As we’ve explained through this blog in recent weeks, the National Trust is becoming increasingly concerned about the piecemeal, rushed and confusing way in which the Government is making changes to the planning system. Here we discuss our response to two recent Government consultations – on the findings of the Local Plans Expert Group and on the Rural Planning Review.
Since the election it has introduced a major set of reforms to the planning system through the Housing and Planning Bill and significant revisions to the National Planning Policy Framework. Now the Government is now considering a further set of changes to the Local Plan making process, and has also asked for further views on relaxing planning in rural areas.
Last year Ministers set up a Local Plans Expert Group (LPEG), including private and public sector planners, councillors, politicians and developers (but no environmentalists) to make recommendations on how to make the local plan making process ‘more efficient and effective’.
The Expert Group made its recommendations alongside the Government’s March Budget, and yesterday a Government consultation on the Group’s findings closed. The National Trust responded to that consultation – you can read our response to the LPEG report in full here: Local Plans Expert Group – National Trust response – 16 April 2016
What follows is a short summary of our response.
The importance of local plans
We welcome the fundamental assumption behind this report, which is that the local plan-led system is the best way to guide good development to the right places, meeting long term needs. John Rhodes – the Chair of LPEG – made this explicit at the launch event for this report, and we think the Government should re-affirm its commitment to the plan-led approach and the principles of sustainable development in any future policy statements and legislation.
There are many points in the report that the Trust support and agree with. Many of the reforms proposed will help to reduce the conflict in the system and reduce some of the administrative and regulatory burden that is restricting plan preparation.
However we have a number of significant concerns with the recommendations taken as a whole. In summary, these are:
- The report promotes a much reduced, simplified, and formulaic plan preparation process, with an emphatic emphasis on housing growth. We are concerned this could reduce the scope of plans to be an expression of local distinctiveness and to plan positively in other areas, for instance biodiversity, adapting to coastal change, flooding resilience, landscape and heritage
- The report suggests Assessments of Environmental Capacity should in future be a key part of local plan-making. This could be a positive proposal, if it is done well. However, there is a concerning lack of detail on how Assessments of Environmental Capacity will be delivered in practice– despite the fact that these are acknowledged by LPEG as an essential counter-weight to assessments of housing need in its vision for plan-making. This stands in stark contrast to very detailed proposed changes to guidance on assessing housing need
- We support the group’s assertion that planning needs a period of stability after significant recent reform – but feel that proposing 47 reforms across this system is not compatible with the need for stability. Although a small number of these are welcome, many could result in further confusion and instability in the system. These are on top of many other changes in recent years and additional to other forthcoming reforms such as those in the Housing and Planning Bill.
- The report makes many recommendations relating to strategic planning. We agree that there is a clear need for more consistent, strategic planning, but we do not believe that the recommendations put forward would successfully address the problem, nor that they would deliver and be consistent with democratic and environmental objectives. The Government should, in particular, review how strategic planning is considered within its devolution agenda
- The report fails to adequately address local authority resourcing and skills. Council planning teams have had the largest percentage cuts of any local authority function in the last five years. It is difficult to see how further radical change can be effectively absorbed and delivery speeded up without the provision of additional resources. Government should provide transition funding to help planning authorities adjust to the significant reforms being made to the system
- Overall the report presents a mixed and contradictory picture on public engagement. There are some welcome recommendations (for instance promoting earlier public consultation at the vision and high level options stage). However, we are concerned by proposals to remove discretionary consultation, to confine representations at Examination stage to written form, and a lack of proposals to improve transparency over strategic planning mechanisms
Through a separate consultation the Government has asked for views from farmers and other rural businesses about their experiences of the planning system in rural areas. In particular, the Government are asking whether there should be more ‘permitted development’ in these areas – in other words, development which does not require full planning permission.
As a rural business with more than 11,000 employees based predominantly in rural areas, managing more than 250,000 hectares of land, we are involved in many forms of development in rural areas.
We believe it is important that buildings are both useful and used, where this is possible, and as an employer and stakeholder in many rural areas, we want to see thriving rural communities. We also support the planning system as a tool for enabling good, necessary development which is in the public interest, and is sympathetic to, and complements, its surroundings.
We see no need for further major reforms to the system, and in particular do not feel that any further extensions to permitted development rights would be appropriate. We also oppose any extension of existing rights to protected areas. 75% of National Trust land is within National Parks and AONBs, and, as a rural business carrying out development in these areas, we believe that the current planning regime is the correct one. National Parks, AONBs and other protected land such as World Heritage Sites and conservation areas. These are exactly the types of place where the standard solutions, which permitted development rights encourage and support, can easily cause unnecessary harm.
In addition, we regret the Government’s recent announcement that it plans to allow mobile phone masts of up to 20 metres to be erected without requiring full planning permission in protected landscapes, and ask Government to reconsider this decision. As an applicant, our experience is that a creative dialogue with the local planning authority can often be means of designing a development that both meets operational needs and satisfies environmental concerns. We are concerned that these changes will alter the balance between ensuring the efficiency of operators’ networks and the need for landscape protection, to the detriment of some of our finest landscapes.
We also ask the Government to improve guidance for councils to ensure protections for AONBs are properly applied.
You can view our full response to the Rural Planning Review consultation here: Rural Planning Review National Trust response – April 2016 (PDF)