger contribution to housebuilding.[3]

Q.3 How can the planning system ensure that buildings are beautiful and fit for purpose?

 

  1. The National Trust was founded on the simple and enduring idea that people need historic, beautiful and natural places. Beauty and quality of design in our built environment can have a powerful effect on people, bringing genuine happiness and wellbeing, and should be part of the broad objectives of the planning and development process. However, beauty cannot come at the expense of well designed, accessible and sustainable buildings and places. Aesthetics and style are important, but people’s emotional response to place is built on other factors, including how easy a place is to navigate and use and how safe and comfortable they feel, as well as how it looks.
  2. Setting clearer standards for design could be a powerful way to drive up quality and beauty in development. But we do not want or need every settlement to look and feel the same. There must be flexibility to allow for local distinctiveness, variety of materials and styles, and to allow for development that fits with the existing vernacular buildings. Historic buildings and fabric, as well as natural environment features and green infrastructure, are integral parts of place and why people connect to place. They should therefore be integrated into design thinking and the resources for delivering well designed places.
  3. In terms of the proposals in the Government’s White Paper, we wholeheartedly support the ambition and commitment to driving up design standards and improving places where people live.  We believe that design guidance could play an important role in this. But creating a clear framework of design guides and codes across different geographical scales and the scope of considerations will be a challenge. We think that the proposals as currently framed in the Government’s White Paper are lacking in the necessary clarity and detail to make design coding a success – we would like to see a framework developed at both national and local level which includes integrated elements such as design guides (including a review of the Manual for Streets), master planning, design codes, clear standards for energy efficiency and low carbon heating, access to greenspace, and mechanisms for Design Review (such as local panels) with nationwide coverage.
  4. One of the key challenges will be ensuring design codes are robust enough, so that development in a large area still feels cohesive even when delivered by different developers. We feel strongly that the way a place works and the benefits it provides for the people that live there, are equally as important as the way it looks or the style in which it is built. While welcoming the introduction of national space standards for houses developed under Permitted Development rights, we are though hesitant around the idea of a rigid national design code and would like to discuss how a ‘model’ design code would work in practice. We also have concerns around widening permitted development rights for ‘popular and replicable’ forms of development that will enable ‘gentle densification’ or ‘redevelopment of existing residential buildings’ in Renewal Areas. We would welcome a clearer understanding of how standards for ‘popular and replicable’ will be determined. It is essential that this does not lead to a proliferation of low quality, identical developments, that do no respect local context, nor safeguard heritage and nature.
  5. There is a challenge around skills within local authorities, which may make delivering on aspects of the Government’s plans challenging. Currently many local authorities do not have the required architecture and urban design skills or resources, so additional long-term funding, as well as resourcing the work whilst skills gaps are filled, is imperative. We have welcomed, however, the recognition that planning, design and placemaking needs representation at senior level within local authorities. We support the idea of a Chief Officer for Design and Placemaking - but believe it is important to add heritage to the remit of their role.
  6. Finally, our view is that fostering high quality development is not just about beautiful buildings. Providing the gardens, parks and other green spaces we need around them, particularly in urban environments is crucially important. Delivering green infrastructure has long been a challenge for the planning system, and research commissioned by the National Trust and partners has shown that there is significant inequality in terms of access to green spaces across the country, with disadvantaged and Black and ethnic minority communities most affected by inadequate provision.[4] We’d like more specific plans put in place to deliver vital local green spaces, including consideration of how existing areas can be enhanced through the new system. For example, there could be a stronger focus and clear mechanism for planning obligations or the infrastructure levy to fund and deliver green infrastructure.

 

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

 

  1. The level of housing growth within communities is one of the most fundamental and contentious questions about future development in an area. We believe that the housing target in an area should be based on an assessment of housing need, environmental constraints and other factors, such as locational sustainability and the realistic prospects of delivery. One of our key concerns is that there must be adequate processes, resources and structures for public involvement, so that communities can have a say in housing development that is going to affect them.  
  2. In our view, the ability of an area to deliver on sustainable development objectives should be the key parameter for determining quantity and location of development. The National Trust would be concerned with an overly simplistic assessment of existing urban areas and their ability to accommodate and absorb further development. A single-purpose focus on housing ignores the benefits of holistic planning for the whole spectrum of economic, social and environmental needs.
  3. The White Paper proposes binding centrally-set housing targets in local plan-making. We are very concerned by the lack of transparency about how decisions would be reached about growth in individual areas under this system. We have significant concerns about the scope of environmental issues that would be considered when setting such binding targets and whether adequate robust environmental data exists to make this work at a national level.
  4. Local authority boundaries are often drawn so that large towns and cities are separated from their rural surroundings. It is not clear whether and how this would be considered when setting local housing targets nationally. 
  5.  Overall, neither environmental factors nor the sustainability of locations for growth can properly be considered without some idea of the form that the growth might take and specific locations in mind. It cannot be done effectively simply by manipulating numeric data or using spatial data in an abstract manner.  


Q.5 What is the best approach to ensure public engagement in the planning system? What role should modern technology and data play in this?

 

  1. Enabling people to engage with their local planning system is in our view absolutely critical to an effective and democratic planning system. We have already outlined our concern about the need for public engagement when setting the housing target for an area.
  2. We anticipate a fundamental challenge in the front-loading of democratic and local engagement as suggested in the White Paper. People respond to specific planning applications because they can understand the direct impact of specific, concrete proposals on things they value. Far fewer engage upstream where it is harder to visualise what a strategic plan will mean in practice. The proposed move to a more permissive system within the framework of upfront spatial allocations creates a significant risk that by the time a local community understands the impact of a specific proposal it will be too late to affect it in any meaningful way. We are therefore concerned that communities and individuals will not be prepared or fully equipped to engage in the new front-loaded system at the Local Plan stage which in many cases will remove key opportunities to comment on site specific proposals, which for many is when planning becomes ‘real’.
  3. To be successful, the proposals require a substantial culture shift and behavioural change in the attitudes and expectations of communities and individuals.  If this is not achieved in time, all opportunities for them to have their say will have passed. It is possible that this will lead to a further feeling from communities that development is ‘done to them’ and erode confidence in the planning system, rather than improve it. This is particularly concerning for the first round of new-style Local Plans, which will be in place for a substantial amount of time until community engagement is sought again. We think it is naïve to assume that communities will become enthused about planning at the Local Plan stage, and that later and more detailed opportunities to engage can be removed.
  4. To ensure that Local Plans do genuinely reach local communities and foster active engagement, a statement of the profile of people and groups the consultation has reached in replacement for one of the 'tests' of soundness could be considered.

What role should modern technology and data play in this?

 

  1. We support the Government’s broad aspirations of a ‘digital first’ approach to modernising the planning process and welcome the recognition that this will need to support both plan making and case management and decision making. However, there also needs to be recognition that people might struggle to visualise what the proposals mean in reality, particularly at the Local Plan making stage. The use of 3D technology could help people to fully engage with the masterplans and design codes that support the strategic allocations in Local Plans.
  2. While the overarching aspirations are welcome, Government needs to be really clear about what constitutes engagement in Local Plan preparation. We are concerned that a move to digital platforms might exclude specific groups and while we acknowledge that digital access continues to increase, there are still significant variations in confidence to safely use digital formats. The Office for National Statistics (ONS) 2019 research highlights that digital exclusion continues to be a challenge, with some 5.3 million adults (around 10% of the adult UK population) either without access to the internet or having not used it within the last 3 months.[5] To combat this, there should be an explicit commitment to retain non-digital ways to engage with and view Local Plans and development management information, and we would welcome continued innovation in this area.

Q.6 How can the planning system ensure adequate and reasonable protection for areas and buildings of environmental, historical, and architectural importance?

 

  1. The conservation of heritage assets, landscapes and nature, and the ability for people to access and enjoy these places are key concerns of the National Trust. At present there are specific designations and protective measures to protect certain buildings, sites, areas or landscapes of significance for nature and cultural heritage. These are complex and vary in the level of protection afforded based on significance/rarity/sensitivity ranging from international designations right through to local and undesignated assets. There are three key layers:
  1. The international and national designations are not derived from planning legislation but, like the local designations and undesignated features, they interact with and have a bearing on the decisions made through the planning system. 
  2. There are also significant numbers of assets which lack substantive specific protection - e.g. the majority of our nationally significant archaeological sites are not formally designated and rely on the effectiveness of the planning system to ensure that they are not impacted by development through site specific evaluation. Historic parks, gardens and battlefields also rely totally on protection through the planning system. As such, they are particularly vulnerable to damage or loss, as are unlisted and Grade II listed historic buildings, which do not feature on Historic England’s Heritage at Risk Register.
  3. In our view the protections offered to designated sites and areas are broadly robust in principle, but even for the areas of highest protection, where development is most limited, their effectiveness in practice and the outcomes for nature and heritage from planning decisions can be highly variable. There are over 5000 buildings on Historic England’s “Heritage at Risk” list, which includes (among other categories) assets at risk from inappropriate development. Undesignated sites rely only on the planning system and are extremely vulnerable to instances of poor decision making or where data, resource or expertise is insufficient.
  4. In recent years, while application numbers and other burdens on Local Planning Authorities (LPAs) have grown,[6] we have also seen a significant decline in the number of planning staff, falling 15% between 2006 and 2016.[7] Additional impacts have been felt due to the related reduction in local authority environmental expertise, between 2006 and 2018 a decline in conservation officers by 35% and archaeologists by 34%.[8] Research by ENDS has found that only 26% of local authorities in England have in house ecological expertise.[9] Cuts to key statutory consultees, including Natural England (which has seen a budget cut of over 44% in an 11- year period)[10] and Historic England (49% real-terms cut in funding between 2010/11 and 2019/20)[11] have also been made.
  5. The loss of key skills and experience that attract the trust of decision makers and enable confident decision making is also problematic. In our experience we’ve seen less consistency in planning decisions over time and have seen both a relaxing of restrictions in planning consents granted in some cases, and in others an unnecessarily rigid approach which can prevent reasonable and beneficial changes or developments from occurring. The collective impact is that the ability of the planning system and other protections (such as listing and scheduling of ancient monuments) to protect the historic and natural environment is significantly eroded.
  6. In terms of the Government’s proposed reforms, we welcome the commitment to protecting designated sites, but landscapes, nature and heritage will rarely fit neatly into ‘areas’. We need to go further than simply polish the conservation ‘crown jewels’. An approach for dealing with ‘everyday’ heritage and nature, close to where people live is needed. These assets add a rich dimension to place and must not be dealt with solely as a ‘constraint’. Nor in Protected Areas should they be conceived of as fixed, unchanging or without need of improvement. For example, a Greenpeace report in 2018 found that the condition of 47% of England’s SSSIs had not been monitored for six years.[12] Natural England records that just 38.6% of SSSI land is currently in Favourable condition. Investment and enhancement must therefore be encouraged, and we believe that Protected Areas could beneficially be reframed as ‘Areas for Protection and Enhancement’ in order to promote positive change.
  7. Success in securing high quality and sustainable development will be dependent on the front-loading of understanding about a site and on front-loading public engagement. We have particular concerns about how this will work in relation to important issues like heritage, archaeology and ecology. Most national strategic datasets need updating and investment, and in the new system this won’t be funded by developer’s site-specific assessments as it is now. We’ve called for the Government to invest of at least £150 million for Natural England’s Living England maps, to create a baseline “environmental census” of England’s Natural Capital and the condition of protected sites, and establish a new environmental information hub to create a new, open-data and digital platform for ecological data. Additional investment in Historic England’s digital data infrastructure would also allow them to make more of their datasets available to local authorities and the public. We also want to see a statutory duty placed on local authorities to maintain Historic Environment Records. Improving our data needs serious and long-term commitment in order to create resources that are fit for the purposes required by the proposed planning reforms.
  8. Even with proper investment, up-front data won’t be able to identify every asset – e.g. unrecorded archaeology or the unexpected discovery of important and endangered species. We would like to see a requirement to report on-site discoveries, and to take appropriate action should anything be found. Where there is risk or lack of clarity, sites in all areas should only be allocated dependent on future site-specific assessments being carried out.
  9. Finally, the planning system must work in tandem with other initiatives to solve the nature crisis and reduce carbon emissions, and we would like to see more from Government about how the proposals in the White Paper will support this. With the Environment Bill’s introduction of Biodiversity Net Gain and Local Nature Recovery Strategies to support the England-wide nature recovery network, the planning system should play a key role in delivering the Government’s ambitions in the 25 Year Environment Plan – not only protecting heritage and key habitat and wildlife, but actively contributing to their enhancement. However, we are concerned that there is little detail on how the White Paper proposals will do this or contribute towards tackling climate change.

Q.7 What changes, if any, are needed to the green belt?

 

  1. Green Belts around our towns and cities are an important planning tool which prevent urban sprawl by keeping land permanently undeveloped. This layer of protection for our countryside and the settings of historic towns is extremely valuable and should not be lost. We see the greater need for change being in the way that the distribution of housing growth is handled at a regional and sub-regional level. But we do think that Green Belts have the potential to deliver much more public benefit.
  2. We would like to see the quality of land improved for people and for nature, with more space for wildlife and better access for those living in nearby cities and towns. Given the ambition of the Government’s 25 Year Environment Plan, and the very real need for better access to green spaces and green infrastructure that we’ve seen so well illustrated by the coronavirus crisis this year, there could be a powerful role for Green Belt to play a key role in supporting both nature and the urban populations nearby – for example contributing to local nature recovery networks, and helping link up local green spaces and key habitat. Managed effectively, Green Belt land could also play an important role in helping the UK tackle climate change and reduce the risk of flooding in urban areas.  
  3. The genesis of Green Belts lay in a proposal by the Greater London Regional Planning Committee in 1935 for “a reserve supply of public open spaces and of recreational areas and to establish a green belt or girdle of open space" around London. The 1947 Town and Country Planning Act allowed local authorities to include proposals for Green Belt and in 1955, they were encouraged to do so by the Government.[13] The five purposes for Green Belt now set out in the NPPF are

1)      to check the unrestricted sprawl of large built-up areas

2)      to prevent neighbouring towns merging into one another

3)      to assist in safeguarding the countryside from encroachment

4)      to preserve the setting and special character of historic towns

5)      to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

These sit alongside a policy encouraging local authorities to plan positively to enhance the beneficial use of green belts.

  1. The Planning White Paper did not propose specific changes to Green Belt policy, but in the context of “radical” reform to the planning system there is an opportunity to consider how the Green Belt can operate strategically within a spatial framework to support the needs of urban communities and future generations. For example, it may be timely to go back to the original premise of ‘public open spaces and recreational areas’ and consider what the five purposes of Green Belt should be today and whether in fact the purposes and achievement of beneficial use could be framed more strongly.
  2. That said, in order to serve its purpose of protecting the countryside and preventing urban sprawl, we believe the fundamentals of protections of land in Green Belt enshrined at its inception in the 1930’s should be maintained. Development in the Green Belt must continue to be carefully managed. We acknowledge that there are some limited circumstances where development is acceptable, or where very special circumstances are clearly demonstrated which might outweigh harm to the Green Belt. But any changes to Green Belt policy or to individual Green Belt boundaries must be fully evidenced and justified and formally decided through the Local Plan process, with opportunities for public engagement. Any development must be delivered in a sustainable and strategic way. 

Q. 8 What progress has been made since the Committee’s 2018 report on capturing land value and how might the proposals improve outcomes?

 

  1. A relatively short length of time that has elapsed since the 2018 report and the ongoing exceptional circumstances that continue to create uncertainty and instability mean that the National Trust isn’t able to provide specific evidence relating to how things have improved, or comment on the extent of any such improvements since the Committee’s 2018 report. 
  2. The report outlines measures for making greater use of CPO powers and simplifying the process. Whilst we understand the driver to do so, surveyors may find the proposition of not obtaining development value and just base value being paid for the land an uncomfortable scenario. However, we recognise that CPO powers can be useful in trying to deliver large scale sites with multiple landowners as it does prevent ransoming occurring. As long as there are safeguards built in and the CPO reforms remain accountable and locally determined the prospects of improving outcomes would be supported, particularly if the reforms lead to better opportunities for infrastructure monies being available and more funds for green space and infrastructure.
  3. One of the challenges is that development land values fluctuate hugely across the country and depending on the scale of the scheme, the deals that are done, the timings, the developers and people involved and the infrastructure needed to release the scheme etc. Most of our land is held as inalienable land so it has no land value in the normal sense and where we do have investment land it tends to be small in scale.
  4. At this end of the scale viability is a real issue and the thresholds at which land value capture could be triggered could have a serious impact on the Trust. However, we do not have any detail currently on how the new system would work and this is the key point as it will all depend on the detail which is worked through when Government proposals are set out. As it stands, Committee’s proposals for ‘Improving existing mechanisms’ section seems to be the only element taken forward in any meaningful way with the proposed simplification of CIL/S106 in the planning White Paper.
  5. We believe the following would be worth further consideration:

1)      Formation of a multi-party, public, third and private sector group to push forward the other items – including a detailed review at alternative land value capture methods that better reflect externalisation and internalisation of benefits and disbenefits for people and the environment.

2)      An improved join up between any value capture proposition and Red and Green books so that when projects go to the Treasury for funding assessment the Benefit Cost Ratio is captured accurately

3)      Better join up between land value capture legislation and policy with policy in other departments – the Environment Bill being a classic example.

 

 

November 2020

 


[1] https://www.local.gov.uk/housing-backlog-more-million-homes-planning-permission-not-yet-built

[2] https://www.local.gov.uk/lga-responds-latest-housing-supply-figures

[3] Building More Homes, report of the House of Lords Economic Affairs Select Committee, 2016, HL Paper 20

[4] https://www.nationaltrust.org.uk/features/new-research-shows-the-need-for-urban-green-space

[5]  https://www.ons.gov.uk/peoplepopulationandcommunity/householdcharacteristics/homeinternetandsocialmediausage/articles/exploringtheuksdigitaldivide/2019-03-04

[6] http://ecab.planningportal.co.uk/Uploads/Planning_Portal_Market_Insight_Report_September2020.pdf

[7] NAO Planning for New Homes Feb 2019 https://www.nao.org.uk/report/planning-for-new-homes/

[8] https://historicengland.org.uk/images-books/publications/tenth-report-la-staff-resources/

[9] https://www.endsreport.com/article/1585763/capacity-crunch-councils-expertise-deliver-biodiversity-goals

[10] Supplementary written evidence from Natural England (NER0092). Budget figure as at May 2017

[11] Historic England Three Year Corporate Plan, 2018-21, https://historicengland.org.uk/imagesbooks/publications/he-corp-plan-2018-21/

[12] https://unearthed.greenpeace.org/2018/09/07/half-england-sssi-sites-not-monitored/

[13] Written answer by the Rt Hon Duncan Sandys MP, Minister of Housing and Local Government https://api.parliament.uk/historic-hansard/written-answers/1955/apr/26/green-belts#S5CV0540P0_19550426_CWA_16