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The Association of Directors of Environment, Economy, Planning & Transport (ADEPT), whose members are local government officers, has suggested that the Ministry of Housing, Communities & Local Government needs to think again about the contents of its recent planning white paper, Planning for the Future1.
ADEPT says that the policy paper lacks necessary detail and risks exacerbating inequalities in different areas of the country by encouraging investment in high value areas instead of where it is actually needed most.
Furthermore, it represents “the imposition of a national, top-down approach that does not reflect the local social, economic, environmental and financial challenges faced by local areas”.
ADEPT says in its response2: “The current proposals risk being undemocratic from a local authority perspective, given the future role it envisages for elected councillors and the significantly limited influence that local people will have in relation to decisions about their towns, cities and neighbourhoods through further deregulation.”
ADEPT is also critical of the proposals for new arrangements to make developers pay local authorities for planning permissions, replacing the community infrastructure levy (CIL) and the use of Section 106 agreements by a new infrastructure levy.
“The introduction of an infrastructure levy could simplify the current mixed pattern of CIL and S106. However, there are concerns about the introduction of a mandatory, nationally-set rate based on a proportion of the development value above a certain threshold. This could mean that the Infrastructure Levy would not be payable if those developments do not meet the minimum threshold. Furthermore, it would only be payable on the proportion of the value that exceeds the minimum threshold. Many areas of the country, particularly outside the southeast, have marginal viability,” ADEPT says in its response. “There is a real risk that low value areas under the new system result in LPAs being unable to secure contributions towards new infrastructure. This means that those same local authorities will be left carrying the financial burden of mitigating the wider impacts of development. Furthermore, the proposed calculation does not consider the wide variation in site specific acquisition and enabling costs, for example land value, demolition and remediation. Such an omission of half of the contributing factors to a scheme’s viability will inevitably mean a combination of the following outcomes:
- Large numbers of sites (especially brownfield) become unviable
- The delivery of housing is slowed
- The rates are set so low that they do not deliver infrastructure to at least current levels
- Planning gain from the increase in land values upon planning consent will not be captured on sites that can afford it, particularly on strategic greenfield sites.”
ADEPT president Nigel Riglar said: “The pandemic is bringing communities closer to their local places. They want to see more attention given to green spaces, biodiversity and tackling climate change. They want their places to become healthier, more inclusive and resilient. And, most importantly, they want to have their say, not only on the principles of development through local and neighbourhood plans, but also on individual schemes.
“As it stands, the white paper risks losing local accountability, reducing the influence of communities and their democratically elected representatives through increased deregulation.
“We believe a major reform of the planning system is overdue and presents a valuable opportunity to truly plan for the future through creating a collaborative approach. ADEPT wants to work with government to ensure a new, simplified planning system that will enable local democratic involvement, has a climate focus and will support levelling-up across the country.”
1. The government’s white paper, Planning for the Future, is available here
2. ADEPT’s response in full is available here
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