Planning for a Sustainable Future Analysis of Consultation Responses Background Report B Summary of other comments received on the White Paper List of Respondents to the Planning White Paper www.communities.gov.uk community, opportunity, prosperity Planning for a Sustainable Future Analysis of Consultation Responses Background Report B Summary of other comments received on the White Paper List of respondents to the Planning White Paper November 2007 Department for Communities and Local Government: London Department for Communities and Local Government Eland House Bressenden Place London SW1E 5DU Telephone: 020 7944 4400 Website: www.communities.gov.uk © Crown Copyright, 2007 Copyright in the typographical arrangement rests with the Crown. This publication, excluding logos, may be reproduced free of charge in any format or medium for research, private study or for internal circulation within an organisation. 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Fax: 01603 723000 or email: [email protected] If you require this publication in an alternative format please email [email protected] Communities and Local Government Publications PO Box 236 Wetherby West Yorkshire LS23 7NB Tel: 08701 226 236 Fax: 08701 226 237 Textphone: 08701 207 405 Email: [email protected] or online via the Communities and Local Government website: www.communities.gov.uk November 2007 Product Code: 07 COMM 04934/e Contents Annex 1: Summary of other comments received on the White Paper 6 Annex 1A: Planning White Paper Community Engagement Programme 14 Annex 2: List of Respondents to the Planning White Paper 18 6|Planning for a Sustainable Future Annex 1: Summary of other comments received on the White Paper The ARUP Analysis of Consultation Responses report focuses on the responses sent (both by post or e-mail) to the address set out in the Planning White Paper, Planning For A Sustainable Future. In addition to these formal responses, the Department also received a range of other comments on the White Paper proposals, from a variety of sources which are listed below. These comments have also been taken into account in deciding how to take forward the proposals set out in the Planning White Paper. There were five main groups of comments: 1. Comments made on the White Paper in correspondence sent directly to ministers in Communities and Local Government (CLG) or from Members of Parliament to ministers, reporting or reflecting views of their constituents; 2. Comments made at stakeholder events; 3. Feedback from a series of community consultation exercises conducted by Planning Aid on behalf of the Department; 4. Comments made in response to Government’s draft legislative programme; and 5. Views set out in petitions not submitted as formal responses to consultation. 1. White Paper Correspondence Around 500 letters were received by Ministers in Communities and Local Government directly or from Members of Parliament to ministers, reporting or reflecting views of their constituents over the consultation period from 24 May to 31 August 2007. Of these, over 350 followed a largely standard format, reflecting points of concern raised by various non-governmental organisations. Annex 1 Planning for a Sustainable Future |7 The vast majority of the largely standard format responses picked up 4 points of concern to Friends of the Earth, namely: • The proposal to give National Policy Statements more weight than any other statement of national, regional, or local policy could threaten vital policies such as the sustainable community strategy; • The proposals are bad for local democracy as people would lose their rights to be heard at Public Inquiries, being only allowed a possible ‘open mic’ style airing of views at the end of the inquiry, with no right to cross- examine and no guarantee that their views will be considered; • The proposals are bad for climate and the environment as the Government will be able to force through major expansions in airports, roads and incinerators that will lead to a huge rise in greenhouse gas emissions; and • The proposals will be bad for town centres as removing the “needs test” for retail development will result in more out of town stores, putting local shops and business at risk of unfair competition from the big four supermarkets. During the course of the White Paper consultation, Friends of the Earth also sent approximately 800 signed postcards to the Prime Minister. Although it was evident that these were printed and written in the context of the Barker and Eddington reviews, and in advance of then (forthcoming) Planning White Paper, the covering letter indicated that the postcards were indicative of “an escalating sense of unease” in regard to issues of “local rights and democracy”, the “abandoning” of the “commitment to sustainable development and the fight against climate change.” The principal points raised were to urge support for the plan led system and community engagement in the system and to avoid undue priority being given to economic development. In addition to the standard format letters, ministers received approximately 150 other letters which raised points in relation to the white paper. Of these, approximately 70 were letters to ministers from MPs responding to constituency concerns; approximately 80 were letters sent directly to ministers from members of the public, businesses, voluntary organisations and community groups. The main points raised in these letters were: (a) the role of the commission with regard to the public participation The principal issue of concern raised in the majority of the letters was the perception of a lack of accountability of the proposed planning commission. There were three main concerns: • the un-elected nature of the proposed infrastructure planning commission which was not democratically accountable, nor subject to Parliamentary scrutiny or any appeal mechanism 8|Planning for a Sustainable Future • the role of the national policy statements as the principal reference for decision-making – and that this would not give sufficient weight to the views of local people and • an overall perception of a reduced or secondary role of the public in planning decisions which was seen as an erosion of the rights of the public to be heard on matters which affected them. There was particular concern about the proposed “open floor stage on the grounds it was understood to be the only opportunity for the public to air their views; that it was only available after the end of the Inquiry with no right to cross-examine; and that there was no certainty that any views expressed at this forum would be properly considered (b) Climate Change A minority of respondents raised National Policy Statements and climate change as an issue of concern. Most comments were based on the perception that the proposals for major infrastructure projects amounted to an easing of planning control, with the consequence of an increase in carbon-intensive development, such as roads and airports. (c) the replacement of the “needs test” A large number of correspondents raised concerns about the proposed replacement of the “Need and Impact” test with a new test . Some made reference to press reports which speculated that the proposals would allow more out-of-town shopping centres. This last point – the increased dominance of supermarkets at the expense of local shops – was commonly stated as being of major concern. (d) the role of the public with regards to local development frameworks and development plan documents A similar number of respondents were concerned at the proposals to simplify the consultation stages within the local development plan. Many considered that this amounted to a “watering down” of the democratic process within local plan-making, with some believing that the proposals amounted to a removal of community consultation altogether. There were some who considered that the proposals were an attempt to increase central government control. There was an overall concern that the package of proposals relating to local plan-making and community involvement would have the effect of reducing local people’s rights to consultation or their impact. Annex 1 Planning for a Sustainable Future |9 (e) Householder Permitted Development Rights A number of respondents raised concerns about the White Paper proposals to amend the householder permitted development rights. Views were split on this matter. Some indicated that the measures, particularly in regard to loft conversions, were excessively restrictive. There were forecasts that most of the conversions which are currently permitted would, under the proposals, require planning permission. Some businesses – mainly the loft conversion industry – implied that they would suffer falling orders as a result of this; and that, far from freeing up the planning system from unnecessary development control applications, the proposals would add to them. In contrast, there were those who indicated the opposite: that the proposed measures would enable a proliferation of home extensions or loft conversions – including development in conservation areas. This last point is actually a misunderstanding of the proposals stated in the White Paper, but it was a commonly held view upon which there was considerable anxiety. Some were not convinced of the need for change at all. There were also concerns that permitted development would not take important factors, such as design, into account, thus affecting the character of an area. However, some were generally supportive of the proposals – with some keen to know when they would take effect.