Clive Betts MP Chairman,
Housing, Communities and Local Government Select Committee
House of Commons
London, SW1A 0AA
Dear Mr. Betts,
ENQUIRY INTO THE FUTURE OF THE PLANNING SYSTEM
The National Organisation of Residents Associations was established in 2003, and its members represent some 2,500,000 residents throughout England and Wales.
In response to your Committee's Call for Evidence, I have been instructed to submit the following responses on behalf of the National Organisation of
1. Is the current planning system working as it should do? What changes might need to be made? Are the Government's proposals the right
NORA considers that the current planning system is in need of modernisation and restructuring and that it is not fit for purpose in its present form.
It has submitted its response to the Government's Consultation entitled 'Planning or the Future'. Members have two main issues about the White Paper,
which proposes yet another change in the planning regime. It is considered that the intention of some the proposals introduce a fundamental change in the
planning legislation, which may not be apposite.
2. In seeking to build 300,000 homes a year, is the greatest obstacle the planning system or the subsequent build-out of properties with permission?
NORA's perception of the proposed changes is that it is the intention to expedite the granting of more applications for the
building of new housing and also an intention that partiality is weighted in favour of developers to the detriment of local communities. This would, in effect, centralise
the planning process.NORA also is of the opinion that the proposed changes will produce some 300,000 new builds is based on erroneous data and this is
borne out by figures that the Office of National Statistics have published. Examination of these since 1949 show that the rise and fall in the number of
new builds is determined by the state of the national economy and there have been only seven years when the number of new builds has exceeded 200,000.
There is no correlation between the number built annually and the various relaxations of the planning regulations of the past decade. These have not, in
NORA's submission, have had any discernible effect on the number of new builds. Certain of the Permitted Development Rights have
allowed, and will allow, inappropriate building of and conversion of unsuitable accommodation and extensions which will lower standards and change the
character of many local communities.
2. How can the planning system ensure that buildings are beautiful and fit for purpose?
In too many instances the same designs of new builds are used, especially by large developers, so that traditional or local design and features are not
considered, thus making new developments invariably uniform and unimaginative. Good design reflecting, but not necessarily, copying local existing styles
is unfortunately infrequent.
NORA supports the Government's proposals to make design expectations more visual and predictable and it will expect design guidance and codes to be
repared locally with community involvement, and ensure that codes are more binding on decisions about development with the proviso that they are relevant
to their locality and planners stipulate their implementation. Attempts to digitise beauty is unworkable and, to quote, 'Beauty is in the eye of the
beholder' and cannot be quantified. Guides may help but codes are dehumanising. The Government's Report in January 2020 entitled 'Living with
Beauty' states 'Refuse Ugliness. Ugly buildings present a social cost that everyone is forced to bear. They destroy the sense of place, undermine
the spirit of community, and ensure that we are not at home in our world. Ugliness means buildings that are unadaptable, unhealthy and unsightly and which
violate the context in which they are placed. Preventing ugliness should be a primary purpose of the planning system.'.
It is also supportive of the establishment of the Government's proposal to create a new body to support design coding and building better places, and
that each authority should have a chief officer for design and place-making. However, but considers that centralising design is adverse, since it imposes
a central view when local views should be paramount. In taking into account proposed designs in planning applications for new builds, Planning Officers
should be trained in design and be able to take into their deliberation as to whether the proposed designs are attuned to and harmonious with the existing
surroundings. Therefore, NORA is greatly in favour that Local Planning Authorities should be required to appoint a locally led Chief Officer to administer
and approve the design evaluations. It is desirable, therefore, that the establishment of a new body which would be responsible for issuing the
appropriate guidance on the above.
3. What approach should be used to determine the housing need and requirement of a local authority?
NORA has two major concerns. The plans regarding desirable housing numbers do not appear to reflect the reality of developers' business plans or
express any concern for the 40% of the community who start their independent life in rented accommodation. Our conclusions on this aspect of the
proposals are based on studies of published ONS data.
NORA also is of the opinion that the proposed changes will produce some 300,000 new builds is based on erroneous data and this is borne out by figures
that the Office of National Statistics have published. Examination of these since 1949 show that the rise and fall in the number of new builds is
determined by the state of the national economy and there have been only seven years when the number of new builds has exceeded 200,000. There is no
correlation between the number built annually and the various relaxations of the planning regulations of the past decade. These have not, in NORA's
submission, have had any discernible effect on the number of new builds. Certain of the Permitted Development Rights have allowed, and will allow,
inappropriate building of and conversion of unsuitable accommodation and extensions which will lower standards and change the character of many local
NORA is of the opinion that the proposed changes within this consultation paper would, if implemented, result in a spate of applications below the
40-50 site affordable housing trigger. While this may in the short-term produce an increase in the supply of new houses, this may be at the expense of
the number of affordable houses. It is, therefore, to be of benefit to whosoever owns the land, be it an individual or a developer. The potential
home buyer will be at a considerable disadvantage in this.
NORA identifies that this reveals a defect in the Government's interpretation of the economics and the relationship between house building and the
value of land. In effect this demonstrates that the processes of calculation are at best erroneous and at worst is completely misleading.
While it is highly desirable that there is a sufficiency in the number of homes available for the first-time buyer, there is a divergence between the
price of affordable homes and the market value of the housing that is too expensive for people of limited means.
4. What is the best approach to ensure public engagement in the planning system? What role should modern technology and data play in this?
The main concern expressed by NORA members is the reduction in the involvement of residents in the decision making over planned changes in their
environment, and its apparent breach of the principles of the Localism Act. Access to information on planning applications should be simple. Local
Authorities' Planning websites currently allow searches by weekly or monthly lists of new applications which can be further filtered by Wards.
Community bodies such as Residents Associations or Amenity Societies carry out regular searches and inform their members accordingly by emails or by
posting the information on their websites or by email, although many residents do not have these facilities. For the individual resident, who may not be
a member of their Residents Association and who do not carry out their own personal searches, are at a disadvantage, often only learning about planning
applications in their immediate locality at the last minute or after a decision has been made.
It is suggested that Local Authorities introduce an 'alert' scheme, which registered subscribers would receive as notifications on their devices
of the latest weekly or monthly lists. These should be either by text or email, which is universal and receivable on all devices. Additionally a
notice displaying the details of the planning application should be posted on or near the subject property where the development is deemed to be of major
importance or having a major impact on the area.
All documentation contained in a planning application should be in the same format. The universally recognised format is the 'portable document
format', which is easily shared and printed. Today almost all computer users have a version of Adobe Reader or other program on their computer or other
device that can read these files. However, for instance, correspondence is often in different messaging programs which are sometimes indecipherable
unless that particular program is installed. Therefore, all documents should be converted to PDF. Social media such as Facebook, Twitter, Instagram,
Snapchat, and YouTube are not subscribed to by everyone and therefore they are unsuitable.
The Planning Portal: This is not user friendly and should be revamped. NORA members have complained that navigation to planning applications in their
area is difficult and that all documentation is required to be downloaded, saved and opened in the appropriate programme. This is time wasting and
inconvenient. This is especially applicable to those with devices that have limited storage. Documentation should be able to be viewed onscreen, with
the option of downloading and saving. The present system presents problems where there are numerous documents, sometimes several hundred in the case of
proposed major developments.
It should also be recognised that the use of internet accessible devices is not yet universal.
5. How can the planning system ensure adequate and reasonable protection for areas and buildings of environmental, historical, and architectural
NORA would emphasise that the preservation of historic and listed buildings is of paramount and significant importance. Sympathetic and creative
conversions and adaptations help preserve the significant character of our towns and cities. By so doing, this would ensure continuing maintenance of
these buildings and their use for the benefit and enjoyment of future generations.
6. What changes, if any, are needed to the green belt?
With such a variety of environments available, including land, the risk of building on floodplains, the consideration of local features, the nature of
community and local facilities to be taken into consideration, there is not any formula or no equivalence or algorithm that would produce a method that
NORA feels will be fair and reasonable. While planners may propose the development requirements, in reality, they remain the decision of the developer.
The Green Belt is good, positive planning. It stops urban sprawl and encourages the vital regeneration of our largest cities. It provides the countryside
next door to 30 million people and protects the setting of many of our historic settlements.
Preservation and protection of Green Belts is of major concern to residents. This policy aspires to prevent the urban sprawl which is reducing quality of
life in so many cities across the world. This unsustainable form of development swallows up farmland and wildlife habitats while increasing air pollution,
flood risk and car dependency. Green Belt represents the factor that the land is not fully developed. The Green Belts restrict the development of
buildings and houses. If this policy is removed then there will be no empty land to use for other purposes such as agriculture, park or roads. All the land
will be occupied by houses and buildings.
NORA opines that housing development applications on Green Belt land have more chance of being approved if the proposed site is an allocation in a local
authority's emerging plan, and/or if part of the site is already developed. The solution that should be pursued is the redevelopment of brownfield
sites of 'previously developed' land. Derelict sites within cities and close to their economic and social opportunities should not be ignored in
favour of cheaper or more convenient sites for developers.
7. What progress has been made since the Committee's 2018 report on capturing land value and how might the proposals improve outcomes? What further
steps might also be needed?
NORA does not see that there is an agreed methodology for calculating the amount of land value uplift retained by the landowner. The amount of uplift
returned to the landowner is mostly dependent upon the final sales price for the individual plot of land. The sales price will also be dependent on how
much the land sells for. This in turn is also dependent on who it is that will be buying the land and the associated tax structure that would be applied,
i.e. whether the purchaser would pay capital gains tax, corporation tax amongst others. MHCLG land value estimates are not reflective of the price paid for
land and a comparison between residential and agricultural land value estimates will not give an indication of the amount returned to the landowner.
The price at which a plot of undeveloped land is sold for may be significantly higher than the existing agricultural use value, this is because the market
price will also reflect the potential for the land to be developed at any given point in time.
For and on behalf of the National Organisation of Residents Associations
Alan Grant - Secretary