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Technical consultation on implementation of planning changes

Date: 15/4/2016

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The Planning Officers Society (POS) strongly supports the need to house the population. This is a fundamental requirement of the planning system and central to the NPPF. A good planning system will enable housing provision that meets the full spectrum of objectively assessed need, ensuring that those who are most in need and unable to access housing in the market are assisted.

We have carefully considered the consultation proposals, we welcome many of the proposals, such as increasing fees, the development of brownfield sites and the introduction of a housing delivery test. However, there are also proposals which we believe need to be reconsidered and revised, including: the reduced discount period for affordable housing, including Starter Homes; the consequences for housing under-delivery; the definition of a commuter hub and the proposal to test competition in the processing of planning applications. The latter we take as a fundamental attack on planning departments and consider the practicalities to have many unworkable flaws.

We would call for the empowerment of local authorities to have flexibility to make decisions which are suitable for their local communities. We believe that this is right, as decisions about local development should be taken at a local level. This ranges from prioritising intermediate or affordable rent housing as well as Starter Homes, but not instead of, locally appropriate density levels, to fixing their own planning fees and deciding at a local level
whether a fast track planning service is provided.

We support the findings of the House of Commons Communities and Local Government Committee's findings on this consultation. We agree that it is challenging to link the number of significant pieces of work which are currently underway at the same time, including
- the Local Plans Expert Group
- the Housing and Planning Bill
- this consultation on the NPPF technical changes
- Starter home consultation
It is challenging to fully assess the cumulative strategic impact of all of these proposals together.

It is also challenging for Local Planning Authorities (LPAs) to be able to have a medium/long term business strategy without fully understanding how fees will be increased, competition with approved providers will be rolled out or the additional planning burdens associated with the brownfield register and articulation of permission in principe so the community and stakeholders.

For example, we have particular concerns about the risk that developers will delay developing brownfield sites because local authorities will be required to release more profitable greenfield sites if insufficient housing is delivered to meet local needs. This then links to the current CPO consultation which we feel should be stronger in allowing LPAs power to CPO a site which has planning permission but is not being delivered, this would help break up 'land banking'.

The POS Minerals and Waste forum acknowledge that the main purpose of the Housing and Planning Bill 2015 and this technical consultation document is to provide for and drive up the supply of sustainable housing. However, we are concerned that the technical consultation document appears to have been written without any recognition of the linkages minerals and waste has with the house building agenda, with no reference to, or clarity on, minerals and waste planning matters. There is a clear link between minerals and waste and other issues with a planning or
spatial dimension, with minerals and waste being absolutely necessary to the sustainable house building agenda and energy provision. A sufficient supply of minerals/aggregates is required to ensure the planned housing growth can be built (including roads) and waste infrastructure required to ensure the waste generated by the planned growth is dealt with in the most environmentally/sustainable manner, along with the waste generated when developments are complete (e.g. sewerage/general & household waste). In terms of energy provision, a key government energy policy is the exploration of and development of shale gas and oil resources to provide the necessary energy to power homes and industry.

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