The Chichester Society has submitted a response to two Government documents relating to the planning system.
First the Government has published a consultation document on changes to the planning system a copy of which can be viewed here. The consultation ends at 11:45pm on 1 October 2020. Ways for members of the public to respond can be found here.
Second the Government has also issued a White Paper ‘Planning for the Future’ which can be found here.
The Chichester Society Executive Committee has submitted the following response:
To Civic Voice
The Chichester Society is making the representations set out below to Government on the two planning Consultations.
- Changes to current Planning Systems, a consultation paper with proposals to improve the effectiveness of the current system. It will be found on this link:
Whereas under current policies the assessment of how many new dwellings are to be planned for in any given district is subject to a cap, which applies as a limit to the number, the new method will remove that cap. In addition, statistical sources for determining the starting number of new homes will now involve the use of the ‘higher of’ of various statistics. The Chichester District Local Plan 2015 which expired in July this year contained a requirement for 435 dwellings per annum. We understand that the number will increase to 995 dpa or thereabouts as a result of the changes now proposed which we consider excessive.
These changes pay no regard to local circumstance. They treat all parts of England in the same way. We believe that the individual character of our District areas should be assessed rather than our being handed a formula of “one size fits all”.
Because of the amount of protected landscape (SDNP & AONB) within the Chichester District so little is left that is capable of development and almost all that there is comprises high grade agricultural land in farming production mainly within the southern coastal plain. With the need to increase food production, this area has some of the most fertile land in England with long sunshine hours capable of high levels of agricultural output. To destroy this natural resource and instead to build houses upon it makes no economic sense.
The housing numbers imposed on any Local Planning Authority area should not be determined by the actual size of the authority area but on the size of those parts which have no physical or environmental limits to development. Therefore, we consider that assessment of housing number in any District area should be reduced by the omission of those parts:
- within a National Park,
- an AONB,
- land liable to flood,
- grade 1 & 2 agricultural land,
- wildlife corridors
- and greenfield land important to the setting of the any National Park, AONB or City.
In addition, in Chichester, so much of the demand for housing comes from completely outside the area by the insatiable demand from those elsewhere in England seeking to relocate, many for early retirement. Priority in the allocation of new housing should be given to local residents and young people
- It is proposed to reduce the content of Local Plans. The changes envisage reducing the size of LPs by ‘at least 2/3rds’ by cutting out all lists of ‘policies’ and instead producing a ‘core set of standards and requirements for development’.
Comment: This is a huge task for Local Planning Authorities with limited staff and expertise to create what will need to be site specific sets of ‘standards and requirements for development’ on all areas where ‘growth’ or ‘renewal’ is to be zoned.
- Encouraging greater public participation at the consultation stage of LPs so as to reduce consultation later on when development in ‘growth’ areas comes forward – in fact leading to abandoning the need for outline planning applications altogether in many cases. The proposal is that automatic outline permission is given for new development in “growth” areas and for “beautiful” schemes.
Comment: We oppose the limiting of public engagement on where new development is to be allocated to that period during the Local Plan preparation. Our experience has been that the standard of design falls once development is applied for. We believe that all development should continue to be the subject of individual planning applications.
- Making LPs subject only to the NPPF ‘sustainability’ test, abolishing the test of ‘soundness’, abolishing ‘sustainability appraisals’ and abolishing the ‘duty to cooperate’.
Comment: These tests are seen as essential in preventing a ’developers’ charter.
- Limit content of LPs to that of setting out site or area specific parameters.
Comment: This is a huge task beyond the capacity of most District PLA’s and would need major public engagement to be seen as trusted.
- Involve communities in setting design codes in their area for LPs.
Comment: Looking at the National Design Guide published in Oct 2019, it says almost nothing about community involvement in setting local design codes which we think it should have done. Communities will want involvement provided they believe they will be listened to.
- Nationally to set a new infrastructure levy for infrastructure and affordable housing.
Comment: no comment
- Alter Local Planning Authority (LPA) planning roles to that of appointing a chief officer for ‘design and place making’. The indication is that this may become a ‘statutory appointment’.
Comment: no comment
- Altering the system such that all land falls within one of 3 planning zones– a ‘growth area’ suitable for substantial development’, a ‘renewal area’ which means an existing built up area which is considered suitable for development or ‘densification’ and finally a ‘protected area’ where more stringent development controls apply.
Comment: We have concern that public support to agree where ‘growth’ is to take place will be difficult, perhaps impossible. We consider allocating land for ‘renewal’ and ‘protection’ will be easier.
- Limit the time to determine planning applications to 8 or 13 weeks and to achieve this, to consider making LPAs refund application fees if they exceed these periods.
Comment: Such pressure is only likely to reduce public confidence in the planning system.
- Reduce the time to produce a LP to just 30 months, with the threat of government intervention if exceeded. Give Planning Inspectors holding LP examinations the right to decide who is called to give evidence, the intention being to shorten the process.
Comment: This is a huge task for LPA’s with limited staff and expertise to create what will need to be site specific sets of ‘standards and requirements for development’ on all areas where ‘growth’ or ‘renewal’ is to be zoned.
- Increase ‘permitted development’ rules
Comment: still under discussion
- Increase land owner / developer contributions when land is given pp for development
- Replace paper with digital code: interactive maps, modelling and text messaging.