the Government’s White Paper on proposals for the reform of the planning system in

England.

The current local strategic planning system is failing in its need to be comprehensible

to the general public. We agree that Local Plans should be simplified.

But not at the cost of genuine public involvement, and robust, locally appropriate

development plans. In the best case, we believe it is possible the proposals included in the

Government’s White Paper could create development plans that are responsive to local

needs and concerns, deliver beautiful, well-built and designed homes and communities, and

protect the natural environment.

Yet we are concerned about the worst-case scenario: that these proposals would lead

to Local Plans promoting large scale, ill-considered developments that do not respond

to the wishes of the existing community, and which do not allow for nuance and

variation within the existing built-up and green areas of our rural district.

We are anxious that Local Plans need to be based on solid data, subject to genuine

consultation with local communities, and robust enough to stand up to legal challenge.

We welcome the early input of residents proposed in this White Paper, but consultation

also needs to be possible at a later stage of development - and it should be made

clear to residents how much impact they can expect to have at each stage.

We do not support the proposal to fast track ‘beautiful’ design. We believe that all

buildings should be designed and built to be as handsome as possible. We are

sceptical that local planning authorities - or, worse, a centralised national body - can

pre-determine ‘beautiful design’. We fear that would be too prescriptive.

Architecture has to be appropriate to the precise location and topography - and that cannot

be prescribed by a kind of design algorithm.

Perhaps our greatest concern about these proposals relates to the scale of

development that may be imposed upon our rural district. We do not have faith

in a centrally devised algorithm calculating housing numbers in our district. We are pleased

that, since the consultation closed, the Government has announced it is revising the

proposal for a growth algorithm; and we await more information on this with keen interest.

All our subsequent comments should be read with this strong reservation in mind.

Subject to local planning authorities having adequate time and resources, we are open-

minded about the concept of identifying Growth areas. But we are very concerned that the

30-month timeframe is not adequate. We still believe that the new settlements they comprise

must be subject to close scrutiny from the local planning authority. As we accept the need

for new homes in this cycle, we welcome the ambition of speeding up development in sites

identified for housing growth. But by both significantly curtailing the process for identifying

those sites and then also significantly

streamlining the process for giving planning approval,

we are concerned that these proposals will lead to a loss of local expertise and democratic

oversight. Speed must not compromise quality.

The proposals for Renewal areas are problematic for us, and we would need to see

more detail about how they might work in our market towns and villages before we could

support them. We would resist suggestions about the ‘statutory presumption in favour of

development being granted’ as this indicates little or no detailed planning permission would

be required. Yet we know that building development within existing settlements inevitably

impacts on existing residents, and that permitted development already causes resentment

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and anger. Residents’ opinions about the detail of proposed development need to be taken

into account. If Renewal areas are to be included in the final proposal of these reforms, the

areas would need to be identified in the Local Plan with great detail.

The proposals for securing planning permission in ‘Protected’ areas seem appropriate.

More practically, we are nervous that the massive changes proposed in this White

Paper would just not be manageable in the timeframe envisaged here. We question

how long it would take local planning authorities to develop the expertise, and for the

various digital technologies to be embedded and sufficiently tested. And we fear that

any shortcomings that come from applying the new systems too quickly would leave

all parties exposed to lengthy and expensive legal challenge, and local communities at

risk of unsustainable development.

While we welcome the proposal to allow for some of the uplift in the value of land

designated for development to be levied by the local authority to pay for

infrastructure, we are disappointed that the White Paper is silent on powers the local

planning authority might have to encourage developers to build-out sites on which

they have planning consent.