Reform of Planning System to Involve Community

Aerial View of Housing
Aerial View of Development; picture from Centre for Sustainable Energy

Letter to MP About Reform of the Planning System

Dear Mr Collins,

I hope you are well. When I wrote to you last you said you were broadly in favour of the reforms. I would like to request that you review your opinion in the light of the following information.

Four recent events give rise to this particular email:

  • the Chesham & Amersham by-election. The result should be treated exactly as the press reports suggest – as a shot across the bows highlighting extreme concern about the impact of planning policies and proposed changes. The recent election of yet another Green Hythe Town Councillor and the huge swing towards the Green candidate, Douglas Wade, in the Elham Valley election should also be ringing bells. Greenwashing does not work, people see through
  • the Parliamentary Report about the planning system. This is an excellent report and sets out recommendations which I urge government to heed;
  • The Queen’s Speech. This, although containing limited information, did appear to hint that the Planning Bill would contain most of what was proposed in Planning for the Future, despite widespread concerns raised in consultation responses;
  • the formation of the Community Planning Alliance. I am an active supporter of this new national group. It brings together 440 grassroots campaign groups on a map which has been viewed nearly 100,000 times. Planning and the damage being done to the environment by ‘build, build, build’ is of huge concern. A glance at the map indicates that Chesham & Amersham could be the tip of the iceberg.

I seek your urgent support to lobby for the below, which would make an enormous difference to the way the planning system operates:

    Local communities must be able to shape their own futures.
    1. Communities must be able to comment on planning applications. The proposal in Planning for the Future to remove the planning application stage in areas zoned for development should not be implemented;
    2. All Local Plans should be subject to a referendum, as Neighbourhood Plans are;
    3. Authorities must be asked at draft plan consultation, as one of the soundness tests for local plan examination, if they have engaged with communities satisfactorily and acted upon feedback received during consultations.
    There is not a housing crisis. There is an affordability crisis. It will not be solved by asking the private sector to build, build, build, nor by the initiatives proposed by government (Help to Buy, Shared Ownership, 95% mortgages, First Homes). There must be a proper analysis of housing need so that policies can reflect how to deliver truly affordable homes – not those unaffordable ‘affordable’ homes currently provided by the private sector.

    As per the recommendation of the Parliamentary Committee in its report on the planning system last week, there needs to be an evidence-based national housing target. In addition, policies need to address need, not demand:
  1. For starters the housing target must be up-to-date (not based on the 2014 projections which are used to justify the 300,000 homes p.a target). It should be based on accurate projections (removing the current problem that overcounts students and births in at least 50 districts) and include evidenced assumptions about concealed households. No inflation should be applied through formulae to reach the arbitrary 300,000 homes p.a figure;
  1. Sequential test – authorities to demonstrate that they have brought empty homes into use and used suitable brownfield land;
  1. Needs-based policies. It would be a simple piece of analysis to assess local incomes and what housing can be afforded. This is where government polices and support should be directed, including a big social housing building programme.
    1. Set up an independent panel of ecologists (paid for by developers). Developers must not be allowed to choose an ecologist. Allow Communities to call for a second opinion (also paid for by a developer) if there are any doubts about the validity of an ecologist’s report;
    2. Give environmental matters greater weight than economic and social factors in plan-making and decision-making and remove (as I have requested before) the environmentally damaging paragraph 11d – the presumption in favour of development which trumps other matters when there is no plan or five year supply;
    3. Developers to demonstrate that they have taken on board community concerns before a planning application / reserved matters is granted. A deposit to be paid up front into an escrow account to be repaid once biodiversity promises are implemented.

And finally, to demonstrate Government’s commitment to involving communities in plan-making (as set out in Planning for the Future), I would like to request a meeting with Robert Jenrick MP for the founders and some of the followers of the Community Planning Alliance. This can be virtual. I would be most grateful if you could ask him if he will agree to this.

I hope you will be able to assist and I very much look forward to hearing from you.

Kind regards

Mark Brophy

Member of the Save Prince’s Parade campaign, Member of the Community Planning Alliance, author of The Prince’s Parade and concerned environmentalist.

[Read Damien Collins’ reply.]