Planning for the Future

29 October 2020

A missed opportunity?

Guildford Society has responded to the consultation on the Planning for the Future White Paper.  Although we can sympathise with the objectives to make the planning system simpler and the results better we have serious concerns that the White Paper doesn’t propose an effective solution.  Our concerns relate to:

  1. Is the Planning System really the problem?

The fundamental premise of the White Paper that the planning system restricts housing supply is wrong – 100,000’s of consented dwellings are never built. 

  1. Democratic Accountability

Democratic accountability is talked about in the White Paper but in practical terms ignored.  Thus, there is no discussion of the role of Local Government Planning committees, extremely limited time for public consultation on Local Plans etc.

The White Paper is silent on how to improve Public Engagement and Consultation apart from vague ideas on IT support. 


  1. Sustainability

Planning and the protection of our environment are intrinsically linked.  The White Paper is weak on providing clear guidance and targets for environmental issues – it is noticeable the White Paper presents a wish-list but fails to ask consultees any relevant questions!

The White paper is weak on linking development in a sustainable manner to Infrastructure Development.  This weakness was highlighted by Transport for the South East recently.

As the MHCLG highlight the Planning for the Future is a  “radical reform unlike anything we have seen since the Second World War” to avoid discussing how the new planning system could address matters such as Climate change is very disappointing.

  1. Focus

The White Paper is silent on how major repurposing and improving existing buildings and permitted development rights are to be managed. It is almost entirely focused on new urban development.  Managing the evolution of our existing building stock is important to make the best use of what is built and ensure it is upgraded effectively.

  1. Power to the Developer

We agree with the Town and Country Planning Association when it wrote:

‘the new system would give developers certainty on land allocation while allowing them to retain the ability to submit applications speculatively, to be determined by national policy, and by local design guides where they exist. The developer’s right to appeal against refusal decisions would also be retained. There can be no doubt that in principle this new system, including the parallel extension of permitted development rights, would give maximum benefit to the developer and minimum benefit to communities’

  1. Zones, Sites and Codes

The white paper proposes the concept of Zoning where broad planning principles would ‘wash over’ areas of the local area. This would be supported by Site Specific policies and Design Guides plus either Supplementary Planning Documents.  It is not clear this is a simplification on the current system.  A worked example could usefully be produced.

The White Paper commends experience with Zoning and Design Codes from other countries.  It is not clear that these are responsible for better planning – some countries have bad examples of zones of urban sprawl etc.

The proposed use of Pattern Books is genuinely concerning as many Developers abetted in some cases by Architects use this process at present – hence the number of very similar estates.

  1. Standard Method

The White paper proposes using a standard method to define housing demand.  The current proposed algorithm is overly simplistic and has no concept of strategically steering development. Planning for the Future appears to accept that some areas of the country will continue to be overdeveloped compared to other less economically successful areas. 

  1. IT Support

The White Paper proposes the use of IT as a key enabler.  The White Paper is very vague on what practically is proposed. 

Many local Authorities have invested in 3D Visualisation tools, GIS Planning and Mapping Systems.  These interchange data via known file types with Architects and Developers.  The Greater London Authority is a good example.   Government has an indifferent track record on IT, knowledge management, and associated business processes. 

Maybe all that is required is to encourage exiting LPA developments?

See links below to the White Paper our resonse etc.


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