Rob Butler responded to the government's recent "Planning for the Future" consultation, outlining the concerns of many local residents with the proposals. The consultation response examines the proposed zoning of land, protection of precious green spaces and the need to ensure democratic accountability for planning decisions.
Rob's full response can be read here:
Introduction
I support many of the proposals contained in the planning consultation, especially those to digitalise the planning system, to create a one-stop-shop for a planning applications and to build beautiful. I am, however, deeply concerned about certain aspects surrounding zonation, and the scrutiny applied to development under the proposals as stated. I want to see a planning system that delivers the housing we need for the younger generation at the same time as safeguarding our natural environment. Crucially, we must ensure that development can work for old and new residents alike.
My concerns fall into three key themes:
I. Does this genuinely level up the whole country? The Conservative manifesto committed to level-up communities across the entire United Kingdom, particularly in the north and midlands of England. I therefore believe the proposed reforms should focus on urban regeneration, whereas there is currently a greater emphasis on greenfield sites and “growth areas”. Coupled with the emphasis on affordability, this will mean a vast amount of new housing will be heavily concentrated in the south-east of England rather than in the areas which would benefit from development. The current proposal risks losing a once-in-a-generation opportunity to shift economic growth to other regions, rather than once more to the London periphery.
II. Infrastructure first; I welcome the white paper’s reform to the Planning (s106) Obligations; however, the proposal is not detailed as to how vital infrastructure to support new housing development will be delivered. Unless this can be assured, it will be very diffciult for local communities to see the benefits of development: the complaint most frequently made by my constituents is that there are too many houses, but too few school places, no new roads to ease congestion, and insufficient healthcare provision making it extremely difficult to get a doctor’s appointment.
III. Protecting our green space; Aylesbury Vale is in a unique position. Much of the county of Buckinghamshire is protected either by the Metropolitan Green Belt or the Chiltern Area of Outstanding Natural Beauty (AONB). My constituency and that of my neighbour, the Member of Parliament for Buckingham, have very little protected land. The division of land use into “growth”, “renewal”, and “protected” zones could have far-reaching and detrimental implications for the Aylesbury Vale.
The response
The central tenet of “Planning for the Future” is a complete change from the current case-by-case system to the zoning of land. The proposals seek Local Plans to identify three types of land – Growth areas, Renewal areas, and Protected areas.1 The white paper also outlines plans to build beautiful, digitise certain aspects of the planning process and streamline existing procedures to enhance the planning system. As outlined in the previous section, some of these ideas are to be commended; however, some need urgent review and revision.
I. Zoning
The overall concept of zoning is useful and will allow the planning process to be streamlined considerably. However, these proposals must be considered with care and sensitivity, and will need to stand up to the detailed scrutiny of local representatives.
Growth Areas:
Growth areas are a considerable cause of concern for many residents, in my constituency who believe the designation removes their voice from the planning system by granting automatic consent. The proposals state that this designation will be “applied to land used for comprehensive development; including new settlements and urban extension sites as well as redevelopment of existing urban locations such as former industrial sites or urban regeneration sites “[Page 28, para 4]. If implemented correctly, growth areas could be utilised effectively to unlock additional housing. As the proposed reforms stand, however, I believe that granting automatic consent runs a serious risk of unscrutinised overdevelopment, with the ensuing and inevitable creation of urban sprawl which would be contrary to the white paper’s plans for building beautiful.
Suggestion One: Brownfield sites must be the emphasis before greenfield. The white paper assumes that in growth areas, greenfield development will be necessary and is encouraged to deliver national housing targets. This should be strongly discouraged.
Suggestion Two: Urban extensions must be matched with accompanying infrastructure upgrades in a holistic manner. Over the past 50 years, Aylesbury has experienced considerable housing development, with new estates continuously being added to the edges of the town. These have caused substantial pressure on the existing local infrastructure, particularly roads where congestion clogs the main routes into the town centre. Infrastructure upgrades must therefore be implemented which take into account the needs of the existing population as well as of the new development.
Suggestion Three: Urban extensions should not lead to a coalescence of villages. If an area is marked for urban extension, existing villages should not be merged with a larger settlement in one conurbation. In my constituency, villages such as Weston Turville and Aston Clinton would be at risk of conurbation with Aylesbury should endless urban expansion continue. Therefore there should be explicit protection to prevent this.
Suggestion Three: Automatic planning permission should not apply to areas of flood risk; instead, the proposals should be examined in detail with proper hydrological and environmental studies conducted. Should any development be granted after a considered process, the best possible mitigations must be implemented to ensure both that there is minimised flood risk to the new development and that the flood risk is not displaced elsewhere in the local area. Aylesbury has suffered such problems before, with new developments placed in areas of flood risk. Unsurprisingly flooding has resulted and house-owners face high insurance premiums.
Renewal Areas
Renewal areas cover existing built areas and are classed “suitable for development”. The white paper suggests that these areas will see developments in town centres, gentle densification, small-scale infill projects and will be substantially less intense than the growth areas. These proposals will have a statutory presumption in favour of development.
Suggestion Four: I commend the paper’s emphasis on redevelopment in renewal zones, and I believe renewal zones with gentle development should be placed ahead of any growth area “greenfield” development. Aylesbury has seen some exciting redevelopment projects which have combined commercial, residential and leisure uses in one area with gentle densification; a good example is Exchange Square. As our high streets move away from being solely places of retail, renewal zones have the potential to be the vital bridge to bring people back into town centres to make them real community hubs, where people want to live, work, visit and invest.
Suggestion Five: Local infrastructure must keep up with any densification or redevelopment. Whilst building in town centres is a benefit because some existing infrastructure is at hand, the presumption in favour of development must include some form of local impact survey.
Protected Areas
Areas that are designated as Protected would include sites and places which, as a result of their particular environmental and/or cultural characteristics, would justify more stringent development controls to ensure sustainability. This would include areas such as Green Belt, Areas of Outstanding Natural Beauty (AONBs), Conservation Areas, Local Wildlife Sites, areas of significant flood risk and essential areas of green space.
I welcome the protections afforded in the white paper to the Areas of Outstanding Natural Beauty (such as the Chiltern AONB in the south of my constituency) and the Green Belt.
Concern: Where one area is granted protection an additional pressure is created elsewhere. As referenced at the start of this response, Buckinghamshire is similar to much of the London fringe; substantial areas are protected under the current system by the Metropolitan Green Belt, AONBs, and Sites of Special Scientific Interest. Indeed, land in the old district council areas of South Bucks
and Chiltern is 90% protected, either by the Metropolitan Green Belt or the Chilterns AONB. The comparative figure for Aylesbury Vale is just 6%. As a result, Aylesbury Vale has already been responsible for accommodating the unmet housing need of the south of the county. The proposals in the white paper bring stark consequences for my constituency, as by default most development will be pushed from the “protected areas” of the Chilterns to Aylesbury Vale.
Suggestion six: Create “Protected” land near population centres such that urban sprawl is avoided.
II. Housing Numbers:
While the methodology of the housing requirement figure are dealt with in another consultation, I feel I must object to the methodology of affordability utilised, and which has informed this white paper.
Proposal 4 suggests: “A standard method for establishing housing requirement figures which ensure 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.”
Since 2013, the population of Aylesbury Vale has increased by 10.3%. This growth is the 8th highest rate among the 371 local authorities in Great Britain, and in absolute terms is ahead of the cities of Liverpool and Nottingham. But above-average development has come at a cost. Infrastructure in Aylesbury is already under considerable pressure, yet with affordability as the prime criterion of the proposed new formula, the area covered by the Buckinghamshire Council unitary authority would be expected to accommodate more than 4,000 further homes a year – that is almost double the current requirement.
Moreover, this methodology does not appear to be compatible with the levelling-up agenda of the Government: growth areas should drive economic investment, but adopting a pure affordability criterion means that areas with lower house prices will see a decline in their housing requirements, whereas areas such as my own constituency with above-average house prices will see considerable increases. Given the population decline across the north and the midlands, and the expansion of the economy in London and the South-East, the current proposals would by default further entrench the unbalanced nature of the UK economy.
Therefore, whilst I fully appreciate the need for more affordable houses, I would urge MHCLG to examine the complex local circumstances, give due account to local land-use types and patterns of development, and not focus quite so heavily on affordability to ensure the levelling up agenda works for the whole of the United Kingdom.
Section III: Democratic engagement
I have received a significant number of emails from constituents concerned about the proposals to streamline the planning process and introduce automatic consent. This has caused considerable anxiety, and I endorse the views of Buckinghamshire Council as the competent authority responsible for the planning system.
Section IV: Infrastructure
I welcome the white paper’s proposals concerning the reform of Planning (s106) Obligations. Whilst local authorities have the power to mitigate the adverse effects of housing development in the form of Planning Obligations, commonly called ‘Section 106 Agreement’ the process of securing them is cumbersome and relies on the negotiations between local authorities and developers. A standardised Infrastructure Levy is preferable to the current arrangement, and I welcome that aspect of the proposal.
Concern: Most of the large-scale developments in Aylesbury have met the criteria for s106 agreements. However construction lead times have almost invariably meant that the agreed infrastructure has been completed after most of the housing has been constructed, and even then, has not always been sufficient to meet the needs of the new population. An example is in Berryfields, where a new school was built using a s106 agreement, but was immediately filled by existing demand, leaving newer residents obliged to find school places elsewhere – often at some distance from their new homes. It is imperative that infrastructure comes before houses are completed and new residents move in. New ways must be found to finance this, to avoid the current position where developers only release funds after a proportion of the properties have been sold.
The concept of the Infrastructure Levy is therefore a sound one. However, I am concerned that as currently proposed, the onus will be on the local authority rather than the developer to source the upfront funding through borrowing, which creates an unbalanced risk.
