A national organisation representing civic societies across the UK has criticised many of the main changes which the government is proposing to make to the planning system. It is inviting members of the public who agree with its stance to respond to a government consultation exercise in a similar way.i
in its response to the ongoing public consultation, Civic Voice - "a civic movement with a strong local presence and an influential national voice" - has expressed concerns that the proposed changes would weaken the Green Belt, would result in the construction of new housing with insufficient supporting infrastructure and with too little employment and retail land nearby, and would place insufficient emphasis on local and neighbourhood plans. It is unhappy about the proposal to make it easier to build "starter homes", where purchasers would receive a discount but be free to later sell their house at market rate without repaying the discount.
Civic Voice is unhappy with moves to force local councils to identify additional sites for new housing when there is so much land where developers have permission to build but choose not to do so for the time being: "Unimplemented permissions do not deliver houses.2
Civic Voice share some of the concerns of the Council for the Protection of Rural England which we reported earlier this week. Both organisations suggest that individual members of the public should respond to the Government consultation document in similar terms. The deadline for responses is 22nd February.
Civic Voice response covering letter
To: DCLG Planning Policy Consultation Team (via email)
Dear Sir/Madam,
RE: Civic Voice response to the DCLG National Planning Policy consultation
Civic Voice is the national charity for the civic movement. We work to make the places where everyone lives more attractive, enjoyable and distinctive and to promote civic pride. We set up in 2010 and will be celebrating our 6th anniversary in April 2016. Since we began, we have been joined by hundreds of volunteer-led, community based civic societies with over 76,000 individual members. Civic societies exist in over 60% of local authority areas.
Our response to the consultation is informed by our members’ practical experience and local knowledge. This response has also been informed by the experiences of our Expert Panel, which consists of retired planning inspectors, senior planning officers and heritage and conservation experts. All are members of a civic society.
Positive spatial planning
Civic Voice believes in the importance of the planning system. It combines vision with necessary regulation and plays a critical role in positively managing development, which protects and improves the quality and prosperity of places. We believe its role needs to be strengthened and supported through improved opportunities for public engagement. The planning system also needs effective resources, particularly at local authority level, to produce timely plans with quality of place at their heart.
A clear and effective National Planning Policy Framework (NPPF) which promotes sustainable development; balancing economic, social and environmental considerations, is critical to the planning decision making process, which affects the quality of our cities, towns and villages.
We welcome the opportunity to respond to the consultation. In summary, our response focuses on three key areas of concern with the proposed changes to the NPPF:
1. Unintended consequences of the presumption in favour of brownfield land
Civic Voice supports the principle of developing suitable brownfield (previously developed land) before greenfield sites. However, we are concerned that the proposal, which would in effect, create a presumption in favour of brownfield land is too crude a policy tool and could result in unintended consequences. This is particularly concerning given the link to the statutory register of brownfield land suitable for housing development and ‘permission in principle’ proposed through the Housing and Planning Bill.
To us, brownfield land means urban infill sites, not previously developed land in rural areas, where access to services and public transport is often limited. There are numerous examples of brownfield urban infill sites up and down the country, which are in much need of investment and regeneration. National planning policy should, quite rightly, prioritise such sites for redevelopment given the clear benefits to our towns and cities, and Civic Voice would welcome strengthening national policy to encourage this. We are concerned, however, that the proposed presumption in favour could open up large amounts of land to solely housing development, not necessarily within areas requiring regeneration or in sustainable locations.
2. Implications of the housing delivery test
It must be accepted by Government that there are other factors which have led to historic under delivery of housing. The principal one is the problem of unimplemented planning permissions. At present there is no requirement for developers to implement permissions or indeed, complete sites. Unimplemented permissions do not deliver houses.
Civic Voice objects to the proposed approach to require those local planning authorities, in areas where ‘under-delivery’ is identified, to identify more sites for housing. We are concerned that the effect of this would be to allow developers to continue accumulating permissions with still no guarantee of delivery and significantly more land will be allocated for housing than is required. This proposal would further undermine the community’s influence over the location of new housing without imposing any additional pressure on developers to build houses.
3. Loss of the strategic approach to Green Belt
The consultation puts forward several proposals to encourage housing delivery in particular, starter homes, on sites within the Green Belt i.e. widening the rural exception site policy, encouraging redevelopment of brownfield land in the Green Belt, supporting new settlements. Civic Voice is concerned that the cumulative effect of the proposals would be to create a fundamental change to and weakening of Green Belt policy.
It is important to remember the five purposes of the Green Belt, as set out in the NPPF and the well-established test for releasing Green Belt land for development; ‘in exceptional circumstances’. This is a high bar and the current NPPF gives strong protection to Green Belt. We await the detailed policy wording of the proposed changes but we are very concerned that the current proposals will allow ‘nibbling away’ and erosion of established Green Belt and inevitable resultant pressure to amend Green Belt boundaries.
We attach our detailed response to the consultation questions overleaf, which I hope you find helpful.
Yours faithfully,
Ian Harvey
Executive Director
The full letter, with more detailed points, is available on the Civic Voice website.
One of the many civic groups affiliated to Civic Voice, is the Southgate District Civic Trust.
