Planning for the Future, our response to the Government White Paper
As the UK’s largest private landowner, a conservation charity, significant tourism and rural business, and occasional developer, planning law and processes affect our work on a daily basis. We have a long history of championing the fundamental importance of the planning system for conservation and for creating places that benefit communities.
From short to medium term shocks like the Covid-19 pandemic and the uncertain impact of EU exit on the economy, to longer term nature and climate crises, the challenges we face as a nation are greater than ever, and we need a planning system that supports us to respond.
We agree with the Government that we must ‘build back better’. But long-term planning cannot be about short-term economic growth alone. Our goals should be to build social, cultural and natural capital, drive a low carbon transition, and deliver climate resilience and mitigation alongside economic gain.
We should also recognise the opportunity to use the planning system to help address inequalities and the Government’s ‘levelling up’ agenda. The Covid-19 pandemic has not impacted everyone equally and has thrown into sharp relief how those living in lower quality environments, without access to nature or culture have been particularly affected. Our goal should be to create more high quality, locally distinct places so everyone can enjoy nature-rich, green spaces on their doorstep, access to local heritage and shared cultural spaces that help bring communities together.
The planning system is one of the most powerful tools we have to shape places and deliver a positive future. The single biggest risk with this White Paper is that in the quest for speed and simplicity it simply does not adequately address enough of the above.
Our key concerns with the White Paper
We support the principle of an effective and proportionate planning system, that seeks to integrate and balance economic, social and environmental concerns, and we welcome the Government’s ambitions to do this. However, the National Trust fundamentally disagrees, as the White Paper suggests, that the planning system is the sole blocker to bringing forward housing delivery, growth and development in general.
Furthermore, we are concerned at the scale and pace of change, and the ability of an already overstretched planning sector to respond to the expansion of Permitted Development rights, changes to the current system and these long-term reforms. Whilst the system is complex and would benefit from simplification, the scale of change happening concurrently continues to make the system more complex, and harder to understand and navigate.
Alongside the scale and pace of change is the question of resource. Increases in the number of planning applications and burdens on Local Planning Authorities are happening in the context of a steady decline in the number of planning staff in local authorities and cuts to key statutory consultees such as Natural England and Historic England. Even the strongest, most evidenced and well implemented reforms cannot deliver the outcomes the Government wants to see without the necessary investment in the people and infrastructure that must operate the system in practice.
The zoning of land into growth, recovery and protected categories would be a major change. The success of the suggested approach would depend upon the availability of excellent up-front, easy-to-access data on environment, heritage and ecology which simply doesn’t exist at the moment. Most national strategic datasets need updating and investment, and in the new system this won’t be funded by developer’s site-specific assessments as it is now. The Government will need to address this significant data and funding gap – both now and in the long-term.
Even with proper investment, up-front data won’t be able to identify every asset such as hidden archaeology or the unexpected discovery of important and endangered species. Heritage and nature don’t fit neatly within boundaries. Nature migrates and will do more so in future as the climate changes. We therefore seek reassurances from Government that there will be clear mechanisms for considering these assets within the new system.
The ability to deal with strategic cross-boundary issues is one of the existing weaknesses of current system. The Duty to Cooperate has not generally been a success. We need to ensure in future that there is an effective mechanism for addressing environmental issues, including green infrastructure, at landscape, catchment and ecosystem scale.
Overall, we are concerned that there is little detail on how these proposals will support the Government to achieve its ambitions of the 25 Year Environment Plan, and what contribution the reforms will make towards helping to tackle climate change. The planning system must work in tandem with other initiatives to solve the nature crisis and reduce carbon emissions, and more work needs to be done to make it clear how the proposals in the White Paper will support this.
If delivered well, we do believe that the proposed reforms could produce good planning outcomes and improve the quality of our existing places and new developments. But change at such a fundamental level carries huge risks and addressing those risks successfully will require significant attention to detail. As well as increased funding and new systems and processes, this will require a cultural shift around decision making and the way everyone engages with the planning system.
The next steps in shaping and developing these proposals will be crucial. In order to fully understand the implications and potential unintended consequences of these reforms, and to ensure that the right safeguards, processes and guidance are in place, there needs to be additional and detailed consultation with stakeholders.
We would welcome the opportunity to contribute as the Government continues with these once-in-a-generation changes to the planning system.