Written evidence from the Planning Officers Society
Summary of main points
• We foresee a range of difficulties for individual authorities in setting housing
figures that: win the support of local communities while also complying with
Government policy; deal satisfactorily with the question of migration and
respond to the Framework’s expectations for affordable housing delivery;
• Existing Green Belt policy is restated with only detailed changes. This
represents a lost opportunity to revisit and refresh this sixty-year old policy in
the light of the changed world in which it now operates;
• the new regime is based on a definition of “sustainability” that seems very
strongly biased towards economic considerations. We fear the question “what
is sustainable?” could become a major debating point and an obstacle to
progress. We propose an approach that uses localism to reduce uncertainty
on the matter;
• the Government’s mixed message, about localism versus centrally-driven
policy objectives, is perpetuated in this document, with little or no
acknowledgement of the importance of localism as an element of national
planning policy;
• the duty of authorities to cooperate on strategic matters needs further
strengthening, if joint working at a local level is to be an effective replacement
for the loss of the strategic tier of planning. The Society will be coming
forward with detailed proposals;
Does the NPPF give sufficient guidance?
1. The Society acknowledges the heroic efforts that have been made to
condense national policy, but the removal of over a thousand pages of
guidance, plus the disappearance of an entire regional tier of policy, will
inevitably leave gaps that will need filling (for example, by good practice
guidance). The Government has indicated that it is not generally in the
business of producing such guidance, but the Society (no doubt along with
other bodies such as the RTPI and the TCPA) is willing to play an active part
in its development, where most needed.
2. In this context, the role of the Framework should, at the very least, be: (a) to
acknowledge (as it does in the accompanying impact assessment) that
organisations like ours are a legitimate source of supplementary guidance,
where needed and (b) to lay down broad guidelines for its preparation and
validation. With regard to these, we believe it should be: cross-sector,
prepared with the collaboration of the key agencies and representative
bodies; should be subject to consultation with the wider planning community;
and that there should be agreed methods for self-accreditation and regular
review.
3. In its response to the Framework consultation the Society has identified a
number of areas where complementary good practice guidance would be
appropriate. Once we have seen the final form of the Framework, we and
other key stakeholders will be in a better position to identify where gaps exist,
what the priorities are, and to agree a process and a demarcation of labour
for filling them.
4. Housing requirements: The housing requirements section (28) appears to
be internally contradictory. On the one hand it talks of the plan (though the
Strategic Housing Market Assessment) catering for the needs of the “local needs arising from migration. It is of particular concern to us to know how
plans are supposed to have regard to migration in the absence of any
strategic context for it. The only basis we can see for doing it is by assuming
a perpetuation of past trends in migration, which would not provide a basis for
promoting new directions of growth where these are needed. Nor is it in our
view realistic to expect groups of local authorities, even acting in good faith
on the duty to cooperate, to come up with major proposals on the scale of
new or expanded towns, if these were needed. The paragraph also alternates
between meeting housing need and housing demand. We would strongly
oppose any model based on meeting demand. In large parts of the South
East (and elsewhere) local demand far exceeds anything that, with the best
will in the world, could realistically be delivered.
5. The Framework generally needs to be clearer about what it means by
meeting the full housing requirement (109) since, with the revocation of
regional strategies, each planning authority will have to establish the
requirement for itself. The first of the bottom four bullet points on page 30
talks of meeting the full requirements for market and affordable housing. In
many parts of the south of England, even if the authority’s full housing
allocation could be delivered as affordable, it would not be possible to meet
forecast demand for such accommodation. For many such authorities, fully
meeting that demand would be economically undeliverable and
environmentally unacceptable. It may be better for the Framework to speak of
meeting affordable housing need as being what authorities should aspire to,
subject to local circumstances.
6. The Green Belt policy (133 – 147) appears simply to perpetuate existing
policy. As originally conceived over half a century ago, Green Belt was only
half of a policy, the other half of which was the series of new and expanded
towns that were to be developed outside of the Green Belt to relieve
development pressure inside it. Now that those towns have been largely built
out, it seems an appropriate time to look at the continued operation of the
remaining half of the policy. We have for years been promised a review of
that policy, and this may be seen as a lost opportunity (albeit recognising the
difficult issues such a review might raise). This should not be taken as the
Society advocating a wholesale retreat from Green Belt, but rather as an
opportunity to refresh the rationale for and operation of Green Belt, in a
situation where circumstances are markedly different from those in place
when it was originally introduced.
Is the definition of sustainable development appropriate and is the
presumption in favour workable?
7. Whilst nobody would (presumably) object to the principle of sustainable
development, we are concerned that there will be many different
interpretations of what constitutes sustainability, and that this will prove to be
a fruitful source of delay and confusion at appeals and other planning
examinations. Few developments will score equally high (or low) against all
three of the sustainability criteria set out in paragraph 10 of the Framework,
and the relative weighting that one attaches to these could lead to very
differing views on the sustainability of a particular scheme. It should be selfevident
that this weighting will be different in a National Park, compared to,
say, an inner city regeneration area and this leads us to the view that there
should be scope for some local nuancing of the national definition. In this,
local authorities would be able to flesh out the national policy in the light of
local circumstances and thus at least limit the scope for repeatedly debating
different interpretations. Note that this is not intended to involve the
introduction of a plethora of local policies, but merely to show how national
policy could be applied flexibly at a local level. The requirement to accompany
a plan with a sustainability appraisal already allows an authority some scope
to do this, but it would be helpful if the Framework at least acknowledged this
role for the local authority, and that it should appear in the local plan itself. Not
least, such an approach would be in accord with the Government’s policy of
localism. As the Framework stands, references to sustainability in it tend only
to relate to its economic dimension, which seems some way removed from
the more balanced Brundtland Commission definition, from which it is derived.
8. At the same time, the framework might usefully make clearer the alignment
between the environmental objectives of sustainability and its economic
importance. As the foreword to the Government’s own Carbon Plan points
out: This Carbon Plan sets out a vision of a changed Britain, powered by
cleaner energy used more efficiently in our homes and businesses, with more
secure energy supplies and more stable energy prices, and benefitting from
the jobs and growth that a low-carbon economy will bring. Making this link
more explicit would give greater coherence to the rationale of the Framework.
This same point might also usefully be reinforced in the section on planning
for prosperity.
Are the core planning principles clear and appropriate?
9. Clear yes, appropriate no. There is an underlying tension between the
Government’s national aspirations for the planning system (paragraph 19)
and the principle of localism. Whilst we understand that this is a national
policy framework, nowhere in these principles does there seem to be even an
acknowledgement of any role for local discretion. The core principles should
recognise the importance of localism to planning and, so far as is necessary,
clarify its relationship to national policy objectives. The underlying assumption
seems to be that, once the national policy objectives have been put into
place, communities will fall in behind them and be happy to take whatever
residual decisions are needed to secure their implementation, in the name of
localism. The Society’s extensive contacts with local communities throughout
the country lead us to believe that this will by no means always be the case.
The Government has been critical of the imposition of a regional growth
agenda on local communities, and the resentment that this has caused. We
are not convinced that what the Government intends to be an even highergrowth
agenda, imposed nationally rather than regionally, will be any more
easily accepted, even allowing for the financial and other incentives they
intend to offer communities to accept growth. Opinion surveys have shown
that there is a much greater prospect of achieving consensus on the general
principle of providing more housing than is ever possible in getting agreement
on a specific proposal that it should be provided in a particular location.
Is the relationship between the Framework and other national policy
sufficiently clear?
10. Nowhere in the Framework does there appear to be any acknowledgement
that planning is about more than the use of land – that it is spatial (that is,
having a wider concern for how places work). Perhaps because of this,
linkages between planning and other areas of related policy tend to be poorly
developed or absent from the Framework.
Do the NPPF and the “duty to cooperate” give a sufficient basis for strategic
planning?
11. No. Whilst we welcome the strengthening of the duty to cooperate that has
emerged during the passage of the Localism Bill, we do not believe it has
gone far enough to address adequately the gaps left by the abolition of
regional strategy (44). We are therefore seeking a duty for local authorities to
prepare Strategic Infrastructure Assessments (SIAs). An SIA would be a
simple, transparent process to ensure that strategic issues such as
infrastructure, economic development, housing and the environment are
managed in a co-ordinated way by local authorities and with partners, and
ensure that these are properly addressed through the statutory planning
system. Whilst this measure was not incorporated into the Localism Bill itself,
it may be more appropriately introduced through policy. Lest they be seen as
an alternative solution to the problem, our contacts with Local Enterprise
Partnerships up and down the country lead us to doubt whether most of them
will have the resources, the expertise or the statutory powers to engage in
strategic planning (in relation to infrastructure or generally) in any meaningful
way
12. Collaboration and conflict resolution: The sections of the Framework
dealing with planning strategically and collaborating (45-46) seems to
presuppose that there is always a consensus waiting to be arrived at. The
reality is that some (possibly many) strategic issues will not be readily
resolved. The Framework should at least acknowledge this, and place a duty
on authorities to take all reasonable steps to resolve any impasses thrown up
by strategic issues. It (or supplementary good practice guidance) might also
consider what is to be done in the event of such an impasse.
Are the policies in the NPPF sufficiently evidence-based?
13. One of the biggest untested assumptions in the Framework is referred to in
our paragraph 8, and relates to the willingness of communities to deliver the
amounts of growth the government wants to see, incentivised by Community
Infrastructure Levy, the New Homes Bonus and the new freedoms promised
by localism. We have seen plenty of examples of communities which are
willing to spend considerable sums of their own money to prevent
development, and we are not necessarily convinced that the new incentives
will lead to a sudden dramatic reversal of public opinion.
14. We also have a more general concern, which seems to underlie not just this
document, but much of the Government’s thinking on planning. This is their
perception of the impact that planning has, which we do not believe is
supported by any serious body of evidence. Whilst you would expect the
Society to regard the planning system as important, it is possible to overemphasise
its impact (and, in particular, to over-state any negative effects it
is claimed to have on the economy). A Parliamentary Select Committee was
set up in 2003, in response to claims by the CBI during scrutiny of the earlier
planning green paper, that the planning system was a major impediment to
business. (The CBI’s claims, made in oral evidence, were found to be
unsubstantiated, and the committee looking at the planning green paper
described them as based on “anecdote and prejudice.”) The Select
Committee’s conclusion was as follows:
“Claims that planning damages the nation’s competitiveness seem to have
been made without evidence. The evidence that we have received suggests
that businesses generally support the planning system and seek a number of
best local authorities already run their planning departments in proactive,
responsive ways and if the resources are put into place, such approaches
can be adopted by others.”
15. As part of that Select Committee’s work, they commissioned consultants
Roger Tym and partners to undertake a literature review. This concluded that
“There is no evidence that planning is a significant explanatory factor for the
UK’s low productivity compared to its main competitors.” That this is still the
case is supported by the fact that 86% of all planning applications decided in
2010/11 were approved, the great majority of them within the statutory time
periods. The issue of applications delayed for over a year, to which the
Government has recently devoted a good deal of attention, relates to a
fraction of 1% of all applications, and the reasons for those delays by no
means always lie at the door of the local planning authority. Whilst we are not
complacent about these figures, and are always keen to explore ways of
further improving them, we do not believe that they show a system in crisis,
fundamentally impeding national recovery, as is sometimes portrayed.
The Planning Officers Society
8 September 2011
Decisions, Decisions, Decisions 