White Paper: Planning for the Future – Questions
Pillar One – Planning for development
OVERVIEW
1. What three words do you associate most with the planning system in England?
Unprofessional
Inconsistent
Unaccountable
2. Do you get involved with planning decisions in your local area?
[Yes / No]
Yes
2(a). If no, why not?
[Don’t know how to / It takes too long / It’s too complicated / I don’t care / Other – please specify]
3. Our proposals will make it much easier to access plans and contribute your views to planning decisions. How would you like to find out about plans and planning proposals in the future?
[Social media / Online news / Newspaper / By post / Other – please specify]
The current system works well – the plans are available on the LPA’s website. The proposals in the Planning White Paper would reduce most of the opportunities for people to contribute views to planning decisions. All new planning applications and intended decisions must at least be available on the LPA’s website, and all interested parties should receive notifications on a weekly basis of new applications and decisions made.
4. What are your top three priorities for planning in your local area?
[Building homes for young people / building homes for the homeless / Protection of green spaces / The environment, biodiversity and action on climate change / Increasing the affordability of housing / The design of new homes and places / Supporting the high street/ Supporting the local economy / More or better local infrastructure / Protection of existing heritage buildings or areas / Other – please specify]
Prevent creation of beds in sheds, prevent overdevelopment of sites through sub-division, effective enforcement.
A NEW APPROACH TO PLAN-MAKING
5. Do you agree that Local Plans should be simplified in line with our proposals?
[Yes / No / Not sure. Please provide supporting statement.]
No – Simplification always delivers opportunities to rogue developers. Planning control should not become a tick box exercise. HRA would support improvements in the Local Plan process, but think Proposal 2 requires substantial further work before adoption. Local Plans should not be stripped of
essential local content and relevant general policies.
6. Do you agree with our proposals for streamlining the development management content of Local Plans, and setting out general development management policies nationally?
[Yes / No / Not sure. Please provide supporting statement.]
No – It should not be left to national government alone to set the policies applicable to determining applications not consistent with the design codes or other specifications in the local plan. The White Paper’s professed intention to improve the involvement of local communities is unlikely to be successful when both local authorities and Inspectors will retain the power to approve developments that conflict with the agreed Plan. Developments that conflict with the Local Plan should be illegal. The proposals in the White Papers bring more certainty to developers but less certainty to communities, who will
probably lose even more motivation to participate, and engagement is likely to suffer as a result.
7(a). Do you agree with our proposals to replace existing legal and policy tests for Local Plans with a consolidated test of “sustainable development”, which would include consideration of environmental impact?
[Yes / No / Not sure. Please provide supporting statement.]
No – The test of whether or not a Local Plan is sound should remain. Both environmental and equalities impact assessments should be conducted and evaluated. A test of “sustainable development” that might be developed cannot yet be commented upon but it is assumed that the three objectives in paragraph 8 of the 2019 NPPF will be developed, consulted upon and applied.
7(b). How could strategic, cross-boundary issues be best planned for in the absence of a formal Duty to Cooperate?
The Duty to Cooperate should be retained so that actions, decisions or problems arising in a local authority should be notified to any adjacent ones affected.
8(a). Do you agree that a standard method for establishing housing requirements (that takes into account constraints) should be introduced?
[Yes / No / Not sure. Please provide supporting statement.]
No – The proposal in its current form is unworkable. The main problem is that the “housing requirement” for London is 93,500pa compared with the London Plan housing need figure of 66,000pa and the latest London Plan target of 52,000pa. The “housing requirement” is not “objectively-assessed need” but a figure generated to direct new housing to areas where house prices are highest, regardless of the authority’s capacity to accommodate it.
8(b). Do you agree that affordability and the extent of existing urban areas are appropriate indicators of the quantity of development to be accommodated?
[Yes / No / Not sure. Please provide supporting statement.]
No – The correct indicator for whether there is a good housing supply is the difference between the current price of homes and the cost of building more homes. In well-supplied markets, that difference is generally small. The quality as well as quantity of development and how well it meets local needs for
types of housing and jobs will be the basis of success or failure of the planning system.
A STREAMLINED DEVELOPMENT MANAGEMENT PROCESS WITH AUTOMATIC PLANNING PERMISSION FOR SCHEMES IN LINE WITH PLANS
9(a). Do you agree that there should be automatic outline permission for areas for substantial development (Growth areas) with faster routes for detailed consent?
[Yes / No / Not sure. Please provide supporting statement.]
No – All development should be subject to public consultation and assessed against the requirements of the Local Plan.
9(b). Do you agree with our proposals above for the consent arrangements for Renewal and Protected areas?
[Yes / No / Not sure. Please provide supporting statement.]
No – All development should be subject to public consultation and assessed against the requirements of the Local Plan.
9(c). Do you think there is a case for allowing new settlements to be brought forward under the Nationally Significant Infrastructure Projects regime?
[Yes / No / Not sure. Please provide supporting statement.]
No – Unlikely to happen.
10. Do you agree with our proposals to make decision-making faster and more certain?
[Yes / No / Not sure. Please provide supporting statement.]
No – All development should be subject to public consultation and assessed against the requirements of the Local Plan.
Pillar Two – Planning for beautiful and sustainable places
A NEW INTERACTIVE, WEB-BASED MAP STANDARD FOR PLANNING DOCUMENTS
11. Do you agree with our proposals for accessible, web-based Local Plans?
[Yes / No / Not sure. Please provide supporting statement.]
Not sure – The current system works perfectly well. Each member of the HRA Planning Team has a copy of the Local Plan and uses it on a regular basis. We have no objection to a digitised version of the Local Plan as such, but we do not want to lose the hard copy version.
For a Residents’ Association it is fairly easy to identify those sections of the Local Plan that are relevant to our membership and to the Association’s mission statement. The Heston Residents’ Association was established in 1928 “to preserve our heritage and to maintain an acceptable standard of environment for all present and future residents of Heston”.
A STREAMLINED, MORE ENGAGING PLAN-MAKING PROCESS
12. Do you agree with our proposals for a 30 month statutory timescale for the production of Local Plans?
[Yes / No / Not sure. Please provide supporting statement.]
No – The proposed timescale is probably too short and, will result in large numbers of sites where there has been inadequate time or resources to develop a design code and other rules that will ensure high quality and no damage to amenity.
13(a). Do you agree that Neighbourhood Plans should be retained in the reformed planning system?
[Yes / No / Not sure. Please provide supporting statement.]
Yes – Enables effective citizen engagement in the development process.
13(b). How can the neighbourhood planning process be developed to meet our objectives, such as in the use of digital tools and reflecting community preferences about design?
Put forward some suggestions for public comment. Provide some examples of best practice.
SPEEDING UP THE DELIVERY OF DEVELOPMENT
14. Do you agree there should be a stronger emphasis on the build out of developments? And if so, what further measures would you support?
[Yes / No / Not sure. Please provide supporting statement.]
Yes – All planning consents should be removed after 3 years. New consents should not be allowed for a further two years after expiry under the 3 year rule.
Pillar Two – Planning for beautiful and sustainable places
CREATING FRAMEWORKS FOR QUALITY
15. What do you think about the design of new development that has happened recently in your area?
[Not sure or indifferent / Beautiful and/or well-designed / Ugly and/or poorly-designed / There hasn’t been any / Other – please specify]
Mixed – some good some bad, but all new development ignored the impact on infrastructure. All new development should include an infrastructure impact assessment, with detailed proposals for mitigation.
16. Sustainability is at the heart of our proposals. What is your priority for sustainability in your area?
[Less reliance on cars / More green and open spaces / Energy efficiency of new buildings / More trees / Other – please specify]
All development should allow sufficient space between buildings for maintenance from within the curtilage. Many side extensions are build up to the boundary line with a similar situation at the adjacent property. This means that there can be no maintenance of the side edifice of either property. This presents a particularly difficult problem where adjacent properties carry out hip to gable developments.
17. Do you agree with our proposals for improving the production and use of design guides and codes?
[Yes / No / Not sure. Please provide supporting statement.]
No – We already have design guides and codes (aka SPDs). However, Officers are often unaware or unwilling to ensure compliance with the guides/codes. A|l guides and codes should be strictly applied and not ignored for the sake of administrative convenience.
18. Do you agree that we should establish a new body to support design coding and building better places, and that each authority should have a chief officer for design and place-making?
[Yes / No / Not sure. Please provide supporting statement.]
No – Of course such a body would not work because officers will say that “each development must be considered on its own merits”. Regardless of the existence of the new body officers will continue to ignore any inconvenient constraints in the certain knowledge that there is no accountability anywhere in the planning process.
19. Do you agree with our proposal to consider how design might be given greater emphasis in the strategic objectives for Homes England?
[Yes / No / Not sure. Please provide supporting statement]
Please ensure your proposal is subject to full public consultation.
A FAST-TRACK FOR BEAUTY
20. Do you agree with our proposals for implementing a fast-track for beauty?
[Yes / No / Not sure. Please provide supporting statement.]
All development should be subject to public consultation and assessed against the requirements of the Local Plan.
EFFECTIVE STEWARDSHIP AND ENHANCEMENT OF OUR NATURAL AND HISTORIC ENVIRONMENT
No questions
Pillar Three – Planning for infrastructure and connected places
A CONSOLIDATED INFRASTRUCTURE LEVY
22. When new development happens in your area, what is your priority for what comes with it?
[More affordable housing / More or better infrastructure (such as transport, schools, health provision) / Design of new buildings / More shops and/or employment space / Green space/ Don’t know / Other – please specify]
All of the above. All development must include a detailed infrastructure statement of the impact of the development and the mitigation actions that will be taken. The infrastructure statement must clearly state the source of funds for the provision of new infrastructure. Too many developments rely upon developments by TFL or Railtrack without regard for funding sources.
23(a). Should the Government replace the Community Infrastructure Levy and Section 106 planning obligations with a new consolidated Infrastructure Levy, which is charged as a fixed proportion of development value above a set threshold?
[Yes / No / Not sure. Please provide supporting statement.]
Please submit your proposals to full public consultation.
23(b). Should the Infrastructure Levy rates be set nationally at a single rate, set nationally at an area-specific rate, or set locally?
[Nationally at a single rate / Nationally at an area-specific rate / Locally]
Please submit your proposals to full public consultation.
23(c). Should the Infrastructure Levy aim to capture the same amount of value overall, or more value, to support greater investment in infrastructure, affordable housing and local communities?
[Same amount overall / More value / Less value / Not sure. Please provide supporting statement.]
Please submit your proposals to full public consultation.
23(d). Should we allow local authorities to borrow against the Infrastructure Levy, to support infrastructure delivery in their area?
[Yes / No / Not sure. Please provide supporting statement.]
Please submit your proposals to full public consultation.
24. Do you agree that the scope of the reformed Infrastructure Levy should capture changes of use through permitted development rights?
[Yes / No / Not sure. Please provide supporting statement.
Please submit your proposals to full public consultation.
25(a). Do you agree that we should aim to secure at least the same amount of affordable housing under the Infrastructure Levy, and as much on-site affordable provision, as at present?
[Yes / No / Not sure. Please provide supporting statement.]
Please submit your proposals to full public consultation.
25(b). Should affordable housing be secured as in-kind payment towards the Infrastructure Levy, or as a ‘right to purchase’ at discounted rates for local authorities?
[Yes / No / Not sure. Please provide supporting statement.]
Please submit your proposals to full public consultation.
25(c). If an in-kind delivery approach is taken, should we mitigate against local authority overpayment risk?
[Yes / No / Not sure. Please provide supporting statement.]
Please submit your proposals to full public consultation.
25(d). If an in-kind delivery approach is taken, are there additional steps that would need to be taken to support affordable housing quality?
[Yes / No / Not sure. Please provide supporting statement.]
Please submit your proposals to full public consultation.
26. Should local authorities have fewer restrictions over how they spend the Infrastructure Levy?
[Yes / No / Not sure. Please provide supporting statement.]
Please submit your proposals to full public consultation.
26(a). If yes, should an affordable housing ‘ring-fence’ be developed?
[Yes / No / Not sure. Please provide supporting statement.]
Please submit your proposals to full public consultation.
Delivering change No questions
Equalities impacts
27. Do you have any views on the potential impact of the proposals raised in this consultation on people with protected characteristics as defined in section 149 of the Equality Act 2010?
No
