The Government's Planning White Paper has so far received little discussion locally but its proposals could have a far reaching impact on the borough and leave us defenceless against greedy developers, sub-standard housing and loss of amenity.
I publish below, with his permission, a detailed article by Paul Burnham of Haringey Defend Council Housing LINK which contains some suggestions on answering the consultation questions.
The
government’s White Paper Planning for the Future, published on 6
August, threatens to rip up the planning system which was set up in 1947, based
on public control over all changes in the use of land.
It is
Robert Jenrick who is leading on this policy – the man who fast tracked
planning permission to save a developer friend millions of pounds, after
sitting next to him at a Conservative party fund raising dinner.
The
White Paper brazenly suggests that this government is going to increase
developer contributions to housing and infrastructure – by scrapping the
specific obligation to provide affordable housing.
Why
should we believe such nonsense.
Parts of
the country are to be labelled as ‘growth’ or ‘renewal’ zones, with little
opportunity to oppose bad development plans. Powers for local authorities and
communities to oppose bad schemes are to be severely restricted or scrapped
completely.
The
plans are predicated on redefining “affordable housing” as lower cost market
provision, rather than council or social rent.
It is a
top priority to stop this developers’ charter.
The loss
of local authority powers and the loss of public scrutiny mean that there will
be widespread opposition to these plans.
Unsurprisingly,
the policies are being pursued with dishonest and evasive
arguments. But don’t be deterred. Please take a few minutes to
complete the on-line consultation form, to build the opposition to the White
Paper.
Please
ask your residents association, Councillor, trade union or MP to make their
objection as well. You may want to use the suggested responses below.
This
consultation ends at 11:45pm on 29 October 2020.
https://www.smartsurvey.co.uk/s/MHCLG-Planning-for-the-Future/
Q3. Our
proposals will make it much easier to access plans and contribute your views to
planning decisions. How would you like to find out about plans and planning
proposals in the future?
Other
(please specify):
Comment:
Your proposals severely restrict public participation in practice
Q4. What
are your top three priorities for planning in your local area? (Please select
only 3 answers)
Building
homes for the homeless/ Increasing the affordability of housing/ Other (please
specify):
Comment:
Building 100,000 new council homes a year at normal council rents.
Q5. Do
you agree that Local Plans should be simplified in line with our proposals?
No.
Detailed plans are necessary to take proper account of the affordability and
accessibility of housing for all including the poorest.
Q7(a) Do
you agree with our proposals to replace existing legal and policy tests for
Local Plans with a consolidated test of “sustainable development”, which would
include consideration of environmental impact?
No. This
reduces the ability of communities to challenge bad plans.
Q8.(a)
Do you agree that a standard method for establishing housing requirements (that
takes into account constraints) should be introduced?
No.
The housing requirement needs to take account of those who need secure
affordable rented housing (i.e. council and social rent), and not just testing
the accessibility of owner occupation as you are proposing.
Q9(a).
Do you agree that there should be automatic permission in principle for areas
for substantial development (Growth areas) with faster routes for detailed
consent?
No.
Local authorities and communities need to be able to challenge bad
developer proposals which do not provide affordable and council housing, and
which segregate tenures. etc.
Q9(b).
Do you agree with our proposals above for the consent arrangements for Renewal and Protected areas?
No.
Local
authorities and communities need to be able to challenge bad developer
proposals which do not provide affordable and council housing, and which
segregate tenures. etc.
‘Renewal’
tends to mean that great improvements are promised, but we need to be able to
see and challenge the detail before these plans are accepted.
Q10. Do
you agree with our proposals to make decision-making faster and more certain?
No.
Local authorities and communities need to be able to challenge bad developer
proposals which are driven by profit rather than housing needs.
Q11. Do
you agree with our proposals for digitised, web-based Local Plans?
No. Stop
trying to kid us, there is nothing new about the internet, all plans are web
based these days already. Hard copies of the plans should also be made fully
available for ease of reference.
Q14. Do
you agree there should be a stronger emphasis on the build out of developments?
And if so, what further measures would you support?
Yes.
Stop land banking by developers and housing associations.
Q15.
What do you think about new development that has happened recently in your
area? Other (please specify):
Excess
provision of unaffordable housing designed to price out local people.
Q16.
Sustainability is at the heart of our proposals. What is your priority for
sustainability in your area?
Other:
Social
sustainability as specified in Chapter 2 of the NPPF (2019) and Resolution
42/187 of the United Nations General Assembly, to which it refers. This means
banning the excess supply of unaffordable housing which is the prime driver of
forced gentrification and social exclusion, stopping estate redevelopment
schemes, and building 100,000 new council homes a year nationally.
Q21.
When new development happens in your area, what is your priority for what comes
with it?
More
affordable housing.
Q22. (a)
Should the Government replace the Community Infrastructure Levy and Section 106
planning obligations with a new consolidated Infrastructure Levy, which is
charged as a fixed proportion of development value above a set threshold?
No. This
proposal is cynically designed to allow (and in practice, to encourage) local
authorities to reduce funding for council and social housing, in order to pay
for infrastructure costs which are being squeezed by government cuts in revenue
support grant.
Q22. (c)
Should the Infrastructure Levy aim to capture the same amount of value overall,
or more value, to support greater investment in infrastructure, affordable
housing and local communities?
More
value.
Greater
investment in infrastructure, affordable housing and local communities is
needed from developers – but also from government in the form of direct
investment. Building social rent housing pays for itself in reduced benefit
costs.
Q23. Do you
agree that the scope of the reformed Infrastructure Levy should capture changes
of use through permitted development rights?
Yes.
Q24. (a)
Do you agree that we should aim to secure at least the same amount of
affordable housing under the Infrastructure Levy, and as much on-site
affordable provision, as at present?
Yes.
Q25.
Should local authorities have fewer restrictions over how they spend the
Infrastructure Levy?
No.
Q25 (a)
If ‘yes’, should an affordable housing ‘ring-fence’ be developed?
Yes.
Q26. Do
you have any views on the potential impact of the proposals raised in this
consultation on people with protected characteristics as defined in section 149
of the Equality Act 2010?
Yes.
The
proposals restrict the right of local authorities and communities to influence
bad development proposals which are driven by profit seeking private
developers. Reducing the scope of local plans would undermine policies which
protect groups with protected characteristics, and other lower income groups,
and those without savings, or in debt. Merging affordable housing obligations
with infrastructure contributions will tend to undermine housing provision for
the most deprived groups. Implicit throughout this document is the redefinition
of “affordable housing” as lower cost market provision, rather than
understanding the assessed need for social rent housing for those with lower,
insecure and variable incomes, and especially those with low savings or who are
in debt. The focus on funding affordable housing through developer
contributions ignores the well documented failures of this strategy as
developers very effectively game the system, not only by reducing their
contributions in immediate cases but though policy capture at local authority
level as well.
The
outcome if these proposals were to be adopted would be more overprovision of
unaffordable housing, weaker public policy controls over the vested interests
of the private developers, less provision of really affordable housing, and
more stigmatised housing developments with tenure segregation, worse housing
for the poor, etc. This would adversely people with protected characteristics
as defined in section 149 of the Equality Act 2010: ethnic minority groups,
especially black and Asian people and people of mixed heritage, and female
headed households especially single parent female headed households.
IT GETS WORSE
In
addition to the planning White Paper, the government is also proposing four
parallel and very nasty changes to the current planning system:
(ONE)
Housing targets which will pressurise councils to demolish council estates in
London.
(TWO)
Prioritising ‘First Homes’ discounted home ownership, with prices capped at
£250,000 outside London and £420,000 in London, over other forms of affordable
housing.
(THREE)
Removing the requirement to provide affordable housing in developments of up to
40 or 50 homes (instead of 10 as at present).
(FOUR)
Extending the Permission in Principle consent regime to cover major
developments of up to 150 homes.
As with
the White Paper, please make your objection in person, and through your
organisations.
This one
is urgent, bearing in mind the closing date of 1st
October.
https://www.smartsurvey.co.uk/s/MHCLG-Changes-to-the-current-planning-system/
suggested
responses are offered to 13 of the 35 questions below.
Proposal
ONE: The standard method for assessing housing requirement numbers in strategic
plans
Q1: Do
you agree that planning practice guidance should be amended to specify that the
appropriate baseline for the standard method is whichever is the higher of the
level of 0.5% of housing stock in each local authority area OR the latest
household projections averaged over a 10-year period?
No.
The formula is based on the affordability of home ownership, when it is
decent secure and really-affordable homes for all that are required, and not
this obsession with the over provision of market sector dwellings.
The
National Housing Federation predicts that ‘in London the likely uplift for
targets will be about 50%’. The formula used will produce high numerical
targets for the production of unaffordable homes in London in particular, and
would be used to force councils to pursue demolition and gentrification plans
which are targeted against working class communities.
Q3: Do
you agree that using the workplace-based median house price to median earnings
ratio from the most recent year for which data is available to adjust the standard
method’s baseline is appropriate? If not, please explain why.
No. This
formula is based on private ownership alone. It is housing for all including
secure council and social rent which is required as a priority.
Q4: Do
you agree that incorporating an adjustment for the change of affordability over
10 years is a positive way to look at whether affordability has improved? If
not, please explain why.
No. The
basis of the assessment should be the number of people on the waiting list
including concealed households, and newly forming households.
Proposal
TWO: Setting developer contributions for First Homes
Q8: The
Government is proposing policy compliant planning applications will deliver a
minimum of 25% of onsite affordable housing as First Homes, and a minimum of
25% of offsite contributions towards First Homes where appropriate. Which do
you think is the most appropriate option for the remaining 75% of affordable
housing secured through developer contributions? Please provide reasons and /
or evidence for your views (if possible):
i)
Prioritising the replacement of affordable home ownership tenures, and
delivering rental tenures in the ratio set out in the local plan policy.
ii)
Negotiation between a local authority and developer.
iii) Other
(please specify)
The
proposed target of 25% of affordable housing as First Homes should not be
proceeded with. This proposal directs affordable housing policy towards
near-market and market-supporting options rather provision for those most in
need, i.e. council housing at social rents.
Q15: Do
you agree with the removal of the site size threshold set out in the National
Planning Policy Framework?
No.
Affordable housing policy based on housing needs assessments, with priority
given to the greatest need, must be applied to all sites without exception.
It would
be a retrograde step to widen the ‘exceptions’ to affordable housing policy.
Proposal
THREE: Supporting small and medium-sized developers by reducing affordable
housing requirements
Q17: Do
you agree with the proposed approach to raise the small sites threshold for a
time-limited period?
No.
This would damage the interests of the homeless and those in the highest
housing need. Affordable housing is not a burden on the housebuilding
industry, instead affordable housing should be the purpose of the housebuilding
industry.
Q18:
What is the appropriate level of small sites threshold?
i) Up to
40 homes
ii) Up
to 50 homes
iii) Other
(please specify) one dwelling
No
exceptions.
Q19: Do you
agree with the proposed approach to the site size threshold?
No. The
government’s argument is disingenuous. This is not about assisting small and
medium enterprises in the building industry, instead it is about finding an
excuse to roll back criteria for the social sustainability required in
development, as specified in Chapter 2 of the NPPF (2019) and Resolution 42/187
of the United Nations General Assembly, to which it refers.
Q23: Are
there any other ways in which the Government can support SME builders to
deliver new homes during the economic recovery period?
Yes.
Proposal
FOUR: Extension of the Permission in Principle consent regime to cover major
development
Q24: Do
you agree that the new Permission in Principle should remove the restriction on
major development?
No. This
is a bad proposal which would severely limit the capacity of local authorities
and communities to challenge bad development proposals.
Q28: Do
you agree that publicity arrangements for Permission in Principle by
application should be extended for large developments? If so, should local
planning authorities be:
1. required
to publish a notice in a local newspaper?
ii)
subject to a general requirement to publicise the application or
iii) both?
iv)
disagree
If you
disagree, please state your reasons.
Local
authorities must write to all local residents
Q32:
What guidance would help support applicants and local planning authorities to
make decisions about Permission in Principle? Where possible, please set out
any areas of guidance you consider are currently lacking and would assist stakeholders.
Proper
local authority and community scrutiny must be retained in full.
Impacts
of proposals: Public Sector Equality Duty
Q35: In
light of the proposals set out in this consultation, are there any direct or
indirect impacts in terms of eliminating unlawful discrimination, advancing
equality of opportunity and fostering good relations on people who share
characteristics protected under the Public Sector Equality Duty?
None of
these four of these proposals advance equality of opportunity, and all of them
are directly harmful to people who share characteristics protected under the
Public Sector Equality Duty: Black Asian and Minority Ethnic households,
disabled people, and female headed households.
The
recommendation is to withdraw these proposals. The government should provide
affordable housing grant at an adequate level to build 100,000 new council
homes a year at normal council rents.
