Written evidence submitted by Andrew Longley MRTPI, Head of the North Northamptonshire Joint Planning and Delivery Unit [FPS 147] Background 1. The North Northamptonshire Joint Planning and Delivery Unit (NNJPDU) is a partnership between the districts/ boroughs of Corby, East Northamptonshire, Kettering, Wellingborough, and Northamptonshire County Council. It reports to a Joint Planning Committee1, the strategic planning authority for the area, and a Joint Delivery Committee set up to coordinate delivery of the ambitious growth agenda. 2. The Joint Planning Committee adopted the country’s first Joint Core Strategy (JCS) in 2008 and completed a review in 2016. This includes plans for 35-40,000 new homes over a 20 year period, with 6 Garden Communities at the main towns having a combined capacity for over 25,000 new homes. The JCS also identifies the opportunity for Tresham Garden Village. These strategic developments are supported through the Government’s Garden Communities programmes. 3. The JCS forms Part 1 of the Local Plan for North Northamptonshire. The partner LPAs prepare more detailed Part 2 Local Plans and are responsible for development management. The JPDU provides technical support including urban design input. 4. In April 2021 North Northamptonshire will become a unitary authority and will commence preparation of a new Part 1 Local Plan. The area lies within the Oxford-Cambridge Arc and the new Council will wish to engage positively in preparation of the Arc Spatial Framework. 5. The following responses reflect the NN Joint Planning Committee’s representations on the Planning for the Future White Paper and the proposed changes to the current planning system. Response to the Select Committee’s questions 1. Is the current planning system working as it should do? What changes might need to be made? Are the Government’s proposals the right approach? 1.1 While there is scope to improve the planning system, we do not accept the central premise of the White Paper that the planning system is failing. This is not the case in North Northamptonshire. As set out above, we have well- established joint working arrangements, with an up-to-date and ambitious Joint Core Strategy. The Partner councils have adopted or are well advanced in preparing their Part 2 Local Plans to provide important local detail. Our high- performing development management teams2 consistently achieve top-quartile performance, and our design work has been widely recognised as good 1 established by SI 2005 No 1552 2 BCW were runners up in Planning Team of the Year in this years’ Planning Awards 2020 practice, resulting in our selection for the national ‘Future Place’ initiative in 2019. This positive planning framework, together with support from Homes England and the Government’s Garden Communities Programme, has helped us to deliver a nationally significant scale of growth. We have an ambition to continue to do this as part of the Oxford-Cambridge Arc. 1.2 We therefore consider that the focus of the White Paper on deregulating and simplifying the planning system in favour of the development industry is misplaced. Greater attention should be given to creating the conditions for growth through investment in infrastructure, jobs and the environment, and to measures to ensure that the development sector builds out consented sites without delay. 1.3 The White Paper proposes a radical overhaul of the planning system but gives little detail of how proposals would work in practice. This will create considerable uncertainty and disruption, which could impede rather than speed up development. We would prefer a refinement/ evolution of the existing planning system and the NN JPC response suggests potential improvements to some of the measures in the White Paper. 1.4 Our response to the White Paper highlights proposals that we support. These include some elements of streamlining local plans, the strong emphasis on design, greater digitisation of planning processes, and a resources and skills strategy for the planning sector. Significant resources will be required to implement these proposals and we welcome the Government’s commitment to provide financial support to enable local planning authorities to transition to the new planning system as part of the next Spending Review. 1.5 Our response raises some significant areas of concern with the White Paper, including: a. The heavy emphasis on housing delivery and lack of detail of other key elements of the planning system including the response to climate change, environmental protection and enhancement, infrastructure delivery and employment. b. The simplistic approach to local plans – with just three types of land, and unrealistic timescales given the need to frontload technical work and consultation. c. The loss of local control and flexibility arising from binding top-down housing requirements and the inclusion of development management policies in national policy (NPPF). The JPC has separately raised strong objections to the proposed standard method for calculating local housing need. d. Abolition of the Duty to Cooperate and lack of information about how strategic, cross-boundary issues should be addressed (through mechanisms such as the Spatial Framework for the Oxford-Cambridge Arc). e. The White Paper proposes a less regulated system with more permitted development and more Permission in Principle. This has significant resource implications in relation to front-loading technical work and consultation. At the same time, it would reduce income from planning fees and charges. f. Permission in Principle and other mechanisms for automatic consent would also reduce consultation and democratic input in the development management process. This may be acceptable for small scale proposals, but not for major developments. 2. In seeking to build 300,000 homes a year, is the greatest obstacle the planning system or the subsequent build-out of properties with permission? 2.1 In North Northamptonshire the greatest obstacle is subsequent build-out of properties with permission. 2.2 The planning system in North Northamptonshire is not a significant constraint on housing delivery. Over 13,000 new homes have been built between 2011 and 2019 and capacity is identified for over 30,000 more (including over 22,000 plots on sites with planning permissions). This high volume of planning work puts substantial pressure on the local planning authorities and ongoing support through the Garden Communities programme and other funding streams is essential. 2.3 The promoters of the Garden Community sites (with total capacity for 25,000 homes) report that viability constraints and delays in delivering key infrastructure (examples include junction 10a on the A14, the Isham- Wellingborough Improvement) are the main factors that will impede progress as these developments are built out. Support from Government and its agencies will be vital in overcoming these constraints. 2.4 We would also encourage Government to identify and introduce a range of measures (both incentives and penalties) to encourage the faster build out of consented land and to prevent developers from land banking and slowing the release of consented housing land to maximise sales values and/or increase their chances of achieving planning permission for other speculative sites. It is disappointing that the recommendations of the Letwin Review do not feature in the White Paper proposals. 3. How can the planning system ensure that buildings are beautiful and fit for purpose? 3.1 We support the strong emphasis that the White Paper puts on design. We have concerns that further deregulation of the planning system is at odds with the objectives of promoting high quality design. It is however important that the important that the concept of “beauty” is properly understood as the aesthetics of individual buildings is only one ingredient of successful placemaking. 3.2 Design codes should not become catalogues for pastiche designs; nor should they stifle innovation and creativity in design. The design process, particularly for large sites, needs to be iterative and flexible in order to respond to changes in circumstances including changing demands, viability and technology. It is unrealistic to assume that the developer or local planning authority will be able to resolve all design issues at the Local Plan stage. 3.3 The NNJPDU monitors the quality of new housing development using Building for Life 123, and we will be using its update, Building for a Healthy Life 2020, as a key tool in assessing and shaping development proposals. It is noted that the NPPF recognises Building for Life at para 129 and it would be helpful if Building for a Healthy Life 2020 is similarly endorsed in national policy. 3.4 There is too much scope within the current planning system for developers to drive down quality to maximise profit. Recurrent design issues that need to be addressed in most schemes audited against BfL 12 in North Northamptonshire relate to lack of connectivity and legibility, poor street scene, lack of character and sense of place, car parking and bin storage. 3.5 Further national policy and guidance on design issues, including an updated Manual for Streets, will be helpful in raising design quality but the key to delivering good design is the capacity and skills available at the local level (both for plan making and in development management). The NNJPDU provides a shared design resource for the partner LPAs and we utilise Design Midlands for design reviews. However, we are still reliant on consultants for the capacity to address an escalating workload. We therefore welcome the commitment in the White Paper to a resource and skills strategy for the planning sector and look forward to seeing further detail of this. 4. What approach should be used to determine the housing need and requirement of a local authority? 4.1 A standard methodology provides a useful starting point for setting housing requirements in a Local Plan but should not be binding and it is essential that the methodology is robust.