Memorandum by Places for People Group
THE PLANNING GREEN PAPER
The Places for People Group is a major residential
property owner and developer. Within the Group are Housing Associations
providing affordable housing for general and specific needs, companies
that provide homes for market rent and outright sale and companies
specialising in providing employment and training opportunities.
The Group owns and/or manages about 53,000 properties for rent
and shared ownership in over 200 Local Authority areas in England,
Scotland and Wales and has a substantial development programme.
We are a major customer of the planning process. We have submitted
a response to the Planning Green Paper to the DTLR.
2. THE PLACES
The whole purpose of the Group is to provide
sustainable places for people to live. This includes ensuring
access to all the services and facilities, including jobs, that
they need, not just providing housing. The Group's composition
has been developed so that all of the requirements of regeneration
and development of sustainable communities can be provided. We
are also involved in "Masterplanning" exercises for
major regeneration proposals where solutions will be delivered
by a variety of parties.
3. THE CURRENT
We agree with the Government's analysis that
the current planning system is largely failing to deliver. Quality
of service differs widely between authorities. Some are good,
others are not. The planning system is generally not trusted by
the public, and high profile cases recently re-enforce the view
that decisions are not always made in the best interest of the
local community. In particular, community consultation is not
effective either in the forward planning process, where it is
very difficult to galvanise opinion on strategic matters, or in
development control, where the vast majority of public involvement
is to object to development, rather than play a positive role
in the process.
4. THE GOVERNMENT'S
We generally support the Government's proposals
for change. Specific issues are noted below.
4.1. Reformed Local Planning Framework.
The proposals should work better than the current system, but
detailed guidance must be issued relating to periods for review,
timetables for production etc, to ensure that the plans remain
"live" documents as far as is possible. The position
of authorities during the period of change also needs to be clarifiedplans
on the current framework will need updating to avoid them becoming
4.2. The Role of Regional Planning Bodies.
The degree of effective democratic control; over these bodies
may be queried, but there certainly is a need for strategic planning
on a Regional and Sub-Regional basis.
4.3. The Procedures for major development
projects. (notewe comment on general development projects
as described in paragraphs 5.39-5.42, not major national infrastructure
projects). The proposal for pre-application consultation to replace
outline consents on significant development schemes is very positive.
Working up a proposal in partnership with the Authority, to a
clearly agreed brief and timetable would be of benefit. The agreement
of detailed proposals for community consultation would need to
be timetabled to avoid excessive delay. The role of Masterplanning
in these cases can be very beneficial. We are the "preferred
partners" in the Masterplanning exercise currently starting
at Walker Riverside in Newcastle and the approach there is a very
positive one. Masterplanning enables considered consultation and
the use of techniques such as "Planning for Real" that
facilitate positive engagement by members of the community. Particular
skills are needed for Masterplanning and the trust of the local
community and developers is vital. We contend that such exercises
are more likely to be fruitful if led by parties out with the
Local Authority. Bodies such as major RSLs have both the development
and community consultation skills (in-house or with others) needed
and can be seen as separate from the Local Authority and developers,
so can establish a position of neutrality early in the process.
We understand the need to balance the different pressures in the
process, and, most significantly, we are used to being interested
in the sustainability of the outcome in the longer term.
4.4 Changes to Planning Obligations. The
intention to improve the transparency of the process is welcomed.
The Tariff system seems to be the best or the options outlined.
Local flexibility must be given, but the policies of each LA must
be clearly set out so that developers and the public have confidence
in the system. Some benchmarking on the way flexibility is used
might be useful. Accounting for the use of the obligation "income"
is vital. The emphasis on provision of affordable housing as a
first choice where demand is high is welcomebut realistic
demand analysis is needed. Where affordable housing is provided,
authorities should have the ablity to specify the tenure of the
housing to be provided (rent, shared ownership or sale) and to
specify in high demand areas that it should be managed by a regulated
landlord to ensure it stays "affordable"first
sales at initial discounts do little to assist the lower paid
when they get sold on in a rising open market.
We strongly support the concept of mixed tenure
communities and so would support strong guidance that affordable
housing is to be provided "on site" wherever feasible.
In higher demand areas, it is the ability to access sites that
compromises ability to deliver affordable housing, so a "cash"
obligation might not be beneficial. Where RSLs are used to deliver
an affordable housing element, they should be involved in the
process from an early stagetoo often the "affordable
element" is decided late in the day, and the recipient RSL
has no influence on location on the site, built form or environs.
All of these can have a significant impact on sustainability.
We do NOT generally support the idea floated in paragraph 4.24
that whole sites might be reserved for affordable housing. This
might be appropriate for small sites in a few high demand areas
where affordable housing is very scarce and the wider neighbourhood
of mixed character will result, but our approach is that for sites
of any significance, a mixture of tenures on the site is more
4.5 Compulsory Purchase Orders. The proposals
are generally helpful. CPOs for planning purposes will be needed
to assist area regeneration. The use of a "loss" payment
over market value will assist the process, but the extra cost
should not be borne by the subsequent development proposals if
it will exceed the site value.
4.6 Effects of changes. There is much detail
yet to be resolved, but generally we believe the changes have
the potential to deliver more certainty and faster decisions.
The decisions should also be better ones if the detailed implementation
is correct. The potential is there for better public consultation,
but winning the trust of the public will not be an easy process.
In particular, the proposals for involvement in major infrastructure
decisions will need to be sensitively managed.
4.7 Planning's contribution to the urban
renaissance. In general, the planning process has been a brake
on development and regeneration of many urban areas. Under-resourcing
and ineffective systems have meant that effort has had to be concentrated
in development control, which is totally reactive, rather than
in active forward planning, partnership building and focused regeneration
activity. If the proposed changes can deliver a speedier and more
effective development control system and a more responsive and
flexible forward planning process, planning could play a positive
role in the much-needed urban renaissance. But it will only be
able to achieve this if it is properly resourced and officers
and members engage with communities. The statutory role of planning
in determining applications and the advocacy and community capacity
building roles may conflict with each other. The catalyst and
promoter of regeneration and renaissance may need to be a third
party, as has proved fruitful in the Masterplanning exercises
Group Chief Executive
Gp Director, Procurement and Development
Strategy and Support Manager