The Government's consultation supposedly sets out measures to ‘improve the effectiveness of the current planning system’. We are most concerned about two of the four main proposals:
- Changes to the Standard Method for assessing local housing need - which will generate astronomical new housing numbers for many Sussex districts
- Extending the current Permission in Principle to major development - which could grant automatic planning permission for whole new towns and villages
Sussex Wildlife Trust has objected to these proposals - read our response: Final SWT response to changes to the current planning system sept2020
This consultation has now closed but you can still comment on the Planning White Paper.
The proposals in more detail
1. Changes to the Standard Method
We recommended answering consultation Question 1
The housing ‘need’ of an area is decided by a complicated system whereby a national equation called the Standard Method sets out how many homes a local planning authority needs to plan for. The Government says that councils can plan for fewer homes if there are constraints, such as half the district being in a National Park, but in reality the numbers hardly ever go down or the ‘unmet need’ of one council is passed onto their neighbouring authority.
We don’t like the way the current numbers are calculated as they don’t take into account the the environmental capacity needed to absorb and support this level of development - for example, the extra greenfield land taken, the extra drinking water needed and all the new roads built to serve new homes in car-dependent locations.
The Government's proposed changes to the Standard Method will see astronomical increases in housing numbers for some Sussex districts:
- Arun will go from 1,368 per year to 2,063 (+51%)
- Horsham from 920 per year to 1715 (+86%)
- Rother from 736 per year to 1173 (+59%)
- Brighton & Hove from 924 per year to 1520 (+65%)
For other districts, the housing number will stay the same or go down - but there may be a requirement for these districts to take housing from neighbouring districts that can’t deliver their quota. For example, 80% of Rother is in the High Weald Area of Outstanding Natural Beauty (AONB) and therefore has different housing requirements. Whilst Wealden’s housing need is 1,199 under the new system (down from 1,225) they may well have to take on some of Rother’s under-delivery.
We believe the housing numbers proposed by the new system are unachievable for most local councils and developers, resulting in Local Plans failing to meet their housing targets. In this situation local planning authorities have much less say on the types and location of development that goes head. It plays into the hands of speculative developers and creates barriers to the creation of strategic networks for wildlife, where nature is fully integrated into new development.
These changes could be adopted very quickly and will immediately impact the planning system for the next few years.
2. Permission in Principle (PiP)
We recommended answering consultation Question 24
PiP is a system that allows developers to find out whether a site would be suitable for residential development before spending money on surveys to find out what the biodiversity value of the site is, how the site might be accessed and what the flood risk might be. The developer must submit an application that simply states the location of the site, with a map, and the minimum and maximum number of dwellings they would like to build. From the day after receiving the application, the council has just five weeks to decide if PiP should be granted. If it is, then the developers have to supply more detailed information in order to get full planning permission. Currently, PiP is only allowed for applications on small sites that support fewer than ten dwellings. The Government want to change this to allow permission in principle for larger developments.
Sussex Wildlife Trust does not support this because:
- The Government says that councils should use historic ecological records to inform decision-making, but this is not sufficient - up-to-date site surveys should be required
- There is no requirement for any ecological information at the application stage, which risks setting a principle for development on sites that are really important for wildlife and/or key components of a Nature Recovery Network
- PiP will most likely be used for unallocated sites (i.e. sites that have not been allocated for development in the Local Plan) and once PiP is granted, the developer has five years to put in the further detail like the mix and size of homes. This means it will be really hard for councils to plan for the extra infrastructure needed, including green infrastructure
- With no ecological information, councils can’t know that net gains to biodiversity can be delivered
- Five weeks is not long enough for a council to decide whether a site is suitable for potentially hundreds of homes, especially when they don’t have any detailed information to inform their decision
- The consultation period for local people, stakeholders and even statutory consultees like the Environment Agency is very short. We don’t think it’s enough time to make an informed decision and it will be really easy for applications to be missed
- There is no way of assessing the cumulative impacts of lots of PiP sites, as councils won’t know how many people will be living there or when the homes might be occupied
How can I respond to the consultation?
Changes to the Current Planning System
This consultation has now closed - thank you for taking the time to respond