The consultation for Planning for the Future, the government White Paper proposing major planning reforms, closes on 29 October. Earlier this month, Future of London’s Steering group met for an informal discussion on what the proposed reforms might mean for London, an event that was kindly sponsored by Lewis Silkin.
Written in response to the government view that the planning system is too complex and ineffective, there is no doubt at all that Planning for the Future would mean a drastic overhaul of planning. To frame the discussion, Sara Hanrahan, Partner and Head of Planning at Lewis Silkin, kicked off the event with a succinct summary of the major changes that the White Paper is proposing.
Local plans and plan-making
As development management policy will be set out at a national level, local plans will be slimmed down and focus on how land is allocated for development. Land has been divided into three zones:
- growth areas for substantial development
- renewal areas for small schemes within built areas
- protected areas for limited development in areas of countryside or green belt, for example.
The local plan’s role will be to clarify the rules about what can be done in each of these areas, like location size and building heights and so on. The hope is that a zonal system will boost housing delivery and move away from a discretionary, case-by-case system towards a more defined set of rules that provides certainty.
Housing need and housing targets
Alongside Planning for the Future, the government also published a consultation on changes to the method for assessing local housing need. This is a proposal to change the guidance in the short term but it’s also relevant to the proposals for land supply reforms set out in the White Paper.
The new method would move away from just forecasting housing growth and, instead, use a blended approach that would take existing housing stock levels into account as well. This would allow more up-to-date data to be used for calculating local housing need. But one of the big concerns in London is that the new formula might lead to housing targets that are unachievable.
Design codes and a ‘fast-track for beauty’
Throughout the White Paper, there’s a big emphasis on design. Last year, the government issued a National Design Guide that sets out 10 broad principles for defining successful places. What Planning for the Future suggests is that the national guide and codes would be supplemented by local guides and codes, the latter shaped by input from local communities.
There is also a ‘fast-track for beauty’ option for new developments, which suggests that if proposals come forward that comply with good design principles, they would be expedited. But Sara did admit that people are still a bit puzzled by what the government means by ‘beauty’.
Tech to play a greater role in planning
Another important change being put forward – and, arguably, the proposal that’s being met with the most support – is that technology will play a much greater role in both the planning process and in local plans themselves.
The government want to introduce map-based, fully digitised local plans and are preparing detailed guidance to help local authorities do this. This would include a model template so there would be an element of standardisation across local plans throughout the country.
What does all this mean for London?
Hilary Satchwell, Director at Tibbalds Planning and Urban Design and one of the Mayor’s Design Advocates, was keen to stress that London is already doing a lot of the things that are being proposed in the White Paper.
- We already have Opportunity Areas, which are growth zones, and areas that are protected, such as the Green Belt.
- Local plans are already slimmer in the capital than elsewhere in the country, given that planning policy here is currently set both regionally and locally.
- London has a good track record in good design and placemaking, and the New London Vernacular delivers better quality housing than we’ve seen before.
While Hilary admitted that the current system isn’t perfect – it’s risk averse, it makes it hard to engage with communities in the early stages and some terrible developments still get planning permission – she questioned how radical Planning for the Future really was. “Isn’t this White Paper just doing planning the other way round? Isn’t it setting out a strategy for prejudging through the Local Plan what the answer is and then setting out and coding how you might get there?” she asked.
“A transparent, digital and accessible planning system would be fantastic”
In response to Sara’s and Hilary’s reflections, FoL’s Steering Group – which is made up of planning, housing and regeneration practitioners from across the public and private sectors – then debated what these proposals might mean for London. Everyone was in agreement that the digitalisation of planning has the potential to greatly improve the system – if it’s done well.
Lockdown has meant that many local authorities have already been carrying out digital engagement and have found that they’ve been able to reach different demographics. But it was also pointed out that it will take time to put a fully digital, transparent system in place and the government may have underestimated how challenging this will be. The recent debacle over the Covid test and trace system shows just how badly online systems can go wrong when they’re rolled out in a rush.
The group also agreed, for the most part, on the White Paper’s aspiration to engage more people with the planning process – particularly because in the current system, planners only tend to hear from the ‘usual suspects’.
But although it’s a great idea to get more residents involved in the local plan, it seems unrealistic to expect them to engage in early, broad, and perhaps more strategic, discussions of a Local Plan. People tend to get involved with the planning system only when there’s a particular development or issue that affects them.
While more consultation with residents early on might make the early parts of the planning process, such as drafting the Local Plan, more democratic, the implication is that this would then mean less opportunities for local people to engage later on.
One size doesn’t fit all
Several attendees expressed concern that London’s built environment is so much more complex than the three zones proposed – and that’s what makes its urban landscape so unique. Because of the high densities of developments in the capital, considering the context of each new site and how it fits in with the surrounding area is critical.
“A tick-box, numbers-driven approach risks reducing creativity, particularly when it comes to the high design standards that we see in London,” said one attendee.
One local authority planner said that, in his borough, not all of the sites that come forward would easily fall into the three zones outlined in Planning for the Future. And the lack of nuance in the White Paper’s proposals, particularly around zoning but also in the shift from local to more national policies, would be problematic for local authorities that create bespoke planning policies in order to reflect the needs of local communities.
“The big downfall of the White Paper is that it reduces the planning system to numbers. When planning’s done right, it’s so much more than that,” added another local authority attendee.
National versus local policies
While there was concern that a zonal system is too simple in a city like London, some attendees also feared that the emphasis on more national policies would make the capital’s planning system even more complicated, given that we already set planning policy at a local and regional level.
But, as Hilary pointed out, there’s a need for national policies alongside regional and local ones – and having several different levels of policy isn’t in itself a bad thing. However, it needs to be clear who controls what at each level and there was a feeling amongst the group that the White Paper has not fully untangled the distinction between central and local government policies. What if, for example, local design codes developed by a local authority through engagement with residents contradicted the national design code?
And several attendees also made the point that the main reason why the current system is slow and therefore perceived as ineffective, is because planning departments are seriously under resourced. It’s difficult to both retain existing staff and recruit new staff because of the workloads. This lack of consistency can lead to project delays as past decisions are overturned when a new officer starts in post.
Both the public and private sector agree that the planning system would be more efficient if there were more investment in, and resources for, local authorities. The government hopes that the costs for the new planning structure will come from developers as a development contribution, but whether this would sufficiently boost the resources of local authority planning departments isn’t examined in much detail in Planning for the Future.
“This will have a devastating impact on affordable housing provision”
Arguably, the harshest criticism of the new proposals came from both local authority and housing association Steering Group members, regarding the impact these reforms would have on affordable housing provision in London.
There’s an urgent need to address the capital’s housing crisis, given the high numbers of people on local authority housing waiting lists, and London’s high house prices. But none of the proposals put forward in the White Paper will boost the delivery of affordable housing.
Housing associations, in particular, risk being marginalised within the housing market, as the restrictions on cross-subsidising affordable homes with market homes suggested in the paper will limit both their offer and their competitiveness. This may drive housing associations out of London, to places where they can more easily secure affordable land.
What’s next for the White Paper?
As Sara was keen to stress, a big ‘if’ hangs over all of these proposals. Given that much of the White Paper seems to be unpopular across the political spectrum, we’ll have to wait and see just how many of them are taken forward.
Nevertheless, it has clearly sparked a lot of passionate debate within the sector about the flaws and merits of the current planning system, whether it’s time for reform and how that reform might happen. Involving more planners and other built environment practitioners in the next iteration of these proposals might be one way of answering some of these questions.
Thanks to the following Steering Group members for their thoughts and contributions:
- Neil Cleary, LB Hackney
- Patrick Devlin, Pollard Thomas Edwards
- Lisa Fairmaner, Greater London Authority
- Jenna Goldberg, London Communications Agency
- Tracy Lavers, Notting Hill Genesis
- Stephen McDonald, LB Barnet
- Steve Skuse, Catalyst Housing
- Danny Sutcliffe, Red Loft
- Emma Talbot, LB Lewisham
- Jonathan Wade, RB Kensington & Chelsea