In relation to the recent White Paper, our clients are asking “What about Neighbourhood Plans (NP)?” Indeed, the White Paper has left a large gap which begs that very question. Of course, the full impact of the proposals is as yet impossible to predict with certainty as this is merely a consultation and the final changes to law and policy will only become clear as the process progresses.
However, having discussed this with other professionals in our network, including, planning lawyers and Town Planners, we can offer the following personal views, distilled from what we are hearing.
It is clear that that through the White Paper, the Government very much want to retain and probably enhance the involvement of communities in planning decisions. Within the White Paper, the Government proposes to allocate housing numbers to Local Authorities which will in turn be responsible for “divvying up” this allocation within each Authority’s area. It is our view, that when it comes to communities undertaking Neighbourhood Plans, the LA will seek to allocate housing numbers in their area in conjunction with Neighbourhood Planners. Why would they not do this in consultation with local Parishes, Towns and Neighbourhood Forums as that would herald an inevitable return to the NIMBYism of the past? Your NP can therefore use these allocations to develop your NP and go on to develop suitable Design Guidance.
Given the proposed new 30 month deadline for production of Local Plans (which currently take up to seven years to adoption) we do not believe that LPAs will have either the time or the inclination to work out the detail of allocations locally. We also expect that all Parishes will be “strongly encouraged” to undertake Neighbourhood Plans, perhaps without actually making it compulsory. The penalty for not doing one would likely be having no say at all about what development is given to them.
· New local plans will be required to designate land into one of three categories:
• Growth, suitable for "substantial development";
• Renewal, suitable for "development - gentle densification"; or
• Protected, with more stringent development controls.
The paper suggests that LPAs call for suggestions for areas under each of these three categories in the first six months of the plan-making period (in a manner equivalent to the “call for sites” which many LPAs make in the early stages of preparing a local plan currently). We believe this will be the time when LPAs will be approaching local parishes and Neighbourhood Plan Groups to ask for their views and suggestions so that they can be included in the Local Plan.
• The paper also talks of increasing the use of digital technology and making these resources more available to Neighbourhood Plans. This would be likely to include a wide range of tools such as:
• an increased use of digital tools for engagement;
• interactive plans with machine-readable planning policies.
• creative platforms for neighbourhood plans.
• a wider range of data sets available to all; and
• planning officers with "geospatial capability and capacity”
Neighbourhood Planning is likely to be crucial in this process, which can only increase the effectiveness of this community engagement. For example, being able to access a wider range of participants through flexible consultation methods will improve the engagement process, by providing the first level of evidence for the Neighbourhood Plan. It is very encouraging that the White Paper suggests these digital tools will be available to NP groups as they are quite sophisticated (and becoming ever more so) and will increase the impact of the NP
o Neighbourhood Plans have already become a vital part of community engagement with strategic planning and we cannot see their role being diminished in the future. Given this, you will likely be in a far stronger position, the closer to being made the Neighbourhood Plan is. Also, bearing in mind just how long the White Paper will take to become new legislation and planning guidance, and, in the meantime, little might change and only time has been wasted.
o The Government has already put additional money into the NP grant funding scheme for 2020 (it is now possible to apply for up to £10k) and they have also put further funding in certain circumstances. We don’t believe they would do this if they intend to side-line Neighbourhood Plans
The final conclusion that we draw at this stage is the White Paper’s big focus is on addressing housing supply and providing 300,000 homes per annum via its new standard methodology, making it easier to secure approval, and to open the market to SMEs and self-build, and encourage densification in renewal areas. It should be remembered that in 2014/5 142,480 new homes – private, Housing Association and Local Authority – were commenced. In 2018/19, the corresponding figure was 163,910, so to increase this to 300,000 new homes will require a dramatic increase.
This is thus a huge “ask” and it will only be possible with the strengthening of Neighbourhood Plans and if LPAs are to reach their 30-month targets to produce Local Plans.
The White paper shows that government is very keen that local communities continue to be given the ability to produce design codes which will determine how development takes place within their communities. They refer to this as “participative design”. This will be two pronged: 1) allocation of sites; and 2) design of the development within that site.
Our views, as expressed above, are based on our own interpretation in conjunction with that of our professional colleagues and advisors. At this stage of the process all views rely heavily on personal interpretation. However, Plan-et will be responding to the consultation as above and will be continuing to observe the process closely to report on more details as it emerges. With reference of course to the impact on Neighbourhood Plans.
In the meantime, we encourage all our clients to continue working on their emerging plans as that is undoubtedly be the best way forward at this stage, and to ensure that you are properly prepared for the planning system of the future.
 MHCLG “House building; New build dwellings, England: December 2019. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/875361/House_Building_Release_December_2019.pdf