Response to government consultation: 'Planning for the Future'
The government have been consulting on a White Paper which outlines a major shake-up of the UK's planning system. Cornwall Green Party assembled a team of expert members to provide the following response. The consultation was structured with questions, so our response is laid out with brief notes on context for each section, the questions asked by the government, and our answers.
Pillar One – Planning for Development
Summary of key proposals:
- shorter plan making and decision-making timetables
- transition to a land classification system for areas of growth, renewal and protection
- automatic outline permissions for new sites in growth areas and extended permitted development rights in renewal areas
- retention of planning permission requirements in the countryside and protected areas
1. What three words do you associate most with the planning system in England?
- imbalanced (in favour of the developer)
Policies need to be 21st century: zero carbon by default, prioritising de-growth and regeneration of nature.
2. Do you get involved with planning decisions in your local area? [Yes / No]
2(a). If no, why not? [Don’t know how to / It takes too long / It’s too complicated / I don’t care / Other – please specify]
Yes. This response is written by residents and elected Green Party parish and town councillors of Cornwall.
3. Our proposals will make it much easier to access plans and contribute your views to planning decisions. How would you like to find out about plans and planning proposals in the future? [Social media / Online news / Newspaper / By post / Other – please specify]
These proposals do not make it easier to contribute to planning decisions. These proposals ask for contributions at the stage of plan making. Cornwall Green Party’s elected councillor’s experience of creating local and neighbourhood plans confirm that the public are uninterested and reluctant to be involved in long-term planning and are easier to engage in individual planning applications. Whilst agreeing that planning applications are unduly complex, sometimes including hundreds of documents, Cornwall Green Party believe the complexity is the responsibility of developers who crowd the planning process with excessive maps and convoluted language in order to deter criticism from the general public. Cornwall Green Party would welcome a simplification of the planning system so everyone can read and understand applications, design codes etc., but are cautious about building in a digital divide.
Some of Cornwall’s residents are less likely to see plans on social media or digital platforms than through traditional methods. Currently planning applications are notified via Cornwall Council’s website (all digital), notices placed in the local newspaper, green notices placed on local lampposts and often as hard copies in the offices of parish and town councils.
Cornwall Green Party recommend continuing with traditional methods to advertise planning applications whilst simplifying and improving digital services.
4. What are your top three priorities for planning in your local area? [Building homes for young people / building homes for the homeless / Protection of green spaces / The environment, biodiversity and action on climate change / Increasing the affordability of housing / The design of new homes and places / Supporting the high street / Supporting the local economy / More or better local infrastructure / Protection of existing heritage buildings or areas / Other – please specify]
- Action on Climate Change
- Action on regeneration of nature and biodiversity
- Affordability of rental and self-owned homes in Cornwall
5. Do you agree that Local Plans should be simplified in line with our proposals? [Yes / No / Not sure. Please provide supporting statement.
Government Proposal 1: The role of land use plans should be simplified. We propose that Local Plans should identify three types of land – Growth areas suitable for substantial development, Renewal areas suitable for development, and areas that are Protected.
No. Cornwall Green Party does not agree with these proposals and the simplification of Local Plans to provide zones for Growth, Renewal and Protection.
Cornwall Green Party believes these proposals are unable to reflect the complexity of the Cornish landscape; they will be detrimental to the Cornish environment and will dilute local democracy.
Cornwall has a distinct landscape in which small towns, villages, hamlets, farms and small holdings are scattered amongst the historic backdrop of mining and agriculture. The average size of a smallholder plot in Cornwall is 4 to 12 acres. This means Cornwall has scattered and continual habitation from the Tamar to Lands End.
It will be difficult and complex to assign zones in these historic and agricultural areas without damaging the viability and dynamism of Cornwall’s rural communities. The protections already afforded by the AONB and the World Heritage Site stifle development within these areas as homeowners and developers struggle to comply and afford the conditions tied to their planning applications. The nature of Cornwall’s built environment, which is scattered and diverse will require planning consideration on a site to site basis rather than a wholesale assignation of a ‘protection’ zone. Development must continue in rural areas and assigning areas throughout a multitude of small hamlets and villages will complicate not simplify the system. The current proposals do not clarify how rural areas can be zoned into growth, renewal or protection.
The government must also be mindful that areas of Cornwall are sparsely populated and not even represented by parish councils. Cornwall’s remote and smaller communities have parish meetings, not elected councillors. Consequently, over 50% of Cornwall’s communities do not have the resources to develop Neighbourhood Plans or be effectively included in Local Plans, leaving these villages and hamlets unprotected from excess and unwanted development.
The government’s descriptions of a new zonal planning system leave the environment unprotected. There is no clarity of detail as to whether the zones will undergo a full environmental assessment before being assigned as Growth, Renewal or Protected or whether there will be no assessment at all. The prime minister has even BOASTED there will be no more counting of newts!
Cornwall Green Party would like to see more detailed environmental assessment and absolutely zero ‘offsetting’ of biodiversity obligations in the government’s planning reforms. The UK is one of the most nature-depleted nations in the world and there is no mention in these planning proposals of policies and strategies to safeguard the UK’s diminished populations of flora and fauna, nor are there any details to show intent to increase or recover biodiversity and the abundance of wildlife populations.
The government’s white paper does not mention the inclusion of a zone for a nature recovery network, which is one of its flagship policies. There is no indication how the nature recovery network, currently being developed at a local level, will feed into the proposed system of zones.
Cornwall Green Party welcomes the intention to have detailed national mapping of land, land use and nature which will be available online to everyone. However, this data should be informed by local knowledge and linked to the Land Registry as land ownership is. Cornish residents and potential buyers should be able to see who is benefiting from the huge uplift in land values in Cornwall once land is assigned for growth. This is especially important as land currently assigned for development in Cornwall is often owned by overseas companies and individuals.
Cornwall Green Party has concerns that the government’s proposals will dilute democracy and ride roughshod over the hard work already undertaken to produce Local and Neighbourhood Plans.
Cornwall Council is in the process of updating its Local Plan with a DPD for the climate emergency. The policies in this document aim to support the county’s ambition to be net zero carbon by 2030 through local planning policy. This includes One Planet policies which allow people to build a property and inhabit land on which they subsist. It includes policies to enable renewable energy production and future mining extraction. These policies are the result of an ambitious consultation process which was supported by organisations and individuals throughout Cornwall helping to influence and design the final draft. It is unsatisfactory to see this document and all this hard work abandoned for the government to pursue a new NPPF around which this document has not been framed. The government must recognise that the imposition of a zonal system without the detail of how current local policies and plans will be respected is undemocratic. And the current white paper does not contain any detail on whether policies for the climate and ecological emergency will be in included – a sad omission.
It is also unclear from the government’s proposals how future local and neighbourhood plans will be resourced so they can be completed within 30 months. This timeframe is short and local authorities, especially parish and town councils, will need access to professional support if these plans are to be meaningful. This will require finance for the training of existing officers and parish clerks as well as the contracting of consultants.
Lastly, and most importantly, Cornwall Green Party agree that public consultation has become a ‘tick box’ procedure and welcome the proposals for genuine co-design of local plans. However, in the experience of Cornwall Green Party’s elected councillors, the public rarely get involved in the drafting of Local and Neighbourhood plans. The process is remote and complex, and hard-working families do not have the time to become involved. People prefer to make their views known on individual planning applications which affect them personally or their communities. Refusing general members of the public a right to comment on or challenge planning applications which are taking place on their doorstep is a loss of democracy. Developers may acquire permitted rights to build in growth zones, yet the impact of that development may be felt in protected zones. If the public cannot raise this issue through a democratic process, then developers have gained an undue advantage.
6. Do you agree with our proposals for streamlining the development management content of Local Plans, and setting out general development management policies nationally? [Yes / No / Not sure. Please provide supporting statement.
Government Proposal 2: Development management policies established at national scale and an altered role for Local Plans.
NO. Cornwall Green Party does not agree with ‘streamlining’, as outlined in the proposals. These proposals will reduce democratic involvement in the planning system.
Once again there is a lack of detail in the white paper on this issue and it is not clear as to how the national general development policies will work in reality.
Nevertheless designating land as a ‘growth’ zone will curtail the input of elected representatives in the planning process. Transferring local plan development to professional officers will again undermine the democratic process; local authority officers are not accountable to the public.
Given the differing economies, environments, and demographics of different local authorities, there should be more democratic input at the local level, not less. It is not clear how Cornwall Council will be able to set policies which respond to local priorities in the proposed system. Any problems of cronyism, delays, and apparent unfairness are alleviated by increasing transparency and accountability, not by removing decision making.
The push for making the planning process more and more reliant on digital technology is attractive to some, but unless the proposals are accompanied by meaningful efforts to increase digital literacy and engagement throughout the whole population, digitally disadvantaged communities will become ever more disenfranchised.
7. Do you agree with our proposals to replace existing legal and policy tests for Local Plans with a consolidated test of “sustainable development”, which would include consideration of environmental impact? [Yes / No / Not sure. Please provide supporting statement.
Government Proposal 3: Local Plans should be subject to a single statutory “sustainable development” test, replacing the existing tests of soundness.
YES. Cornwall Green Party agrees with these proposals and it is surely right in principle that local communities should be the ones to set their development priorities, within a national framework that sets strong minimum standards (e.g. for low/zero-carbon housing, biodiversity protection, etc).
Cornwall Council has suffered from national planning inspectors overruling its housing targets revising these upwards to 52,000 from an initial target of 38,000 set by the Council’s Planning Policy Advisory Panel for the 2020-30 period. This number includes an assumption that 7% of these homes will be holiday lets/second homes. The growth of second homes and holiday lets is hollowing out many local communities and doing nothing to help provide affordable housing for people who need it in Cornwall. Councils need stronger powers to set local ordinances and/or differential council tax levels that can help to prevent this sort of development.
There is a risk that such a test could be set up in a flawed way from the start, meaning that using it as the single measure for all planning applications would ensure that every decision is more or less a "bad" one. Environmental considerations need more than just the council surveying people who happen to be walking past the area on any given day, soil and water tests and so forth being carried out and scientific data being taken into consideration.
It should also include tests such as "Is there sufficient local infrastructure to support this new development", as many problems in Cornwall come from thousands of new houses either being stuck in the middle of nowhere or on the side of towns where schools, doctors surgeries, etc, are already at or even beyond their capacity. It is not sustainable to simply double the size of small towns like Helston in terms of population by doubling the number of houses, whilst not doing anything to increase the provision of services. In fact in many cases, services are being reduced.
7(b). How could strategic, cross-boundary issues be best planned for in the absence of a formal Duty to Cooperate?
8. Do you agree that a standard method for establishing housing requirements (that takes into account constraints) should be introduced? [Yes / No / Not sure. Please provide supporting statement.]
Government Proposal 4: A standard method for establishing housing requirement figures which ensures enough land is released in the areas where affordability is worst, to stop land supply being a barrier to enough homes being built. The housing requirement would factor in land constraints and opportunities to more effectively use land, including through densification where appropriate, to ensure that the land is identified in the most appropriate areas and housing targets are met.
NO. Cornwall Green Party does not agree a standard method for establishing housing requirement figures. This assumes that land supply is the key determinant of affordability, which is not the case in Cornwall. Much of the pressure on prices comes from demand for second homes and holiday lets, and from inward migration. We need better definitions of “affordable” housing, both to buy and to rent.
“Affordable” rent is currently defined by the Department of Communities and Local Government as rents at less than 25% of gross household income. By that definition it is very hard to find affordable rental property in Cornwall, where median gross household income is around £22,000. So to be affordable rent must be less than £5,500 a year, or £458 a month. But it is also defined by government and Cornwall Council as “up to 80% of open market rent”. Market rents in Cornwall average £625 a month, which means that an “affordable rent” could be as much as £500 a month. So by the 80% definition, more than half of Cornish households are unable to afford “affordable rent”.
Note that “social rent” is based on a different formula that combines local wages and local property values, and typically sees rents set at around 50% of private rents in the same area. But few homes for social rent are being built.
In 2018, homes for social rent made up just 5% of all new “affordable housing” in Cornwall (i.e. those built from 2010). The number of social homes being built had plummeted from 423 in 2011/12 to just 74 in 2018. This is largely due to the relationship between Cornwall Council and private developers.
Now developers are encouraged to build ‘starter homes’ of up to £250,000, to be sold at a 20% discount to make then “affordable” to buy. But for most households in Cornwall these homes are completely unaffordable even after this discount. According to the DCLG, a house is “affordable” to buy if it costs no more than 3.5 times gross household income. That means the median household in Cornwall can actually afford a house of up to £77,000.
Even when developers agree to provide a certain proportion of “affordable” housing. They often renege on these agreements and end up providing much less.
Any procedure for establishing housing requirements needs to be based on a realistic assessment of the need for affordable housing and a much more realistic definition of affordability based on local incomes.
8(b). Do you agree that affordability and the extent of existing urban areas are appropriate indicators of the quantity of development to be accommodated? [Yes / No / Not sure. Please provide supporting statement.
9. Do you agree that there should be automatic outline permission for areas for substantial development (Growth areas) with faster routes for detailed consent? [Yes / No / Not sure. Please provide supporting statement.
Government Proposal 5: Areas identified as Growth areas (suitable for substantial development) would automatically be granted outline planning permission for the principle of development, while automatic approvals would also be available for pre-established development types in other areas suitable for building.
No. Cornwall Green Party does not agree with the proposals to create zones for Growth, Renewal and Protected areas.
i. Major simplification of land use planning is likely to lead to:
- key decisions being made without proper understanding of the bigger picture and locally relevant issues
- ignoring important issues such as environmental protection, climate mitigation, local vernacular design and cultural relevance
- lower-level staff making key decisions
- local annoyance at poor council decision making reduced local democracy
ii. Reducing land use decision making to three zones means that:
- Growth areas developers will concentrate on pushing low quality, standard, locally alien developments onto areas which will have no power to resist
- this approach to development will alienate local communities and reduce their quality of life
- such hostility will not increase the number or range of new homes built
iii. The urgent need for climate action in not recognised in the process or apparent policies outlined.
The science and UK legislation is clear that the UK has to reduce our emissions dramatically starting now and continuing each year at a minimum of 4% reduction or over 16 million tonnes p/a CO2e.
If the government is serious about meeting its legal requirement to reach carbon zero by 2050 then house building has to play a significant part in this.
a. Homes must be zero carbon from now on to meet legal targets for zero carbon.
- The suggestion in the consultation that homes could be reduced in carbon emissions by 80% by 2025 does not meet the legislative commitment to the UK being net zero by 2050, as once built it is hard and expensive to make fabric changes to buildings.
- After ten years of development the zero carbon homes standard was ready to go in early 2016, until the new government of 2015 pulled this development.
- Therefore there is no reason why, some five years later, all new homes should not be zero carbon from 2021.
We propose net zero now to save carbon emissions quicker and much more cheaply
b. The existing duty to meet the Climate Change Act requirements through plan-making under several planning acts must be made explicit rather than implicit.
This should build upon the existing legal duty and should apply to both development planning and decision making and should include explicit reference to implementing the carbon reduction budgets required by the 2008 Climate Act as amended. The Planning and Compulsory Purchase Act (section 19) and the NPPF (Paragraph 148) require Local Plans to achieve radical carbon emission reductions in line with the Climate Change Act (upgraded to a -100% requirement by 2050). This must be made much clearer to all involved in the planning system
c. Changing the planning system to speed up new homes delivery is tackling the wrong part of the system
All the evidence and analysis from knowledgeable parties such as the Local Government Association, the MHCLG’s own figures and others show that the blockage in housing delivery is not the planning system. It is housebuilders which do not build when they have planning.
Housebuilders have the requirement to maximise shareholder value and directors’ salaries and hence will hold a land bank to increase their asset valuations, and build in small numbers in each area in order to keep demand high and supply small, so minimising the potential for house prices to reduce.
Recent government figures show that nine in ten applications are approved by councils with more than a million homes given planning permission over the last decade yet to be built. It is time that the government produced papers on policy which are evidenced based.
Note on Energy hierarchy
The consultation document states that the Energy Hierarchy should be followed. However, the main determinant of energy use around housing is its location and relationship to public and active transport infrastructure and to local services.
Therefore the first step in the Energy Hierarchy must be the location of new developments in relation to transport.
This leads to the requirement to plan low energy transport infrastructure in advance of new building developments.
An analysis of the carbon footprints of several Cornish communities provides strong evidence for the importance of location vs transport needs as shown in the table below.
Location must therefore come first in the energy hierarchy as a function of connection to low-carbon transport infrastructure.
9(b) Do you agree with our proposals above for the consent arrangements for Renewal and Protected areas? [Yes / No / Not sure. Please provide supporting statement.
9(c). Do you think there is a case for allowing new settlements to be brought forward under the Nationally Significant Infrastructure Projects regime? [Yes / No / Not sure. Please provide supporting statement.
NO. Cornwall Green Party does not agree new settlements should be brought forward as NSIPs. New settlements should be located close to existing communities to facilitate good transport links and employment opportunities. In the recent research paper published by Transport for New Homes it is shown that so called ‘garden villages’ are “car-based sprawl under a different name”. New settlements are best positioned close to existing transport networks and communities to prevent the increase of emissions and as such should be decided upon by the local communities on which they will impact. The building of homes is not building national infrastructure – it is fulfilling a local need and should be decided upon by a local authority and its residents.
10. Do you agree with our proposals to make decision-making faster and more certain? [Yes / No / Not sure. Please provide supporting statement.
Government Proposal 6: Decision-making should be faster and more certain, with firm deadlines, and make greater use of digital technology.
NO. Cornwall Green party does not agree with the assumptions presumed by this question.
Delays in the planning system, in the experience of Cornwall Green Party elected councillors, are usually the result of actions by developers; where delays originate in the planning system there are usually good reasons for these.
At root, the current planning system is democratic and in fact and in practice it is open for community engagement. In view of these factors, the decision-making process is remarkably quick, though it may suit the property development industry to argue otherwise.
Whilst, in general, faster decision making might be a reasonable aspiration, it would be a small gain if gained at the loss of a democratic system open to community engagement.
11. Do you agree with our proposals for accessible, web-based Local Plans? [Yes / No / Not sure. Please provide supporting statement.
Government Proposal 7: Local Plans should be visual and map-based, standardised, based on the latest digital technology, and supported by a new template.
YES. A local map providing a framework for land use would be useful and include additional mapping projects including nature recovery network, water catchment areas, forest canopy cover and agriculture. A comprehensive local map would enable local decision making to mitigate climate change and ecological collapse.
12. Do you agree with our proposals for a 30 month statutory timescale for the production of Local Plans? [Yes / No / Not sure. Please provide supporting statement.
Government Proposal 8: Local authorities and the Planning Inspectorate will be required through legislation to meet a statutory timetable for key stages of the process, and we will consider what sanctions there would be for those who fail to do so.
NOT SURE. Cornwall Green Party is not sure whether it agrees or not with the 30 month timeframe for the production of Local Plans. Though welcoming any increase of speed in local authority delivery of plans, the white paper does not provide details on how authorities will be supported to produce a plan within this timeframe. A Local Plan will need to be well resourced with trained officers and local consultants and if the plan is to be co-designed, as also promised in the white paper, then the public will also need time and resources to reach informed decisions.
In reality, 30 months feels like an arbitrary figure. Local authorities across the country have different geography and demography, and different levels of success in developing existing local plans. Given the reduced funding to local authorities in recent years, and recently announced increases in housing numbers for Cornwall, it seems that local authorities are being set up to fail. If the ‘sanctions’ proposed include overriding local policy with national guidelines, then this cannot be in the interest of such a unique area as Cornwall.
13. Do you agree that Neighbourhood Plans should be retained in the reformed planning system? [Yes / No / Not sure. Please provide supporting statement.]
Government Proposal 9: Neighbourhood Plans should be retained as an important means of community input, and we will support communities to make better use of digital tools.
YES. Cornwall Green Party believes a continuing commitment to Neighbourhood Planning can be positive; however more investment/funding is required to support communities both to meet the technical requirements and enable proper community participation.
In the experience of Cornwall Green Party’s elected councillors and volunteers, there has been an underestimation of the scale, complexity and time needed to produce a Neighbourhood Plan, with volunteers trying to make sense of jargon, policies and regulations. In a region like Cornwall, which is less affluent than most other areas in the UK, many residents do not have the time or inclination to enter the Neighbourhood Planning process. The volunteers who do come forward are in most cases retired or elderly and this is not a representative slice of the local demography.
Once a plan reaches the referendum stage, on average a ‘yes’ vote is 88% but on a turnout of 32%. Therefore, do Neighbourhood Plans adequately reflect the wishes of the whole community when the majority do not vote? Do NPs need reform? And if so the government needs to address public apathy. Is this a failure of communication, the complexity of the planning system or the lack of strong opinions which prevents residents voting or becoming involved?
Cornwall Green Party’s parish and town councillors report that developers have the upper hand in the planning process. Large developers, with access to professional planning consultants and agents, can too often run rings around the Neighbourhood Plan. Recent planning applications in Hayle Harbour have seen local authorities negotiating with developers to provide residential over and above retail in order to fulfil governmental targets. The imbalance between the power of the developers and that local communities must be resolved to protect local democracy. Development must be for local need, not for developers’ profits.
13(b). How can the neighbourhood planning process be developed to meet our objectives, such as in the use of digital tools and reflecting community preferences about design?
The neighbourhood planning process needs better access to resources and trained consultants or facilitators who can organise and deliver genuine co-design of local plans. As far as we are aware in Cornwall, most of the planning process and Local and Neighbourhood Plans are digital. A digital map of Cornwall with a land use framework would be useful.
14. Do you agree there should be a stronger emphasis on the build out of developments? And if so, what further measures would you support? [Yes / No / Not sure. Please provide supporting statement.
Government Proposal 10: A stronger emphasis on build out through planning.
In Cornwall there are nearly 28000 homes with planning permission which are not yet completed and in 2019/20 for every one dwelling built there were 8.4 with permission but not yet started; the majority are on large sites (of more than 200 homes.)
The fact is that the predominant factor in delays to build out is that developers are sitting on the added value that a planning approval brings and speculating on a future rise in value. This can only be prevented by penalties for doing so: shortening the start time requirement (to say one year) before an approval lapses. But also preventing developers from making a sham start such as laying a drain or even just turning a turf, in order to avoid the expiry of an approval.
It is far from obvious what penalties might be levied against developers for tardiness in build out. Legislation would certainly be required but clearly Planning For The Future will , in any case, bring major changes requiring legislation.
In Liskeard, for example, there is currently a development which is stalled by the developer and has been simply abandoned in its half-complete state as a fenced off site. There is a road and two public footpaths that run through the site and are currently inaccessible to the public. The footpaths form the only pedestrian route between a large housing area and a primary school. The action by the developer is causing genuine difficulty to the community. This delay in build-out is having a negative impact on the infrastructure and it is unlikely that this is an unusual case.
Cornwall Green Party proposes that an appropriate penalty to incentivise developers to avoid delays in build out would be a staged increase in Infrastructure Levy. For example, an increase in CIL of 10% per year of delay of completion beyond two years of commencement of building.
Pillar Two – Planning for beautiful and sustainable places
Summary of key proposals:
- Introduction of national design codes and process for creating binding local codes
- Permitted development rights to create popular development types
- Mandating of street trees, biodiversity net gain and nature recovery networks
- Speeding up of future homes standard implementation
15. What do you think about the design of new development that has happened recently in your area? [Not sure or indifferent / Beautiful and/or well-designed / Ugly and/or poorly-designed / There hasn’t been any / Other – please specify]
All of this seems to be about superficial design features rather than the need to prioritise zero-carbon design if we’re to have any hope of tackling the climate emergency. However, there is plenty of evidence that people highly value examples of sensitively built low carbon development in Cornwall – e.g. at Jubilee Wharf in Penryn, Verto-built housing in Newquay and Truro… We need national design codes to set ambitious low/zero-carbon standards and for developers of such housing to be offered substantial discounts/incentives to build to these standards (particularly affordable housing). Cornwall has companies with the skills and ambition to do this, but as Richard Pearce of Truro based Verto Homes commented recently: “Why should a fairly small company – doing more for the built-environment than all of the national housebuilders put together – be subject to the same costs as shareholder driven companies, only interested in their bottom line, and not concerned or held accountable for the damage they are doing to the planet?”
16. Sustainability is at the heart of our proposals. What is your priority for sustainability in your area? [Less reliance on cars / More green and open spaces / Energy efficiency of new buildings / More trees / Other – please specify]
Government Proposal 11: To make design expectations more visual and predictable, we will expect design guidance and codes to be prepared locally with community involvement, and ensure that codes are more binding on decisions about development.
No sustainability in this proposal.
17. Do you agree with our proposals for improving the production and use of design guides and codes? [Yes / No / Not sure. Please provide supporting statement.
Government Proposal 11: To make design expectations more visual and predictable, we will expect design guidance and codes to be prepared locally with community involvement and ensure that codes are more binding on decisions about development.
YES in principle - These need to be locality specific to avoid homogenised design. Offer a degree of flexibility. Not only focus on the built environment but MUST focus on the Local natural environment with clear message on how to design for vastly improved biodiversity, energy efficiency, etc.
18. Do you agree that we should establish a new body to support design coding and building better places, and that each authority should have a chief officer for design and place-making? [Yes / No / Not sure. Please provide supporting statement.
Government Proposal 12: To support the transition to a planning system which is more visual and rooted in local preferences and character, we will set up a body to support the delivery of provably locally-popular design codes, and propose that each authority should have a chief officer for design and place-making.
Yes in principle – Anyone making decisions based upon design must hold relevant design-based qualifications and have the experience to do so. Understandings of good design are subjective, therefore the decision-making process must be participatory and democratic. Bodies should be localised and able to act autonomously. The scope of the bodies should not solely be focused on subjective aesthetic value but should focus on human and environmental wellbeing; persons responsible should hold the relevant qualifications and experience.
19. Do you agree with our proposal to consider how design might be given greater emphasis in the strategic objectives for Homes England? [Yes / No / Not sure. Please provide supporting statement.]
Government Proposal 13: To further embed national leadership on delivering better places, we will consider how Homes England’s strategic objectives can give greater emphasis to delivering beautiful places.
No - Design must not be based merely in aesthetics but MUST take a more holistic view of what a well-designed built environment should be, the design decisions that are made now with respect to the built environment will determine whether we have a truly sustainable and healthy future.
20. Do you agree with our proposals for implementing a fast-track for beauty? [Yes / No / Not sure. Please provide supporting statement.
Government Proposal 14: We intend to introduce a fast-track for beauty through changes to national policy and legislation, to incentivise and accelerate high quality development which reflects local character and preferences.
NO. Cornwall Green Party does not agree with the government’s proposals for implementing a ‘fast track for beauty’.
Beauty is an entirely subjective concept. What qualifies as beautiful, what explains this consensus, who has been consulted? ‘Beauty’ within this context appears to be linked only to aesthetics. A well-designed built environment is wholly unachievable if solely working with the agenda of achieving ‘beauty’ or a subjective perception of pleasing aesthetics. A well-designed built environment must be working towards making our lives continuously better through promoting both physical and mental health and must leave the natural environment richer and healthier than we found it. Such a homogenous approach has potential to eradicate local identity and sense of place. Fast-tracking for any reason has the dangerous potential to become undemocratic and environmentally destructive.
Cornwall Green Party’s elected councillors already find planning policies confusing. Policies often contain subjective terms such as ‘enhance’ and ‘respect’ which are interpreted differently by developers, planning officers and individuals. Subjective terminology adds confusion and frustration to decision making at planning meetings. It upsets individual applicants and the public whilst developers and planning consultants learn how to manipulate it. Adding the concept of ‘beauty’ to the planning process or design process will increase that frustration.
Over the last few years the Duchy of Cornwall has embarked on housing developments in Newquay and Truro which it deems to be beautiful and in keeping with Cornwall. Some would argue these developments are a Georgian pastiche with no front gardens, no greenery and not reflecting the Cornish vernacular. Now, if Cornwall Council is to co-design a code for buildings in Cornwall to enable a ‘fast track system’ for beauty, whose view of beauty will appear in the design code? Let us hope it is not the Prince of Wales’ idea of beauty, or all the houses will look the same, out of place, out of context and the wrong side of history.
The subjective term ‘beauty’ will be a cause of conflict, unnecessary debate and frustration either when producing the design code or interpreting the design code.
If Cornwall Council is lucky enough to engage its residents, businesses and developers to agree a design code, Cornwall Green Party believe the homogenisation and standardisation of design will diminish the huge variety of architecture and housing currently enjoyed in Cornwall.
Pillar Three – planning for infrastructure and connected places
Summary of key proposals:
- Consolidated Infrastructure Levy with removal of S.106 and CIL
- Infrastructure Levy to be extended to Permitted Development
- Affordable housing delivered through Infrastructure Levy
- Resources and skills review
22. When new development happens in your area, what is your priority for what comes with it? [More affordable housing / More or better infrastructure (such as transport, schools, health provision) / Design of new buildings / More shops and/or employment space / Green space / Don’t know / Other – please specify]
Cornwall Green Party’s priorities for what comes with development in Cornwall are:
- The development is designed to be carbon neutral. Does the design incorporate renewable energy features for self sufficiency?
- The development will increase biodiversity and be built to improve natural surroundings.
23(a). Should the Government replace the Community Infrastructure Levy and Section 106 planning obligations with a new consolidated Infrastructure Levy, which is charged as a fixed proportion of development value above a set threshold? [Yes / No / Not sure. Please provide supporting statement.
Government Proposal 19: The Community Infrastructure Levy should be reformed to be charged as a fixed proportion of the development value above a threshold, with a mandatory nationally-set rate or rates and the current system of planning obligations abolished.
23(b). Should the Infrastructure Levy rates be set nationally at a single rate, set nationally at an area-specific rate, or set locally? [Nationally at a single rate / Nationally at an area-specific rate / Locally]
23(c). Should the Infrastructure Levy aim to capture the same amount of value overall, or more value, to support greater investment in infrastructure, affordable housing and local communities? [Same amount overall / More value / Less value / Not sure. Please provide supporting statement.]
23(d). Should we allow local authorities to borrow against the Infrastructure Levy, to support infrastructure delivery in their area? [Yes / No / Not sure. Please provide supporting statement.]
24. Do you agree that the scope of the reformed Infrastructure Levy should capture changes of use through permitted development rights? [Yes / No / Not sure. Please provide supporting statement.
Government Proposal 20: The scope of the Infrastructure Levy could be extended to capture changes of use through permitted development rights.
25a). Do you agree that we should aim to secure at least the same amount of affordable housing under the Infrastructure Levy, and as much on-site affordable provision, as at present? [Yes / No / Not sure. Please provide supporting statement.
Government Proposal 21: The reformed Infrastructure Levy should deliver affordable housing provision.
NO. Cornwall Green Party believes there should be an increase in affordable housing provision both through the infrastructure levy to allow the building of social housing by the council as well as on site provision by developers.
Affordability needs to be considered on a local level, relative to local averages. In Cornwall we have some of the poorest people earning the lowest average wages in the country. We also have some of the very highest property price averages outside of London, thanks to wealthy people from outside of the county moving here to enjoy the scenery and quiet, or buying second/holiday homes. Many people born in Cornwall, whose families have lived in the same place for as long as records have existed, cannot afford to buy a house here. Where "affordable" houses have been built these have been declared affordable relative only to average house prices, with no consideration of what local people are actually able to afford, so they remain out of reach. Besides which, there is also nothing to stop these wealthy people moving to Cornwall and buying up the affordable homes. Priority needs to be made for genuinely local people, particularly in a highly desirable location like Cornwall with many people from outside looking to buy property here and locals simply not having the means to compete in the current market.
25(b). Should affordable housing be secured as in-kind payment towards the Infrastructure Levy, or as a ‘right to purchase’ at discounted rates for local authorities? [Yes / No / Not sure. Please provide supporting statement.]
NO. Taking an in-kind payment will lead to the gentrification of housing estates and social housing being segregated. This is not conducive to rounded community relations. Developers need to build affordable homes as part of any development of over 5 houses. Developers need to make an infrastructure levy payment as well as sell properties for social housing to local authorities at a discounted rate. Current levels of profit for housing developers stand at 20%. This is too high and the excess profits must be redressed with the building of more homes for social rent.
25(c). If an in-kind delivery approach is taken, should we mitigate against local authority overpayment risk? [Yes / No / Not sure. Please provide supporting statement.]
25(d). If an in-kind delivery approach is taken, are there additional steps that would need to be taken to support affordable housing quality? [Yes / No / Not sure. Please provide supporting statement.]
Answers to 24 -25 Affordable housing and infrastructure are separate issues and should be treated separately. In Cornwall there is an acute housing crisis in both private and rented sectors. There is little mention in Planning For The Future of measures for bringing vacant homes into use or of provision for rented housing both of which would alleviate the situation.
In Cornwall many homes remain vacant for many months of the year as they are second homes, holiday and airbnb lets. There are financial incentives that encourage investment in those property sectors; to counter which the tax system should be used to impose at least equivalent disincentives.
The planning system should be used to encourage development of affordable homes and prevent developments of second homes and holiday lets. There is no mention of this in the white paper.
Developers have used the difficult topography of Cornwall to argue down the affordable housing provision due to the high cost of infrastructure. Now that Cornwall is losing the EU infrastructure support that it had enjoyed, there will be even greater threat to affordable housing. Affordable housing should be ring-fenced.
26. Should local authorities have fewer restrictions over how they spend the Infrastructure Levy? [Yes / No / Not sure. Please provide supporting statement.
Government Proposal 22: More freedom could be given to local authorities over how they spend the Infrastructure Levy.
YES. Cornwall Green Party believes the Infrastructure Levy should be used by the local authority for what it agrees is appropriate to support local affordable housing need and local infrastructure.
26(a). If yes, should an affordable housing ‘ring-fence’ be developed? [Yes / No / Not sure. Please provide supporting statement.]
YES. Cornwall Green Party believes the Infrastructure Levy should be ringfenced! Otherwise the money could be used for all sorts of purposes other than affordable housing and infrastructure. Cornwall Green Party recommends the infrastructure levy is ring-fenced for each local (parish or district council) area, because in a county like Cornwall – a unitary council – monies for infrastructure and development money gravitate towards the larger areas of population like Truro, even when it's raised by developments and taxes in other parts of Cornwall. In West Cornwall there have been many large housing developments and no discernible investment in new infrastructure to support them. The existing infrastructure is pushed beyond capacity and falling into disrepair and neglect.
27. Do you have any views on the potential impact of the proposals raised in this consultation on people with protected characteristics as defined in section 149 of the Equality Act 2010?
There need to be protections put in place to make housing accessible to local Cornish people. The Cornish people have recognised minority status and due to property prices being elevated by large numbers of people migrating to Cornwall for the lifestyle benefits , local people are unable to purchase or even rent affordable homes near where they were brought up.
Cornwall not only has a distinctive cultural identity that needs to be protected, but also the majority of the buildings here are unmistakably "Cornish", built to local styles using local techniques and materials, and this is put at risk by gentrification and homogenisation, as seems to be suggested by some of the proposals in this planning white paper.
There is little mention in these proposals of how housing is to be made more accessible. The UK builds some of the smallest houses on Earth, with no consideration to the possibility of disabled people living in them unless they're specifically being built as part of a complex for the elderly, and this presents a lot of challenges to disabled people, particularly younger ones. Doorways are too narrow, paths are too narrow, there are too many steps, etc. It is possible to make things easier. Continental European building standards already make provisions for these things, with standard door sizes in new buildings, for example, being roughly 40cm larger than those in England. Scotland adopted the European standards some years ago, but properties in England and Wales still stick to older national ones that make it almost impossible for disabled people to manage in them, and make adapting them after the fact extremely costly.