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Planning to fail: net zero is impossible without urgent changes to planning policy, CPRE analysis finds

Posted 8th Apr 22, filed under Environment

*CPRE wants all Local Plans to demonstrate how they will deliver a reduction in private car mileage*

Reaching net-zero carbon emissions by 2050 is impossible without urgent changes to national planning policy, analysis by CPRE, the countryside charity, has found.

A study of all 24 Local Plans outside Greater London that have been adopted since the Climate Change Act was updated in 2019 shows just one local authority has introduced a quantified, strategic-level carbon-reduction target.

No other local authority has a Plan to hit net zero. In each case, government planning inspectors have been content to sign off Plans without making tackling the climate emergency a central priority. A study of inspectors’ reports produced before plans are adopted showed an average of only one mention of ‘climate’ for 24 mentions of ‘housing’.

Housing, transport, business and industry generate 62 per cent of our carbon emissions. That is why CPRE is calling for the climate emergency to be urgently put at the heart of planning decisions so we have a realistic chance of hitting net zero by 2050.

For this to happen, the National Planning Policy Framework must be amended so that:

• All new developments demonstrate a measurable reduction in net carbon emissions over the life of the development

• All Plans demonstrate how they will deliver a reduction in private car mileage

• Any plans to boost housing and employment must also be justified on the basis of the additional carbon reductions they will deliver

• All councils must have their net-zero carbon target integrated across the Local Plan as a whole, and this should be an additional test of soundness at examination.

Planning inspectors must give as much weight to environmental targets as they do housebuilding targets. Yet national planning policy has failed to keep up with climate-change legislation, leaving ambitious carbon-reduction targets impossible to achieve.

CPRE’s research shows how national planning policy sets detailed and specific housebuilding targets, with planning inspectors regularly requiring changes to local authority plans that fall short. Conversely, climate targets are generalised, subjective and hard to enforce, with no evidence that inspectors find fault with plans on environmental grounds.

Commenting on the research, Crispin Truman, chief executive of CPRE, said:  

“We’re not going to hit net zero by accident – we need to plan for it. Unfortunately, local authorities are hamstrung by national planning policy that is woefully behind the times on this issue.

“Local Plans need to act like road maps plotting the path towards the sustainable future envisaged by the government’s climate-change legislation. The fact that they don’t come close to doing so is proof of the failure of current national planning policy.

“In terms of climate, we are planning to fail. It is impossible to hit net zero if it isn’t prioritised in Local Plans. Providing the attractive, affordable homes that people need and ensuring it is environmentally sustainable is not an either/or trade-off. We need to do both at the same time and with the same level of commitment.

“Worryingly, CPRE’s research has found clear-cut evidence that planning inspectors routinely force local authorities to adopt housebuilding targets with no attempt to reduce greenhouse-gas emissions. Worse still, there is no evidence of any serious effort to reduce car journeys – new developments are frequently planned on the edges of towns with no requirements to provide better public transport or cycle lanes to reduce road journeys.

“We found not a single example of planning inspectors demanding changes to Plans to ensure they reduce carbon emissions. This was in sharp contrast to how Local Plans must itemise and quantify how they will meet housing needs. Both objectives are important, but there is a stark difference in emphasis. It’s time for a revitalised, net-zero-focused planning system to increase biodiversity, enhance the countryside’s ability to soak up carbon and create sustainable places to live.”

Changing how places work to make them a lot less energy-hungry is a crucial step on the road to net zero – and the planning system is the means to do it. Local Plans need to radically reduce public dependence on car travel, including the introduction of thriving ‘20-minute neighbourhoods’ that place housing, amenities and workplaces within walking distance of each other.

Industrial and commercial developments could be permitted on the condition they install solar panels, helping create a modern network of rooftop renewable energy that would reduce pressure on the countryside.

A renewed ‘brownfield first’ approach would redevelop land and buildings in the heart of communities where housing is most needed, retaining and reusing the embodied carbon.

Monday, April 4, 2022

Enough is enough! Scrap the Housing Delivery Test and stop rewarding developers’ failure to build homes already approved

Posted 26th Jan 22, filed under Planning

*There are already enough houses with planning permission or allocated within an adopted Local Plan for “another Maidstone” to be built in Kent in the next five years*

Richard Thompson, CPRE Kent planner, lays out how disastrous governmental planning policy is desperate news for Kent

The publication of the 2021 Housing Delivery Test results, combined with existing lack of five-year housing supplies, now puts Kent in the frankly ridiculous position where 11 out of its 13 councils are being punished for developers’ failure to build homes already approved.
The Housing Delivery Test is a backwards-looking assessment that compares how many houses having been built in a council’s area over the last three years against the government-set housing number for that area. The result is given as a percentage of homes built against this target, with increasingly severe punishments the lower this percentage is.
The National Planning Policy Framework five-year supply test is a forward-looking assessment of whether enough houses have been granted planning permission, or are allocated within a Local Plan, to ensure this same government-set housing requirement is likely to be built.
The point is, both tests see the imposition of a housing target on a council and then punishes it for not meeting this target. However, the reasons the targets are missed are largely factors completely outside of their control. That is, it can grant as many planning permissions and allocate as much land as it can, but unless it starts physically building the houses itself, it is at the mercy of market forces.
Private housebuilders will, however, only ever build at a rate that the local housing market can absorb. They are not going to build at a level that over-supplies a local housing market as this would force them to reduce prices and lower profits. They are also currently subject to practical constraints such as labour and material shortages.
As of March 31, 2020, (from when the most up-to-date Kent-wide numbers available) some 64,611 new houses either had planning permission or were allocated within an adopted Local Plan and were expected to be built within the next five years. For context, that’s already enough houses for another Maidstone planned for Kent over the next five years.
Yet this is not deemed enough.
Because of either the Housing Delivery Test or the five-year supply test, nine of Kent’s councils are subject to the most severe of punishments: an automatic presumption that speculative planning applications will be granted, even if they are contrary to democratically adopted Local Plans.
Of the remaining four councils, two must produce action plans setting out how they are to increase housebuilding in their areas. The full 2021 Housing Delivery Test results, along with the last published five-year supply figures, are shown below:

Area Name	Housing Delivery Test: 2021 measurement	Current five-year supply (years)	Consequence
Ashford	118%	4.54	Presumption
Canterbury	65%	5.13	Presumption
Dartford	105%	5.63	None
Dover	88%	5.56	Action plan
Folkestone and Hythe	85%	5	Action plan
Gravesham	57%	3.27	Presumption
Maidstone	170%	5.6	None
Medway	67%	1.78 – 3.03	Presumption
Sevenoaks	62%	2.89	Presumption
Swale	78%	4.6	Presumption
Thanet	78%	4.23	Presumption
Tonbridge and Malling	63%	2.89	Presumption
Tunbridge Wells	97%	4.83	Presumption

The real-world consequences for Kent of this absurd policy are stark. Councils across Kent are rushing through ever-increasingly unsustainable Local Plans in a fruitless endeavour to beat the presumption punishment. In Kent, this often entails allocating ever-increasing housing numbers on greenfield land, which is more profitable and hence more likely to developed quicker, making them more attractive to councils needing to boost housing delivery in the short term to meet the five-year supply test.
In the meantime, speculative applications are being allowed either by councils or at appeal (because of the current presumption punishment), causing anger and disenfranchisement among local communities.
And it is not just us saying this. In calling for the Housing Delivery Test to be suspended, Canterbury City Council chief executive Colin Carmichael has stated “it cannot be right to punish councils that are working hard to do what the government asks even when most of the levers councils need to pull are out of their control”.
We agree. Only it’s not just the councils that are being punished, it’s the people of Kent who have lost a democratic voice to oppose speculative development. It is Kent’s special countryside that is being sacrificed to this developer’s charter.
And the government wonders why the people of Kent are so angry with the current planning system.

Wednesday, January 26, 2022

The revised NPPF is out! Not bedtime reading maybe, but it’s going to play a big part in planning policy

Posted 29th Jul 21, filed under Planning

This year’s NPPF consultation focused largely on design codes and ‘building beautiful’

A revised version of the National Planning Policy Framework has been published this month (July) – see here.
The new incarnation follows this year’s consultation, which focused primarily on incorporating design codes and building-beautiful recommendations.
The full government consultation response can be found here, while the original comments made by CPRE to the consultation are here.
The changes are largely incremental and as anticipated though are to be formally applied from the date of publication (Tuesday, July 20) for both Local Plans not yet at examination and planning decisions.
For immediate practical purposes, all paragraph numbers from paragraph 53 onwards have now changed – here is a tracked version illustrating the differences between the February 2019 version of the NPPF and this latest edition.

For more on the NPPF, see here

Thursday, July 29, 2021

Gravesham Green Belt: fight for it or lose it!

Posted 6th Nov 20, filed under Campaigns

Downs Road, Istead Rise, where 165 homes could be built

Local people are being urged to fight for the Green Belt in Gravesham.
Below is a list of the sites under threat and Alex Hills, Gravesham chairman of CPRE Kent, is making clear what is at stake.
“Many of these sites are on prime farmland, which is much needed for food supply,” he said.
“The proposals will result in villages merging, while no account has been taken of the impact of the new Thames crossing or the planned theme park.
“Many of the locations have poor public-transport links and the infrastructure is not there to support the developments.
“The sites in Meopham and Istead Rise will increase traffic on the A227, which is already facing at least a 10 per cent increase in traffic from the new Thames crossing.
“Further, these developments would destroy important wildlife habitat.
“Please, if you want to protect the Gravesham countryside, write to your MP and your ward councillor.”
Proposals in the Gravesham Local Plan Regulation 18 (Stage 2) Consultation could see 425 new homes in Higham, 275 in Istead Rise and 1,705 in Meopham, plus commercial development.

Sites under threat:

Land west of Wrotham Road (Site B), next to Helen Alison school, Hook Green, Meopham. Meopham North: 120 dwellings
Land at Longfield Avenue, New Barn, Istead Rise: 25 dwellings
Willerby Farm, 2 Downs Road, Istead Rise: 10 dwellings
Land west of Walmers Avenue, Higham Shorne, Cobham and Luddesdown: 40 dwellings
Land north of Steeles Lane, Meopham DA13 0QQ (behind houses south side of the green). Meopham South: 95 dwellings
Land north of The Drove Way, Istead Rise (behind the island): 75 dwellings
Land west of Norwood Lane, Meopham (Churchways, Meopham). Meopham North: 150 dwellings
Former Tollgate Hotel, Gravesend: commercial
Land adjacent to Higham station: commercial
Canal Road, Higham: 10 dwellings
School Close, Hook Green, Meopham. Meopham North: 15 dwellings
Land to the south of Green Lane and east of Wrotham Road, Hook Green, Meopham (opposite Camer Parade). Meopham North: 350 dwellings
Land at and adjoining Buckland Farm, Chalk Road, Higham: 40 dwellings
Land north of Camer Road, Hook Green, Meopham (Norwood Lane to Sole Street). Meopham North: 520 dwellings
Land north of Melliker Lane, Hook Green, Meopham. Meopham North: 160 dwellings
Land between Melliker Lane and Longfield Road, Hook Green. Meopham North: 180 dwellings
Land to the north, east and west of Three Crutches. Higham/Shorne, Cobham and Luddesdown: commercial
Rose Farm, Downs Road, Istead Rise: 165 dwellings
Land to the east and south of Lomer Farm, Wrotham Road, Meopham (behind Cricketers Drive): Meopham North 115 dwellings
Land between Lower Rochester Road, Hermitage Road and School Lane, Higham: 85 dwellings
Land between Taylors Lane and School Lane, to the north of High View, Higham: 250 dwellings

You can learn more from Gravesham Borough Council’s Local Plan Core Strategy Partial Review and Site Allocations Document and Development Management Policies Document here

Friday, November 6, 2020

‘We fundamentally disagree with the inspector’s conclusions and believe key parts of the Local Plan requirements have been incorrectly interpreted’: Sevenoaks begins judicial review proceedings in planning battle

Posted 22nd Apr 20, filed under News

The authority is making good on its warning that it would not back down

Sevenoaks District Council has taken its challenge of the Planning Inspectorate to the next level by beginning judicial review proceedings.
The move comes in response to a government-appointed inspector’s refusal to endorse the council’s new Local Plan.
The inspector, Karen Baker, wrote her final report on the examination of the Plan on March 2, concluding it was not legally compliant in respect of the council’s duty to cooperate.
She had advised the council of her view in a letter to the local authority in October in which she wrote: “I have significant concerns about a number of aspects of the Plan, both in terms of legal compliance and soundness.
“My main concern relates to the lack of constructive engagement with neighbouring authorities to resolve the issue of unmet housing need and the absence of strategic cross-boundary planning to examine how the identified needs could be accommodated.”
However, not only did the council, which is being told its Plan should include the building of 11,312 homes, refuse to withdraw it but its leader, Peter Fleming, gave a fierce response to the inspector’s letter:
“It is clear to me the way this has been handled calls into question the integrity of the whole Plan-making system in this country…
“To call into question an evidence-led approach comes to the root of our concerns with the actions of the inspector. If we are not to follow the evidence to make our Plan then the government may just as well dictate how many homes an area should have and then pick sites, we need to put an end to the thinly veiled charade that Local Plans are in any way locally led.”
Cllr Fleming is now making good on his warning that the council would not back down: “I will be writing to the Secretary of State on this matter and urgently asking him to intervene,” he said in October.
“It appears something is very wrong with the system if a council with its communities works hard for four years to produce an evidence-based Plan that delivers housing, jobs and infrastructure investment, whilst protecting the environment, only to be halted by a single individual.
“We will not be withdrawing our Local Plan and the inspector will produce her report in due course. We will then take the strongest action open to us.”
The council says its Plan submission included more than 800 pages of evidence detailing how it had worked with neighbouring authorities during its production of the Plan. It adds that those councils and other organisations involved in its development supported the council’s evidence and approach.
And on Friday last week (April 17) Cllr Fleming said: “Taking legal action is not something we would undertake lightly and demonstrates we are serious about standing up for our residents and our cherished environment, against what we believe is a fundamental failure by the Planning Inspectorate to take account of the weight of evidence in front of them.
“Working with landowners, communities and developers, our new Local Plan put forward innovative solutions to deliver almost 10,000 homes and improved infrastructure while protecting nearly all of our Green Belt. It’s a huge frustration that, after so much work, we cannot take our Plan forward at this time.
“In our view, concluding we failed to cooperate with neighbouring councils was the only way to halt the examination. We reject this. We gave the planning inspector detailed evidence of our work with our neighbours and, from the start, they said they couldn’t accommodate the homes we could not deliver.”
Julia Thornton, cabinet member for development & conservation, added: “Our Local Plan is the first in the country to be assessed under a new planning framework. We believe, whilst this is not the reason the inspector has given, failing to meet the government’s housing figure would potentially impact on subsequent Local Plans across the country.
“If the inspector did have significant concerns over our duty to cooperate, these should have been raised soon after we had submitted our Plan, not months later. We fundamentally disagree with the inspector’s conclusions and firmly believe key parts of the Local Plan requirements have been incorrectly interpreted.
“We feel have no choice but to take this course of action.”
Robert Jenrick, Secretary of State for Housing, Communities and Local Government, which is responsible for the Planning Inspectorate, will have the chance to respond before a judge decides if the case should proceed.

You can read more on this story here and here

Wednesday, April 22, 2020

Sevenoaks sticks to its guns and refuses to withdraw draft Local Plan from examination

Posted 20th Jan 20, filed under Planning

Sevenoaks Council District Council is on collision course with the Planning Inspectorate after refusing to withdraw its draft Local Plan from examination.
Planning inspector Karen Baker in October last year warned the local authority that she would issue a report concluding its Plan was unsound if it was not withdrawn.
Her letter, sent on Thursday, October 17, said: “I have significant concerns about a number of aspects of the Plan, both in terms of legal compliance and soundness.
“My main concern relates to the lack of constructive engagement with neighbouring authorities to resolve the issue of unmet housing need and the absence of strategic cross-boundary planning to examine how the identified needs could be accommodated…
“Furthermore, I have significant concerns about the soundness of the Plan in respect of a number of areas including the approach to sustainability appraisal, the chosen strategy for growth, the assessment of the Green Belt and housing supply and distribution.”
Council leader Peter Fleming promptly gave a stinging response : “It is clear to me the way this has been handled calls into question the integrity of the whole Plan-making system in this country…
“To call into question an evidence-led approach comes to the root of our concerns with the actions of the inspector. If we are not to follow the evidence to make our Plan then the government may just as well dictate how many homes an area should have and then pick sites, we need to put an end to the thinly veiled charade that Local Plans are in any way locally led.”
The council has stuck to guns and on Wednesday, January 8, put a forthright statement on its website:
“In the latest response to the planning inspector, Sevenoaks District Council has vowed not to withdraw its draft Local Plan, despite continued pressure to do so,” it read.
“The council’s strategic planning manager, James Gleave, confirms in the response dated 3 January that the council will not voluntarily withdraw its Local Plan from examination and continues to disagree with the conclusions made by the planning inspector.
“The government-appointed planning inspector, Karen Baker, wrote again to the council on 13 December 2019 urging it to withdraw the Local Plan from examination.
“She repeating her belief that the council has not carried out its duty to co-operate with neighbouring councils to find sites for new homes that cannot be delivered due to constraints such as the Green Belt.
“The inspector believes the council had not done enough to address the ‘unmet housing need’ despite the proposals achieving almost 90 per cent of the government’s housing target.
“Mr Gleave goes on to say while the planning inspector highlights the council’s perceived failings, she does not provide a clear understanding of what constructive engagement with neighbours should be.
“She fails to take the pragmatic approach expected in the legislation and ignores significant evidence, much of it from the council’s neighbours and independent experts.”
The council statement is concluded by leader Cllr Fleming, who says: “I will be writing to the Secretary of State on this matter and urgently asking him to intervene.
“It appears something is very wrong with the system if a council with its communities works hard for four years to produce an evidence-based Plan that delivers housing, jobs and infrastructure investment, whilst protecting the environment, only to be halted by a single individual.
“We will not be withdrawing our Local Plan and the inspector will produce her report in due course. We will then take the strongest action open to us.”

For more on this story, see here

Monday, January 20, 2020

Goodbye and thank you from Brian Lloyd

Posted 2nd Feb 16, filed under Blog

We said goodbye to Senior Planner Brian Lloyd on Friday. He had worked for CPRE Kent for eight years and transformed the way we dealt with local plans and planning applications and issues. As well as making a major contribution to the plan making process across the county he was involved with neighbourhood planning and advised, trained and helped parish councils.

Brian and his partner Jean, photo by Paul Buckley

Brian said: “A big thank you to everyone that came along to my leaving party on Friday and to those that contributed towards my leaving gifts – a camera and membership of Kent County Cricket Club for 2016. This was extremely generous, and most unexpected, as were the lovely flowers presented to Jean. It was wonderful to see so many people who had travelled from all corners of the County to send me off. I am really looking forward to having time to do the things I have not been able to, especially when the better weather comes, and spending more time at cricket will most definitely hit the spot. It has been a privilege to meet and work with so many people who feel so passionately about Kent’s countryside, and it’s has been inspiring that so many people give so much time to CPRE and their communities to try and ensure that future generations can enjoy it as we have been able to. I wish you all well and I am sure that I will see many of you again in the future.”

Hilary Newport presents Brian with his gifts, photo Paul Buckley