Creating communities, not just homes
With more than 1.3 million households on social housing waiting lists and record numbers of children living in temporary accommodation, councils in England are operating at the very sharp end of this emergency.
Local government fully shares the Government’s commitment to boost housebuilding significantly, and stands ready to work constructively with ministers, communities and developers to deliver the 1.5 million safe, decent and genuinely affordable homes that the country urgently needs.
To tackle this crisis successfully and turn these shared ambitions into reality, it is vital that councils are equipped with the right powers through the planning system, along with the skills, resources and long-term funding to take effective local action.
The Government has proposed the largest shake-up of planning policy since the National Planning Policy Framework was introduced in 2012.
Given the breadth of changes proposed and the potential implications each change could have, the LGA has strongly urged ministers to take careful heed of our, and our member councils’, consultation responses, as those most intrinsically involved in plan-making and decision-taking.
Planning is about creating communities linked with the right economic activity and public services, while conserving and enhancing the natural and local environment. Critically, local authorities must be empowered to take their residents along with them on this journey to develop and build more homes.
“Planning is about creating communities linked with the right economic activity and public services”
That is because it is not just homes that are required to create thriving, attractive and desirable places and communities in which to live, but the accompanying local and national infrastructure – to be developed both now and phased at early and timely stages alongside the development of new homes – which is of primary concern for residents.
Additionally, the Government must take urgent action and work with the development and housebuilding industry to ensure there is a suitable pipeline of sustainable sites, which – once allocated in a local plan and/or given planning permission – are indeed built out. People cannot and do not live in planning permissions.
Local authorities must be given greater powers to ensure prompt build-out of sites with planning permission and we urge the Government to come forward with the outcomes of two consultations from last year regarding build-out.
Councils should not be subject to punitive measures regarding the delivery of housing, which undermine the plan-led system, including the five-year housing land supply test and the housing delivery test.
While we support the Government’s aim to improve the efficiency and consistency of the planning system, we have significant concerns about the limited flexibility within the proposed reforms for planning committees.
A standardised approach does not account for the diversity across local planning authorities, and it is essential that councils retain the ability to tailor decision-making processes to reflect the specific needs of their communities.
The involvement of elected councillors in planning decisions is the backbone of the English planning system and our reservations about a national scheme of delegation centre on this role potentially being eroded.
Government must also remain mindful that – with devolution, widespread local government reorganisation and the introduction of spatial development strategies led by combined authorities, and with two approaches to plan-making with definitive backstop dates in place – this is a period of significant flux, change and uncertainty within local planning authorities.
Plan-making policies
Key points in the LGA’s response to the government consultation on changes to the National Planning Policy Framework (NPPF) include the following, in respect of plan-making policies…
National decision-making policies
These must not become a rigid substitute for local decision-making. The local plan must remain the primary vehicle for shaping places, and national policies must leave room for local discretion to address site-specific constraints that national rules cannot anticipate… If a local authority has the evidence to set a higher standard, regarding environmental standards, design or density, for example, they must retain the primacy to modify or amplify national policy to suit local needs.
Local plans
The LGA supports the plan-led system and the clear definition of the local plan’s role. However, the expectation that plans are prepared and adopted within 30 months is extremely ambitious given the current resourcing crisis in local planning departments, with 79 per cent facing recruitment difficulties.
Plan evidence
The LGA warmly welcomes the explicit policy direction to ‘reuse or update existing evidence’ rather than commissioning wholly new studies. This will significantly reduce the resource burden on councils and accelerate plan adoption. We urge the Planning Inspectorate to apply this policy robustly during examinations to prevent unnecessary requests for additional evidence.
Limiting local standards
Councils should be able to respond to local conditions. One-size-fits-all national policies can have perverse outcomes in highly specific local circumstances. If they are introduced, they must be limited to technical matters and not restrict local authorities from setting higher standards where there is local ambition to do so.
National bodies need to cooperate
Effective strategic planning requires that infrastructure providers (such as water companies and National Highways) are not just consultees, but active partners. The LGA is concerned that without stronger powers to compel infrastructure providers to align their investment plans with local growth strategies and spatial development strategies (SDS), the envisaged cooperation will not deliver the necessary infrastructure to support growth.
Viability assessments
We strongly support the move towards ‘standardised inputs’. The LGA has long called for reform to prevent developers from using viability assessments to negotiate down contributions towards affordable housing and infrastructure. We urge the Government to ensure these standardised inputs specifically prevent the price paid for land from justifying a failure to comply with policy.
Review mechanisms
Local plans should set out the specific circumstances for review mechanisms, but national policy must set a high bar for their use to ensure they remain exceptional rather than routine. Review mechanisms are a necessary tool where viability is genuinely challenged by unforeseen economic shifts, but they should not be a safety net for developers who have overpaid for land.
Energy efficiency standards
Restricting local authorities from setting energy efficiency standards above Building Regulations undermines local climate leadership and the Government’s own climate ambitions. Many councils have declared climate emergencies and wish to push for energy-efficient and affordable-to-heat homes faster than national minimums allow. The NPPF should be suitably flexible to accommodate this local ambition, rather than capping it.
Our full response also covers proposed changes to decision-making policies, achieving sustainable development, delivering a sufficient supply of homes, ensuring the vitality of town centres, securing clean energy and water, making effective use of land, protecting Green Belt land, achieving well-designed places, managing flood risk and coastal change, conserving and enhancing the historic environment, and much more.