Like everyone working in the Built Environment in England, Prior + Partners have read with great interest the proposed reforms to the planning system set out in Planning for the Future.
In principle we welcome a number of the proposed reforms proposed, particularly regarding reform to the Local Plan process, and the much greater emphasis on design outcomes. However, we consider there are a number of areas requiring further consideration. Our summarised thoughts on a reformed planning system are outlined below, and available in more details in our full response available here[TC1] .
Prior + Partners are of the opinion that the reformed planning system should:
Ensure effective, cross local-authority boundary strategic planning: Existing replacement measures have proved to be an inadequate substitute for the pre-existing regional planning system, with the Duty-to-Co-operate failing to recognise and incorporate the function of (often complex) functional economic areas and are compounded by the lack of explicit role of Local Enterprise Partnerships. In light of this, Prior + Partners advocates for the creation of a national spatial plan, as proposed by the UK2070 Commission (led by Sir Bob Kerslake).
Recognise that role that planning needs to play beyond housing delivery in moving toward a zero carbon future, the “Green Economy” and combating ecological breakdown. Given the increasing importance of the planning system in ensuring the delivery of climate change resilient and net zero carbon ready homes, a reformed system should be advocating for a climate-positive approach to development wherever possible, in order to support UK government legislation to bring all greenhouse gas emissions to net zero by 2050.
Uphold local contextualisation through the streamlining of the Local Plan process: At this point in time, it is not clear how national government consideration and understanding of constraints to housing delivery could replace the level of inherent knowledge possessed at the Local Authority officer level. National development management content, whilst welcome on a number of typical issues, should also include an annex on locally specific policies (focussing solely on issues that are wholly unique to a local area such as local views, local Green Belt or locally specific economic land policies, for example) allowing production of policy to be sped up.
Require high-level masterplanning design work to be completed upfront, helping ensure the intrinsic sustainability of development proposals: Prior + Partners would fully support the development of a consolidated test for “sustainable development” whereby a well-developed concept plan and masterplan proposals are subjected to a shortened test of soundness at the plan-making stage, appropriately considering mitigation and with a view to achieving sustainability, to ensure proposals are positively prepared, justified in context and deliverable. Whilst in the case of smaller scale development the production of this evidence base can be frontloaded by Developers, in the case of larger-scale, strategic developments (for example in the case of major growth areas), we propose that some level of additional public resource such as access to a funding stream should be provided to help de-risk early stage design work carried out by the Local Authority. This will help to ensure that large-scale strategic development in growth areas with potential for significant public benefit will still come forward, inline with the Dutch VINEX policy.
Provide greater certainty to developers to encourage them to invest in projects that will make truly excellent places: In order to attract large-scale investors / developers with capital to engage with a vision-led approach, the Local Plan system needs to be able to be able to provide certainty for investors. Although we do not agree that these growth areas should be provided with automatic permission in principle, given our concerns that this could potentially permit poor quality development, we promote a ‘permission to build’ approach, whereby the principle of development in an area is established but the quality of development must subsequently be agreed through the creation of a detailed masterplan, design codes, and other work that might (in the present system) be submitted to support a major Outline Planning Application.
Raise the influence of design quality in planning policy and encourage code-led growth: Prior + Partners fully supports proposals to establish a new body to support the development of design codes, design guides and policy for better placemaking and warmly welcome a stronger role for Homes England in the delivery of design objectives which embed sustainability principles in all development that they enable. Whilst we support a system whereby the planning system places value on understanding the best way to accommodate growth and intensification in a sensitive way, at present proposals to implement a ‘fast-track for beauty’ offer little detail by way of defining the mechanism by which ‘beauty’ would be defined. Without clear, objective criteria (such as locally-defined design guidance, character studies or design coding), it would be extremely difficult to prove what proposed development can be defined as ‘beautiful’ and therefore the practice cannot support the proposal in its current form.
Properly support Neighbourhood forums to help lead locally-led growth and identify material attributes of what a well-designed place in the local context would look like: We are concerned that at present, proposals in the White Paper present a greatly diminished role for Neighbourhood Forums, which is to the detriment of the ambitions of the Localism Act 2011. Beyond settlement scale and the creation of local design guides, Prior + Partners advocates for the creation of design codes at the neighbourhood and site level. Individual Neighbourhood Forums could supplement Local Authority resources (if appropriately supported from a technical perspective) to help develop locally led design guidance and codes to help steer site specific growth through an appropriately reformed system of Neighbourhood Plans. As part of this, Prior + Partners asserts that an appropriate model for disseminating funding, expertise and technical capacity to Neighbourhood Forums should be set up, for example via a specific funding stream and/or tender process that facilitates the use of SME design firms.
Provide much more consideration to how we best deliver the next era of new communities: In the long run, the most sustainable communities may be delivered beyond a single plan period and require enabling infrastructure[TC2] . Prior + Partners believe that truly successful new communities and major regeneration projects are achieved through the creation of good, flexible masterplans, accompanied by appropriate design guidelines and codes, and supported in the delivery of infrastructure which is considered fairly during any test of soundness.
Acknowledge that in most cases it impossible to deliver significant levels of new housing without investment in infrastructure: Community objection to new projects is often based around a perception that enabling infrastructure for development (notably transport and social infrastructure) will not be delivered on time, or at all. In order to address this and better reflect community preferences about design, this Planning White Paper should consider the feasibility of developing a national bank for sustainable communities; for example by exploring the potential to extend the Treasury’s large infrastructure guarantee scheme.
Ensure that Infrastructure funding methods and planning obligations must remain nuanced and balanced to secure adequate infrastructure and provision of community facilities without impacting development viability: Opportunities to make the planning obligation system much more predictable should be welcomed, especially when this allows for more robustly evidence agenda setting for Local Authorities and certainty for site promoters of all scales earlier in the process. However, whilst there are many complexities, difficulties and time delays associated with the current system of capture, this is because it must, through mutual agreement, adequately balance a number of often competing elements. A significant level of nuance is captured in this process, whether through prioritisation of infrastructure, phasing considerations or other pragmatic caveats to included commitments and the implementation of effective mitigation, which may not be captured in the revised system as proposed. It is clear that site specific solutions, bespoke to local context, and responsive to site needs and values will often be the most appropriate mechanism for capturing uplift without stifling development. It should also be reiterated that S106 planning obligations extend far beyond a purely infrastructure funding role and act as an important source of clarity and control, notably on stewardship and maintenance, on delivery for both Local Authorities and applicants.
Develop an accessible and understandable planning system which advocates for places and communities that are intrinsically sustainable through design: As a practice, we assert that engaging early in collaborative, engaged masterplanning and design work should be an essential part of the planning process and focus on places which deliver on future-proofed infrastructure, excellent public transport, sustainable buildings and well-designed open spaces. The ambition to make planning more accessible and understandable for all will play an important role in democratising the planning system moving forward, helping to deliver on one of the core values of the localism agenda. The uptake of PlanTech and the use of tools and techniques to better illustrate design outcomes are useful tools in helping to communicate proposals, and should be an increasingly important part of community consultation moving forward.
Support a quick transition towards a planning system that is design-led, with a focus on delivering vision-led development designed around clear spatial frameworks from the site-scale to the regional and national scale. Further detail on how the high-quality design and placemaking outcomes central to the proposals can be achieved should be outlined before reform is implemented. In order to achieve the adoption of Local Plans with a 30 month time frame there needs to be much more thinking and clarity around the proportionate evidence base and assessment that would be required. It must also not be underestimated that the timescales for fair and robust engagement alongside time to synthesise responses is a significant part of the process and without additional capacity and resource funding such timescales are going to remain very ambitious. Any amendment to the Local Plan system should therefore provide a suitably long transition period to allow Local Authorities the requisite time to reallocate resources and avoid short-term reductions in housing delivery.
Prior + Partners are committed to providing their technical expertise and lessons from practical application throughout the development of these proposals to ensure that the aims and ethos of reform are met without unintended consequences. If you are interested in joining the conversation, have thoughts on next steps or have any questions on what this means for your project or proposal, please let us know.