The new Green Paper on planning is an opportunity to improve the process

November’s Accelerated Planning Green Paper will be an opportunity to promote improvements that would benefit all involved in the planning system.

Duncan Neish, Policy Officer, National Housing Federation

Duncan Neish, Policy Officer, National Housing Federation

9 October 2019

Things never stay static for long in the world of planning – that may raise an eyebrow if you’ve had an application delayed recently. But planning has featured prominently in the early announcements of new ministers.

Next month’s Accelerated Planning Green Paper should bring more substance and an opportunity to pitch proposals for improvement – not least for resources to operate the system effectively. The Federation will make that argument, along with several others.

You can help by sharing your planning experience – whether as an applicant or in acquiring Section 106 homes.

Background

What’s planning for? It’s about promoting, directing and controlling land use in pursuit of environmentally, socially and economically sustainable development.

National policy and guidance provides a framework for local planning authorities’ (LPAs) plans and policies. These provide a basis against which to assess applications for permission. Applicants should be clear on what’s sought locally, and their applications processed in timely, predictable fashion.

Simple in theory – not always in practice.

Many LPAs are very resource-constrained and lacking effective plans and policies. There may be insufficient development land in suitable locations. Applications processes and decisions can be slow and unpredictable. Affordable housing requirements may be uncertain or inconsistently applied.

Planning spans the Federation’s priorities of delivery, quality and trust. But members regularly find it a barrier to delivering more affordable homes more quickly. Underlying this frustration is chronic under-resourcing: spending on planning has fallen by almost half. A fifth of posts have gone and recruitment and retention are problematic (recent Planning Advisory Service research found particular issues with senior planners).

Better resourcing is vital – but what else needs to change? We’ve engaged members – particularly the Delivering Great Homes group – to better understand their perspective. And we’ve also worked with the Royal Town Planning Institute, Local Government Association and Planning Officers Society on how we might collaborate to secure improvements.

Federation proposals

Firstly, to improve the application process, we’d like to see:

  • more meaningful pre-application engagement
  • robust (not necessarily quicker) timescales for processing and determination, including associated comments and consents (e.g. highways, legal)
  • early discussion of likely conditions, including timescales
  • regular meetings with case officers, including specialists
  • greater use of standard templates for legal and other agreements and clauses.

Some of these can be realised through planning performance agreements – although use and experience of these is variable. There is willingness to pay more for a better experience, however.

More fundamentally, there may be a case for incorporating lessons from the Nationally Significant Infrastructure Projects regime. This could include frontloading community consultation and options generation and combining multiple consents into one application.

Application aggravation is often symptomatic of insufficiently robust local policy. Resources have been diverted to statutory development management – yet pro-active policymaking is literally investment in our future. Continued under-investment is a false economy, favouring only landowners and speculators unconcerned with building soon, quickly, or to a high standard.

Making plans means making decisions, sometimes difficult ones, and not every LPA will. So we’d like to see:

  • Up-to-date local plans made mandatory, with effective central intervention where required.
  • Strong national guidance on affordable housing requirements. This should provide a meaningful ‘backstop’ for planning decisions, including consideration of viability arguments. Recent NPPF and NPPG changes were welcome – but need to be translated into robust local targets.
  • Stronger, enforced standards for good design. Recent developments on design guidance offer hope here.
  • National policy and guidance to require good practice in the transfer of affordable housing associations. This should cover provider selection, engagement, quality, price, and when contributions other than completed homes (e.g. commuted sums or land) are appropriate.

I should note that some LPAs have good policy frameworks and use these to deliver high quality affordable homes in well-designed places. They show what’s possible – and should be the norm.

Finally, we’re interested in a deeper debate about how affordable housing is secured through planning. Experience of Section 106 is mixed. It takes advantage of an essential mechanism, offers local flexibility and has proven durable. Conversely, it’s complex and open to ‘gaming’. The Green Paper could consider simpler, sustainable and more effective mechanisms. Network Homes have been giving this some serious thought.

How we’re taking our ideas forward

We’re ready to share our ideas with a wider audience. We’re in contact with MHCLG, and recently met their Chief Planner. We’ll engage other official contacts, including HM Treasury, and input to the Green Paper. And we’ll continue to work with partners – ideally so our ideas become their ideas, increasing the chances of them being heard and adopted by the Government.

We’re keen to know how members experience local planning, including where things work well. If you’d like to know more, or have a story to tell, please contact me.

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