by Jess Price
Please take action now to respond to the Government consultation on changes to the current planning system - which closes at 23.45 on Thursday 1st October 2020.
These proposed changes might look small but they will have huge impacts for wildlife and people in Sussex. You can read the Sussex Wildlife Trust’s response here to help you with your own, and we have summarised our main concerns below:
Changes to the standard methodology – Question 1
This will see an even bigger drive for new housing with astronomical new targets for house-building in many Sussex districts - without taking into account our environmental limits.
- This will not deliver additional houses, just additional housing figures. The methodology assumes that by forcing local councils to plan for unrealistic numbers of new homes, developers will build so many that the value of their own product will not rise any further. However, the Government commissioned an independent review – The Letwin Review – which show that increasing supply is not the problem. In fact, there are nearly a million homes with planning permission that haven’t been built yet.
- Using the baseline data as suggested in the changes will result in a self-perpetuating situation where councils with high rates of house building in the recent past are made to continue that level of delivery in perpetuity. Continuous growth is clearly not compatible with the principles of sustainable development, especially when there is currently little opportunity for councils to require new homes to contribute sufficiently to net zero targets.
- The new numbers clearly cannot be accommodated in a sustainable way – there is no consideration of the environmental capacity needed to absorb this level of development e.g. drinking water, clean air, access to nature. The standard methodology should allow councils to adjust numbers based on local conditions and particularly recognised ecological assets. This must include components of the Nature Recovery Network and particularly sites with potential to contribute to nature’s recovery.
- When councils fail to meet their housing targets they are punished by having less control on what development is acceptable for their local needs. In our experience, this results in unplanned development in unsustainable, car-dependent locations, that do nothing in terms of delivering nature on people’s doorsteps. It also creates physical barriers to the development of a Nature Recovery Network and perpetuates unhealthy, nature deprived lifestyles.
- The way the affordability ratio is calculated assumes that people in Sussex live and work in the same council area. This is not the case, since many people commute for work.
Extension to Permission in Principle (PiP) - Question 24
Currently, PiP is only allowed for applications on small sites that support fewer than ten dwellings - but the Government wants to change this to allow permission in principle for much larger developments.
- We are very concerned that the changes to PiP will result in sites of high value for nature being destroyed by development, as well as opportunities to contribute to natures recovery being lost. The Government's 25 Year Environment Plan is clear that a Nature Recovery Network (NRN) must be created to protect and restore wildlife. How a site can contribute to the NRN can only be determined with a site survey to assess its current and potential ecological value. This information cannot be left until the technical detail application stage as by then the minimum number of dwellings to be accommodated on the site has already been set. Sustainable development cannot be achieved when permission for the principle of development is given with no understanding of what the impacts of development on that site might be.
- Current Sussex local plans are not yet informed by Local Nature Recovery Strategies and have often been adopted with an insufficient ecological evidence base. Whilst a useful starting point, historic environmental records cannot replace on-the-ground survey data.
- Allowing PiP for major development is not compatible with the requirement in paragraph 170 of the National Planning Policy Framework (NPPF) to provide net gains to biodiversity. It is clear that the Defra biodiversity net gain metric cannot be employed without a site survey and therefore it is not possible to know whether a site can in fact deliver a net gain at the PiP stage.
- There is no ability to assess the cumulative impacts of developing PiP sites as so little information is provided at the application stage. Stating only a maximum and minimum number of dwellings provides no information on the number of residents that will move into a site and therefore councils can make no estimates of the impacts this development may have in terms of transport, water use and access to local green spaces. As PiP is valid for five years before more detail must be provided, we are concerned that multiple large sites could be given PiP that will ultimately exceed the environmental capacity of an area.
- The consultation document notes in paragraph 118 that currently some councils are ‘wrongly’ continuing to make PiP decisions based on detailed matters. However, we see this as an indication that LPAs understand that you have to consider some basic principles when determining whether a site is suitable for development and this requires site-specific information. Any application for PiP should be accompanied by a Preliminary Ecological Appraisal and a determination of how a net gain to biodiversity will be delivered.
- The very short consultation period associated with PiP means it is much easier for an application to be missed simply because someone is on holiday. We are also concerned that expanding PiP to major development will add even more pressure onto statutory consultees, shortening timeframes for response without providing any additional resource or capacity. This will do nothing to help provide certainty to developers as issues will be raised at the technical details stage which should have been addressed at the PiP stage.
Click here to respond to the consultation: Changes to the Current Planning System
We recommend answering Question 1 (Standard Method) and Question 24 (Permission in Principle)
Please take action today - thank you