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Planning for the Future Consultation, Planning Directorate
Ministry of Housing, Communities and Local Government
3rd Floor, South East Fry Building
2 Marsham Street
27 October 2020
Response to Planning for the Future White Paper
Deadline for Responses: 23:45 on 29 October 2020
The Parish Council met on 22 October 2020 and considered all the questions raised by the Government’s White Paper: Planning for the Future. Please find below our responses to the consultation. We have grouped our comments together under the five main proposals rather than attempting to answer each question individually.
Overall, the view of Hurstpierpoint and Sayers Common Parish Council is that the Paper does not present a balanced view as to why the current system is deemed unfit for purpose and as a result does not offer solutions which will provide the desired outcomes. This point is developed in more detail in the following paragraphs.
- Streamlining the Planning Process
The current system is democratic, based on local consultation and the advertising of applications. The Parish Council is currently a statutory consultee and offers considered and relevant planning advice based on policies contained in a made Neighbourhood Plan which received a 94% approval from residents who voted on it. Advice on applications is formulated by locally elected councillors with current knowledge of local demographic and environmental conditions which provide valuable context to the Planning Authority when decisions are made.
‘Streamlining the process’ under the proposals in this paper will, by reducing input from parish councils, be significantly detrimental to the quality of decisions without adding materially to the speed of decision making. The implication in the White Paper is that Parish Councils inhibit developers from building houses in the required numbers but, in the case of this Parish at least, this is demonstrably untrue. The Neighbourhood Plan for this Parish has provided for the building of over 300 new houses with at least 30% of them being in the affordable housing categories as required by the plan. This number has been more than sufficient to meet the unmet demand locally in all market categories except social housing the provision of which is beyond the remit of a Parish Council alone. The national standardisation of Local Plans would weaken the role of the Neighbourhood Plans which would lose their important legal status and become little more than design guides.
In addition we believe the White Paper makes explicit criticism of Local Planning Authorities claiming that they are responsible for inhibiting the construction of housing at the required level because they apply planning policies and processes which have been ‘in place since 1947’. This is manifestly unfair and untrue. Current planning policies and procedures have been updated and modified to meet demand countless times since 1947 and the current system operating with the National Planning Policy Framework of March 2012 (updated February 2019) bears absolutely no comparison to the process put in place after WW2.
Most relevantly the NPPF is based on the principle of a ‘presumption in favour of development’. The White Paper misses completely the fact that local authorities do not build houses – developers do. The paper fails to examine the reasons that application of this principle in the planning process over the last 8 years has failed to produce the number of new houses to meet the demand nationally. For example there is no analysis in the Paper of the practice by developers of ‘landbanking’ which entails not building houses for which permission has been granted, in some cases for many years, in order to allow land values and property prices to rise and profits to be increased.
There is therefore no evidence that streamlining the process in the ways described in this paper would increase the rate at which new houses are supplied to the market and on the contrary there is evidence that removing the input and influence of Neighbourhood Plans and Local Planning Authorities would significantly reduce the quality of planning decisions.
- Digital First Approach
In the view of this Council the White Paper does not offer a new approach to making good quality planning decisions. Rather, the Paper offers a series of questions many of which are related to debating the use of technology in the process rather than focusing on the key issues. The use of technology is not, in this Council’s view, a matter which requires a policy decision but should simply be an evolving aspect of maintaining an efficient and effective process. A White Paper which was genuinely focussed on improving the supply of housing in England should be giving far more emphasis to issues such as creating sustainable communities and providing affordable and social housing in sufficient numbers, especially rented affordable housing.
- New Focus on Design and Sustainability
The White Paper appears to be based on the premise that, given freedom from the alleged constraints of local democracy, developers will produce well designed housing in sustainable communities comprising the right balance of housing to meet demand at all levels of the market. In fact there is ample evidence in Mid Sussex that the opposite is true and that without the, albeit limited, influence of Local Authorities in the planning process developers will build executive houses in areas of natural beauty because they are the homes which can be sold at the greatest profit. Evidence for this assertion can be found in the number of affordable houses for which planning permission has been granted in the last five years in Mid Sussex (800) and how many have actually been delivered by the developers concerned (95). This Council believes that, contrary to the White Paper’s claims well designed and sustainable communities will only be created by planning authorities and policies which are not driven by the need to maximise profits.
- Infrastructure Delivery
There has been ample evidence in the development of a Neighbourhood Plan by this Parish and in the formation of the District Plan by Mid Sussex District Council that reliance of housing developers to deliver the infrastructure needed to support the numbers of new homes required in England is doomed to fail. The Burgess Hill Northern Arc development is a case in point. The building of these much needed houses in an area otherwise suitable for major development was held for many years because the consortium of developers bidding for construction of houses could not agree to contribute to the necessary development of roads and cycleways, schools, surgeries, shops and services to support the development of housing. It has taken the direct intervention and purchase of the whole development by Homes England finally to begin the development with the right level of top down holistic planning.
It is perhaps relevant that the development was also delayed by the inability of developers to agree on how the construction of affordable as opposed to executive housing would be apportioned between them.
- Land Availability and Town Centre Renewal
This Council is adamantly opposed to the approach in the White Paper that appears to create generic Growth or Renewal zones without input from local authorities and other relevant local interest groups. The Government’s own NPPF mentioned above is clear on the importance of maintaining distinct communities with clear local identities and preserving the spaces between them to prevent their coalescence into large amorphous areas of housing or industry. The Paper’s apparent intention to remove local input to the rate of growth and shape of communities will, we believe, lead to the loss of identity of many historic communities and areas of natural beauty. The methods proposed in the White Paper for determining the location and numbers of new houses by a combination of central government and developers will, we believe, lead to large areas of development in areas of current high demand (i.e. South East England) and will not contribute in any way to the ‘levelling up’ between the North and South of the country that was such a major part of the Government’s manifesto in December 2019.
This Council is also concerned that the issue of ‘brownfield sites’ which are available and could supply land to meet much of the current demand for housing without destruction of the natural environment is not addressed in the White Paper. This Council is aware that the most significant factor in brownfield sites not being attractive to developers is the high cost of clearing the sites for development relative to greenfield sites. This Council believes that this is the reason that the White Paper does not contain a proposal to mandate the use of brownfield sites as a priority for a new planning process. Clearly these sites would provide a major contribution to improving land availability, but they are omitted as they would also be detrimental to the profitability of development.
Clerk to the Council
c.c. Andrew Griffith MP, Councillor Joy Dennis, West Sussex County Council