Written evidence submitted by Civic Voice [NPP 38]

  1. Civic Voice is the national charity for the civic movement. We work to make the places where everyone lives more attractive, enjoyable and distinctive. We promote civic pride. We set up in 2010 and will be celebrating our 6th anniversary in April 2016. Since we set up, we have been joined by hundreds of volunteer-led, community based civic societies with over 76,000 individual members. Civic societies exist in over 60% of local authority areas.
  2. This response has been informed by the experiences of our Expert Panel, consisting of a collection of individuals from across England. The Expert Panel consists of retired planning inspectors, senior planning officers and heritage and conservation experts. All are members of a civic society that is a member of Civic Voice.
  3. We welcome the opportunity to submit evidence to the Department’s select committee inquiry.

The role of planning

  1. The National Planning Policy Framework (NPPF) has a central role to play at the heart of the planning decisions which affect the quality of our cities, towns and villages.
  2. Civic Voice believes the planning system has untapped potential to engage people in becoming more actively involved in their community as well as positively managing development for the widest public good. We support the principles behind neighbourhood planning and believe this has been a success of the current Government in its devolution and Localism agenda. The planning system combines vision with necessary regulation and already plays a critical role in protecting and improving the quality and prosperity of places.  We believe its role needs to be strengthened and supported through improved opportunities for public engagement. The planning system also needs effective resources, particularly at local authority level, commensurate with the important role it plays.

Planning as the solution not the problem

  1. Planning is a means for informed discussion about the kind of society we want to live in and the places we want to inhabit. Civic Voice supports a positive plan-led system, which promotes sustainable development in its widest sense; that which balances environmental, social and economic considerations equally.
  2. The value of effective spatial planning in the public interest is that planning also needs a strong defence against vested interests who seek to weaken safeguards or promote exceptions to get around the system. Civic Voice in its manifesto Localism for Real has called for strengthened provisions in the NPPF that call for community participation on major planning proposals and in the production of local plans. The requirement should be that designs for major developments have been produced with the participation of local people rather than simply that they have been consulted.
  3. A clear and effective NPPF which promotes sustainable development, balancing economic, social and environmental issues, will only be achieved if local planning authorities have sufficient resources to produce timely plans with quality of place at their heart.
  4. Specifically in terms of the Department’s consultation on proposed changes to national planning policy (Dec 2015) we urge the Committee to consider the following issues as part of its inquiry:

Unintended consequences of the presumption in favour of brownfield land

  1. Civic Voice supports the principle of developing suitable brownfield (previously developed land) before greenfield sites. However, we are concerned that the proposal, which would in effect, create a presumption in favour of brownfield land is too crude a policy tool and could result in unintended consequences. This is particularly concerning given the link to the proposed statutory register of brownfield land suitable for housing development and ‘permission in principle’ proposed through the Housing and Planning Bill. 
  2. To us, brownfield land means urban infill sites, not previously developed land in rural areas, where access to services and public transport is often limited. There are numerous examples of brownfield urban infill sites up and down the country, which are in much need of investment and regeneration. National planning policy should quite rightly prioritise such sites for redevelopment given the clear benefits to our towns and cities, and Civic Voice would welcome strengthening national policy to encourage this. We are concerned, however, that the proposed presumption in favour could open up large amounts of land to solely housing development, not necessarily within areas requiring regeneration or in sustainable locations.

Implications of the housing delivery test 

  1. It must be accepted by Government that there are other factors which have led to historic under delivery of housing. The principal one is the problem of unimplemented planning permissions. At present there is no requirement to implement permissions. Unimplemented permissions do not deliver houses.
  2. Civic Voice objects to the proposed approach to require those local planning authorities, in areas where ‘under-delivery’ is identified, to identify more sites for housing. We are concerned that the effect of this would be to allow developers to continue accumulating permissions with still no guarantee of delivery and significantly more land will be allocated for housing than is required. This proposal would further undermine the community’s influence over the location of new housing without imposing any additional pressure on developers to build houses.

 

Loss of the strategic approach to Green Belt

  1. The consultation puts forward several proposals to encourage housing delivery in particular, starter homes, on sites within the Green Belt i.e. widening the rural exception site policy, encouraging redevelopment of brownfield land in the Green Belt, supporting new settlements. Civic Voice is concerned that the cumulative effect of the proposals would be to create a fundamental change to and weakening of Green Belt policy. 
  2. It is important to remember the five purposes of the Green Belt, as set out in the NPPF and the well-established test for releasing Green Belt land for development; ‘in exceptional circumstances’. This is a high bar and the current NPPF gives strong protection to Green Belt. We await the detailed policy wording of the proposed changes but we are very concerned that the current proposals will allow ‘nibbling away’ and erosion of established Green Belt and inevitable resultant pressure to amend Green Belt boundaries.     

Positive spatial planning

  1. Looking forward, we seek an approach that recognises the need for a stronger role for planning in securing a pattern and quality of development which supports economic, social and environmental progress and provides certainty for investment.  This will need to be based on an approach which delivers “smart growth” and in particular:
  2. Civic Voice would be happy to expand on any of the points above and provide oral evidence to the select committee.

 

February 2016