Cllr Johnson Situ Cabinet Member for Climate Emergency, Planning & Transport Peckham Ward Ministry of Housing, Communities Cabinet Office and Local Government Southwark Council 2 Marsham Street P.O Box 64529 London London SE1P 5LX SW1P 4DF [email protected] 22 October 2020 Ref: JS-033 Dear Mr Jenrick, RE: Southwark Council Response to the Planning for the Future Consultation Within the foreword of this White Paper, you state that the Government is seeking to overhaul the planning system – cutting red tape, not standards – to create a framework that is more efficient, effective and equitable. As our record demonstrates, Southwark Council is a leader in effective planning. Since 2004, we have approved 10,542 genuinely affordable homes. We are the largest landlord of social housing in the capital, fourth largest in the UK and our current programme of housebuilding is delivering over 35,000 new homes including 11,000 council homes by 2043 with a target of 50% being genuinely affordable to respond to the over 10,000 families on our housing waiting list. We recognise the need for the planning system to evolve but we are deeply concerned by the proposals set out in this White Paper – many are simply unworkable in an inner-London borough like Southwark whilst others represent an unacceptable threat to local democracy and the delivery of affordable housing for our communities. Firstly, shifting the focus for consultation away from individual planning applications and towards the plan-making stage threatens to remove the role of communities in the later stages of planning process. Such a step could enable developments to proceed without meaningful consideration of the communities who are currently using the site and living using the surrounding area. Equalities impacts will not be taken into consideration and the opportunity to engage and involve local communities to enable development to contribute positively for people who currently live, use and work on and around the site along with the new inhabitants will be lost. Alongside this concern, by extending the ‘Permission in Principle’ for major developments, landowners and developers will gain a fast-tracked route to securing in-principle permissions without working up detailed plans. These measures damage local democracy – how can communities have confidence in a planning system that erodes their ability to comment on specific proposals once the detail is published? In Southwark, there are networks of active community groups who engage in the variety of planning issues, from plan-making to individual applications. Southwark Planning Network (SPN) is an informal network of active members of many neighbourhood community groups who are engaged in planning in the borough. Those groups are a key way to encourage many more local people to engage with the planning system. Southwark Group of Tenants Organisation (SGTO) is an independent voluntary organisation representing and promoting the rights of tenants and residents groups within the London Borough of Southwark. SGTO has been involved in campaigning for better housing conditions, tenants’ rights and tenants’ involvement in decision-making. Southwark Law Centre has, since 2017, had a project focussed solely on planning advice and representation called planning voice. Community Southwark is a Community and Voluntary Sector body that serves as an umbrella organisation in the borough. These are all examples of the active organisations in Southwark who engage in planning in the borough and members of all these organisations take part with Southwark Council officers in the Regeneration for All Liaison Group. In this group, there are discussions on how the planning system can be improved, and benefit the wider community and realise positive outcomes for all. As Southwark is a densely populated inner- city borough every planning decision has a potential impact on a significant number of people. Planning decisions need to be carefully balanced and have input from the community and people who they directly impact upon at plan making and planning application stages. Moving to a one-size fits all national approach also questions the role and value of local plans and Area Action Plans (AAPs). London-wide, such a system questions the approach of the London Plan and even the role of the Mayor of London in citywide planning. Along with the rest of capital, Southwark residents have an opportunity every four years to directly elect a Mayor of London – creating a planning framework and housing strategy that works for our city is major part of that office. These proposals erode that portfolio, presenting a citywide threat to democracy. The government’s strong rhetoric on devolution and metro-mayors evidently conflicts with this position. Beyond the risks posed to democracy and the community engagement process, the proposed changes to the Community Infrastructure Levy (CIL) and Section 106 will curtail the ability of local authorities to secure equitable levels of affordable housing, social rent homes and other community infrastructure needed to mitigate the impacts of any new development. Specifically, raising the threshold for ‘small sites’ exemption to 50 units would have disastrous effects on the delivery of such affordable and social rent housing. In Southwark, that would equate to a staggering 37% reduction in affordable housing yield – totally 3,050 units over the next decade. These payments have yielded affordable housing worth £6 million in 2016; £13 million in 2017; £40 million in 2018 and £40 million in 2020. The zoning proposal presents substantial technical challenges for a densely populated inner- London borough like Southwark. Our ‘urban grain’ is intricate, with large scale, high-level towers placed adjacent to historic buildings; where modern housing and office developments sit carefully within and between conservation areas. We have also placed our response to the Climate Emergency at the heart of our vision for the borough; planning policy is essential to the delivery of that vision. It is deeply disappointing that this White Paper makes no significant mention of any requirement for local plans to pursue carbon emission reductions in line with the net zero target under the Climate Change Act. As a borough, we have committed to a target of being a carbon neutral by 2030. That ambition is dependent upon a framework that empowers local authorities to make planning decisions that promote positive environmental and public health outcomes. The Government is facing a crucial question from this perspective: whether to follow Southwark’s lead and seize this moment to align the Planning Act and Climate Change Act in a direct and meaningful way. As the UK looks to recover from the coronavirus pandemic, the importance of place and more specifically the quality of one’s home cannot be overstated. Southwark is committed to improving the lives of our residents and we recognise that an effective planning system is essential to enabling the objective. However, the majority of proposals set out in the White Paper will not help yield higher levels of genuinely affordable and social rent homes and they will not facilitate our mission to reducing health and income inequalities. Trying to construct a one size fits all planning approach for a borough as densely developed and diverse as ours would be a major mistake. In short, the Government has placed great emphasis on localism and devolution over the last decade, council and communities must be at the heart of the system to create quality, safe and affordable places for our communities to live, thrive and grow. It is for these reasons that Southwark Council vigorously opposes the measures set out in the Planning for the Future White Paper. Yours Sincerely, Cllr Johnson Situ Cabinet Member for Climate Emergency, Planning & Transport Southwark Council’s vision for our Planning System Our vision for our Planning System is for Delivery, Diversity, Digital and Democracy 23 O ctober 2020 www.southwark.gov.uk Foreword – Cllr Johnson Situ – Cabinet Member for Climate Emergency, Planning and Transport Southwark is committed to improving the lives of our communities through providing genuinely affordable homes, green accessible spaces; affordable workspace and reducing health and income inequalities. Our planning policies are also at the heart of our approach to ensure the benefits of growth in the borough benefit all. Consequently, we are incredibly proud that in recent years we have seen major increases in the number of social and genuinely affordable housing approved, with the last financial year seeing Southwark top the list of London boroughs with social housing starts on site. We have also placed our response to the Climate Emergency at the heart of our vision for the borough, which we have already started introducing into planning policy. However, all of our gains are now under threat with the current Government consultation on the planning white paper, which has been criticised by planning experts, community groups and politicians across the political spectrum. This Government will have the public believe that these proposals will enable more homes to be built, that another reform of the planning system will unlock the a wave construction, we disagree and we point to a study by the LGA that found only half of homes consented in recent years have actually been built. We are clear these proposals are flawed and will not provide the conditions in which we can improve the wellbeing of our residents. Our concerns are that these proposals present are a threat to local democracy, a threat to delivery of genuinely affordable homes and barely mentions the biggest threat to our way of live in the coming decades, the Climate Emergency. These proposed reforms to the planning system are not based on evidence. In short, this council will not stand by as this Government introduces planning policies which will risk the gains we have achieved in recent years.