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In March of this year the government promised legislation to improve the supply of new homes, including legislation on building safety, rental reform, social housing – and an update to the planning system.
Following this, a government White Paper Planning for the Future proposed very significant changes to the planning process for public consultation which closed last week.
At present, LBHF planning applications are assessed against the development policies in the LBHF Local Plan, in the London Plan, and in the government NPPF (National Planning Policy Framework). The White Paper proposes a new approach: a new form of Local Plan, replacing the current format of more abstract policy guidance, by a format with a prescriptive system of development rules and a design code. The Local Plan would also include borough zone plans, which would identify three categories of development:
In Growth and Renewal areas, proposals which are compliant with the Local Plan in height, use-type etc, and compliant with the government NPPF rules, would be effectively guaranteed an automatic outline planning consent, providing a level of certainty in site purchase values. At the next stage, a full planning application, with detailed proposals, would be granted consent if the proposals comply with the more detailed rules and design codes of the Local Plan.
Public consultation in the planning process would be limited to the stage when the new Local Plan is put together by the local authority: community involvement would be excluded from full planning application stage, because (it is argued) the application would be assessed against rules which have already been agreed through public consultation.
The intention is to establish a clear set of planning rules, which are in line with government policy, and have been agreed through community consultation; armed with these certainties applications would avoid the ambiguities of policy interpretation and community objection which (it is said) can delay the full planning application stage.
To illustrate examples of acceptable design and styling, and to provide a basis of resolution of design disagreements, Design Codes would form part of the Local Plan, and would be reviewed through public consultation when the new Local Plan is being put together. Design codes would be coordinated with the government’s National Design Guide, itself heavily influenced by the CreateStreets campaign and to the emerging National Model Design Code. To help the process, a chief officer for design and place-making would be appointed within each local authority.
Besides the changes to the planning procedures, the White Paper addresses a wide range of further planning-related issues, including :
We support the ambition to simplify the planning process, and clear the path for faster house building. Reducing the submission requirements would be welcome to us all – it is not unusual for larger development applications to include up to 500 documents. However, the planning process provides a vital control on the quality of the built environment, and should not be compromised in an effort to remove delays – delays which are partly inevitable in applying standard requirements to the wide variety of building types and site contexts involved.
Whilst the planning process is often cited as cause of housing shortages, the Local Government Association reports that of over 2.5 million housing units granted consent since 2009, at least 1 million have not been completed. Market housing proceeds on the basis of financial viability, and rarely starts without a rising market.
Planning for the Future is an articulate and well presented document – of over eighty pages. The comments described above, together with a wide range of more detailed points, were included in the Hammersmith Society response to the White Paper. Of the numerous issues we raised, our overriding concern is the denial of public consultation at full planning application stage. This is unacceptable: effective public consultation is essential both at Local Plan stage and early in the individual application stage, and provides an important part of community involvement and a foundation for community pride.
The White Paper has generated a significant public response. The submission by the London Forum of which we are member, offers an invaluable detailed analysis and response to the proposals.
We should also mention here that the Government ran a somewhat similar consultation, confusingly named Changes to the current planning system only a month earlier, covering subjects such as changes to the standard method for assessing local housing need, temporarily lifting the small sites threshold below which developers do not need to contribute to affordable housing, and extending the current Permission in Principle to major development.
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