Residents might be interested to read the response submitted by Holmes Chapel Parish Council in response to the 'Planning for the Future' consultation from the Government, which closed on 29th October 2020. Information about the the consultation can be found by clicking the following link:
The following is the response submitted to the consultation by the Parish Council:
Holmes Chapel Parish Council resolves to respond as follows to the request for comments to the government’s consultation on the “Planning for the Future” paper.
Introduction
The Parish Council recognises that it is only one of many thousands of parish and town councils around the country and of course there are many Local Authorities that have a primary responsibility for planning in their area. It is hoped that many of these responsible authorities will respond and that the government will acknowledge and respond accordingly and not pursue the framework and proposals as described for “Planning for the Future” without significant amendment.
There are limited parts of the proposals with which we agree. These include speeding up the process of planning. But a good planning process requires looking at an area holistically and for the longer term, rather than just a short term ‘political’ effort which is not based on empirical evidence.
Our local authority, Cheshire East, is responding to this consultation and we support their many points.
There seems to be a thread that runs through all of the proposals that says that ‘one size fits all’ and that the local authorities do not have the ability or knowledge to consider what is best for their communities. There also seems to be a theme that removes any local democratic engagement, with the proposals relying on unsupported ‘algorithms’ to come up with housing numbers which are not related to meeting local need.
The proposals appear to be aimed at satisfying a perceived short-term requirement for more houses to meet a political agenda, rather than delivering a long term strategically planned outcome for each local community and the country. What is built today will be around for many years and it is essential that any planning must recognise this.
There seems extraordinarily little in the proposals for proper consideration of the infrastructure needs of communities in future planning. These include roads, public transport, schools and further education, social and health services, and other community facilities such as parks and open space.
It is of high concern that there is no attempt in the proposals to resolve the position across the country now, that there are already over 1,000,000 homes that have planning permission and remain unbuilt. If it is recognised that the country is already building over 200,000 homes per year, then ensuring that developers address these approved applications in addition to what is already being approved would meet the arbitrary target of 300,000 homes per year.
The issue is not that more houses are required; the issue is ensuring that developers build what has been approved. Government seems unable to identify when, where & why new homes are required. This should be addressed before any change to the planning system. The proposed blanket categorisation of development zones does not address this.
Developers manage build rates to maximise profits, not Government targets. The proposals appear to be a ‘developers’ charter’ with extremely limited input or sense behind the principles of planning. It is disappointing to see such proposals as these which ignore any opportunity for local communities to have a say.
The proposed simplification of Neighbourhood Plans appears to ignore the time and effort spent by communities in developing the current Neighbourhood Plans. The huge costs and volunteer effort associated with creating Local Plans and Neighbourhood Plans must not be side-lined. Paying lip service to this effort would be a travesty, as well as a huge waste of work, money, and talent.
Many local authorities, including Cheshire East, have a Local Plan. This was ‘made’ in 2017 but these new proposals suggest that this legally prepared plan is to be ignored with the Plan being reworked but under much more restrictive processes.
The theme of the report “Living with Beauty” produced by the Building Better, Building Beautiful Commission in January 2020 provides many of the points we and many others feel about how planning in the future should be conducted. Holmes Chapel Parish Council fully supports all the proposals and recommendations in this document and government must take these into account in any possible future changes. At the least, we would want this to be included as an essential and legal framework behind the National Planning Policy Framework.
Holmes Chapel also supports all the comments presented by the National Association of Local Councils (NALC) in their paper “PR10-20 Changes to the Current Planning System”. Any proposed changes in the planning system must form part of the Planning for the Future deliberations and not treated in isolation.
This must include any calculations for new properties, and not ignore all Office for National Statistics (ONS) data on a projected decline in population. Cheshire East is a largely rural community and Holmes Chapel has already suffered unsustainable growth in housing of 35% in the last ten years, with no appreciable attempts to meet infrastructure needs. Allowing central government to dictate housing numbers based on no local evidence and with unsustainable facilities and services is not ‘planning for the future’ and our current and future residents will be more than upset about the uncaring attitude presented by these proposals.
Specific comments
We are not replying to the online questionnaire as it appears to have been written in such a manner as to attempt to support the proposals and we disagree with the proposals as structured. General points on the proposals are as follows.
1. Currently the UK planning system takes a discretionary approach. This means that a proposed development is not automatically given permission based on its match with the policies in the plans made by local councils. Each scheme is assessed by local planning authorities on a case-by-case basis before planning permission is granted based on needs and requirements of the area. These proposals fundamentally change the approach.
2. The proposals suggest an approach based on zoning land for development. Under this approach, there is no debate about the advantages and disadvantages of a particular scheme, just the general principles governing development in an area. This is intended to create certainty for the development industry and ignores completely any fundamental aspects of need in a community. Some questions on these zones are:
a. Who decides on the zoning and what independent appeal procedures will there be?
b. How can zoning be changed when local circumstances demand.
c. Would open countryside and green spaces be automatically in the ‘protected’ zones?
d. What enforcement will be used to ensure there is a balance between ‘growth’ and ‘renewal’?
e. Renewal would mainly relate to brownfield sites, where the costs of remediation would be far higher and would certainly not be the higher choice for developers.
f. Developers should be required to build on brownfield sites as a condition of obtaining planning permission for green space development.
3. The proposals say that greater use would be made of digital technology, with maps showing which rules apply to any particular site. It is also proposed to engage with the public in a much more digital way when preparing plans and considering development proposals. But this may preclude many residents who are not so digitally inclined, and the proposals makes no mention of how planning can be inclusive.
4. The current system sees local authorities negotiate the contribution that a developer makes towards affordable housing and local infrastructure on a case-by-case basis. It is proposed that this would be replaced by a standardised National Infrastructure Tariff. By doing so, it comes back again to the ‘one size fits all’ principle which does not meet local needs.
5. The current system is over complex. Much needed simplification does not need the proposed degree of change.
6. The proposals will lead to a loss of democratic accountability. Communities have enough difficulty understanding the current planning application process. Trying to envisage the scope and scale of developments, as proposed will create huge difficulties, potentially leading to inappropriate, poor quality developments which will adversely affect local communities.
7. Planning policy is not and should not be about primarily building more and more houses. It needs to focus on how communities can be developed in a holistic way to both deliver new homes and create cohesive communities. Simply allocating more land to build houses without local connections is doomed to long-term failure - how do new developments link into existing homes and their structure -the proposals need to look at all aspects of growth, not just housing.
8. The present system, whilst complex, is now delivering new homes in many parts of the country at pace. This is the wrong time to disrupt what has taken time to create but is now working well. Simplification of some elements would be a far better approach than the current proposals.
9. This Parish Council’s experience of developers is that their motivation is simply profits, with little or no regard for local communities. A statutory financial contribution absolves them of any adverse consequences of their development, from which they simply walk away once building has completed. The current proposals can only make this problem even more acute as developers will be even more remote from local accountability and influence.
10. The move towards working from home will mean vacant office space becoming available for conversion to residential accommodation. This should be encouraged as it will fulfil housing need and revitalise city/town centres.
11. There is a conflict between the need for the smaller houses which people without homes can afford and the larger houses which developers want to build to maximise their profit. The Government’s near total reliance on private developers to satisfy housing need is thus inherently flawed (see next point as well). There should be stronger policies and resources in place to deliver more social housing.
12. Streamlining the planning system alone will not satisfy the housing need if the houses are not built. More approvals will not mean more houses if the developers simply land bank them. Further planning applications should not be approved for developers who have not progressed the approvals they have already got.
13. It is good that the Government wants to retain Neighbourhood Plans. But Neighbourhood Plans should not exist merely to pay lip service to local democracy. The purpose of Neighbourhood Plans should not simply be to facilitate more development. They must have the legal force to prevent development which does not meet local need and/or is unsuitable in its location or design.
14. Neighbourhood Plans should not be regarded as inferior to, or less important than, Local Plans.
15. Neighbourhood Plans should be complied with. If a proposal is in clear breach of a policy which states that something is unacceptable, then it should be refused, even it is acceptable in other respects.
16. More development without the infrastructure to support it is not building communities, but just houses.
17. The provision of additional resources and services should take place at the time of the development, not after it.
18. The NIL proposal to replace S106 money is meaningless unless there are the processes and practical means in place to make use of it. And again, a one-size-fits-all is completely inappropriate with different needs between urban and rural areas. Otherwise, the money is just an admin fee paid by the developer to the LPS to get planning permission.
19. The possibility of our housing requirement being imposed by Central Government is inconsistent with the devolution agenda. The recent appeal decision by the Minister in the Muller case at Stapeley in Cheshire East demonstrates that Government cannot be trusted to make decisions which are in conformance with the Local Plan or acceptable to the community.
20. A flat rate CIL charge might not reflect local circumstances. For example, the Bloor Homes development on London Road Holmes Chapel, generated a highways contribution of £550,000 for a roundabout to replace the traffic lights. Would we have got anything like this amount if a flat rate applied? Furthermore, there is nothing to suggest that the NIL will be tied to the area which generated it and there is every possibility that the Local Authority would prioritise infrastructure enhancement in the principal towns and key service centres. The recent New Homes Bonus Community Fund produced nothing for Holmes Chapel notwithstanding the number of new homes built here.
Summary
Holmes Chapel Parish Council opposes the proposals presented in the ‘Planning for the Future’ consultation. They make planning undemocratic, are not based on local need, are not supplemented with corresponding ‘rules’ on new infrastructure requirements and make no sense on satisfying local need.
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