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Brighton Society response to the MHCLG Planning consultation August 2020

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This response is in two parts:

Part 1 Preamble – which describes the background situation in Brighton & Hove and our general responses to the White Paper based on the planning problems we regularly encounter in the city.

Part 2 Our responses to the questions set out in the White Paper.

Part 1 – Preamble

1. Introduction
As a leading Brighton amenity society we are extremely concerned about the effect national planning policy is having on the urban and landscape heritage of our city – now, as well as in the future.

Our comments on the White Paper stem from that perspective. Planning policy in the city is suffering from several problems, which collectively are having a detrimental effect on the city’s urban landscape.

This response discusses those problems and evaluates the effect the proposed planning reforms are likely to have on them.

1.1 Planning issues in Brighton & Hove
Brighton & Hove is a historic city of international importance. It has almost 3500 listed buildings, and 34 conservation areas. In fact so much of the city’s central area is composed of conservation areas you could almost say the whole city centre is one big conservation area.

Our heritage includes not only our built environment but also our landscape formed by the South Downs National Park immediately to the north of the city, and the high chalk cliffs at the eastern end of the seafront.

It is crucial that our city’s historic elements are the most prominent features, and play the most prominent role in determining the character of our city – they cannot be allowed to be dominated by massive buildings totally out of scale and character with their historic setting.

The same applies to our topography – the landscape must dominate the buildings – not the other way around, as is increasingly the case.

Yet we are in danger of losing this high quality historic urban environment and landscape because of the tall massive developments currently being proposed (and often approved, either by the Council or on appeal), which are having a highly detrimental effect on the city’s skyline, its historic buildings and its landscape and seascape settings.

Page 8 of the consultation states that, “Our guiding principle will be as Clough Williams-Ellis said to cherish the past, adorn the present and build for the future”.

Do we think the White Paper does that? Answer: No.

There is not much sign of cherishing the past or adorning the present happening in Brighton & Hove at the moment. As discussed in the subsequent paragraphs, we consider it will be even less likely in the future if the White Paper proposals become planning law.

2. Need for housing
Of course we need more housing and the Brighton Society fully supports that aim stated in the White Paper.

Housing is a scarce resource and far too many people in Brighton & Hove often have no option but to live in generally cramped rented accommodation. Young couples who wish to buy a home and start a family, cannot find suitable and/or affordable housing and are forced to look elsewhere in Sussex and the south-east.

There is a lack of new low-rise high density housing with a small garden space. Far too many of the new housing developments proposed and approved are tall blocks of flats with little or no private open space – totally unsuitable for young families. 47% of the estimated housing demand in the city is for 3 – 4 bedroom family homes. That need is not being met.

Nor do the current national planning policies provide sufficient incentives or funding for affordable housing. (see para 12 below).

Will the proposed White Paper resolve these problems? Answer: No.

The only thing that seems to matter to the government is the numbers. See paras 4 and 5 below for more.

3. Threat of the algorithmic approach to development
The city’s situation, restricted as it is, into a narrow strip between the sea and the South Downs National Park, yet with a huge and vitally important urban heritage, is particularly threatened by the algorithmic approach to defining housing need proposed in the White Paper.

If the claims are correct that the city will have to accommodate 860 more homes annually (ie, 1,520 total) than the Local Plan currently provides for, then we’re in big trouble – particularly as the average delivery over the last 3 years has only been 392 per annum.

Where, might we ask, are all these new homes going to go? Particularly if – as we are advocating – new development should be height limited in order to protect the city’s urban heritage.

There is an answer – that is to concentrate on building low-rise high density. This can achieve astonishingly high housing numbers. The most densely populated neighbourhood in the city is the area between Western Road and Lansdowne Road in Hove, bounded by York Road to the east and Lansdowne Street to the west.  It consists mostly of 5 – 6 storey Victorian terraces, usually with semi-basements. At 315 persons per hectare this area is also the most densely populated area in the south-east outside London (Brighton & Hove City Snapshot Summary of Statistics 2014).

That equates to 31,500 persons per sq. kilometre. For comparison, several arrondissements in central Paris vary between 28,000 to 42,780. Manhattan is only 27,826.

So we already have low-rise high density precedents in the city.

What we need is a national planning policy which

– recognises, allows and encourages local authorities to relate their housing needs to the potential for meeting those needs by formulating individual policies which relate to specific individual areas of the city;

– enables a diversity of possible solutions suitable for particular situations, and rather than follow the fashionable trend to tall buildings as the only answer to the housing problem in cities, encourages local authorities to look for appropriate solutions which actually provide the housing type, the amount and the density of housing that are needed and fits well within the existing urban environment.

In the case of Brighton & Hove that precedent can be found in our own back yard.

But where in the White Paper can we find any hint of a planning policy which could help achieve that aim? Does the algorithmic approach achieve it?

Answer: No way

Councils must be allowed to tune their planning policies to suit the particular characteristics of their towns and cities, including such criteria such as history and situation, and they must involve the local community. The outcomes of such policy choices will then dictate the best ways to formulate their housing policies.

Algorithms can’t and won’t.

4. The Council has lost control
But we might also wonder whether in practice it’s going to be much worse than the current situation.

The Council’s freedom to determine its own policies is completely hamstrung by its inability to guarantee a 5 year housing supply. Recently it turned down a 17-storey scheme in Ellen Street, Hove, only to see its decision overturned on appeal. The developers Matsim, (worryingly now in control of the Grade 1 Listed Hippodrome), immediately sold it on to another developer, pocketing the profit. (A perfect example of the way developers gain at the expense of the community referred to in para 7 below). A new 18-storey proposal inappropriately called Hove Gardens, has now been approved by the Council which capitulated in order to avoid the risk of losing another appeal.

Also, the Council recently turned down the massive Sackville scheme in Hove, only to approve a slightly revised scheme, knowing it would probably lose on appeal were it turned down a second time.

In the last few weeks it has failed to stop an appeal being lodged on the huge 28-storey Marina development – this time by a failure to make a decision within the required timescale.

Are any of these huge housing developments providing the affordable family homes needed? Answer: No.

Large developers marshall every argument to show why affordable housing is economically unviable, and councils do not have the expertise to argue back.

As we pointed out above, 47% of the total city’s housing requirement is for 3 – 4 bedroom homes, but all the recent large developments mainly consist of 1 – 2 bedroom flats with no gardens. And the affordable housing component of all of them is negligible or non-existent.

Essentially the Council has already lost control of major developments proposed in the city, and the large property vested interests are running the show in their own interest – not in the interests of the city.

Will the proposed White Paper resolve these problems? Answer: No. It will make the existing unsatisfactory situation even worse.

Only something as radical as repealing the 1961 Land Compensation Act (discussed below in para 11) will redress the balance by sharing the planning gain between the community and developers more equitably.

5. The Numbers game leads to skewed results
Planning policy is currently driven by numbers – regardless of the types of housing actually needed. As a result the numbers of new homes applied for and granted in Brighton & Hove are primarily one and two bedroom flats, mostly in high rise blocks, not family homes of 3 – 4 bedrooms with gardens, which accounts for 47% of the housing demand.

Does the proposed White Paper resolve this? Answer: No.
The numbers game fiasco is to be even further reinforced by algorithms.

6. Sites with Planning approval remaining vacant
Many schemes for which planning approval has been granted have not been started. The developers are not building on those sites because the shortage of homes relative to demand means they are sitting on an asset which is rising in value – and as an investment, is making far more money than cash in the bank would.

Does the proposed White Paper resolve this? Answer: No, not at all.

7. New housing used as an investment tool
Many of those flats that have been or are being built are bought by overseas landlords and rented out at high rents or sit vacant rising in value. That isn’t helping local people buy new homes even if they could afford them, which in most cases they couldn’t.

Other developers, once they have planning approval, then sell on to another developer, pocketing the profit from the increase in land value.

Does the proposed White Paper resolve these problems? Answer: No.
See para 11 below for the solution.

8. Neighbourhood Planning
Neighbourhood Plans and Neighbourhood Forums should have created much more community involvement in planning policies and decision-making. But the take-up in the city has been slow, the procedures are onerous and cumbersome and far from conducive to local engagement. See our response to Questions 13(a) and 13(b) in Part 2 below.

Does the proposed White Paper increase community involvement and make it easier for local residents to become involved? Answer: No.

We wonder whether local neighbourhood plans in future will be worth the paper they are written on (forgive the non-digital expression).

9. Community involvement
In Brighton & Hove community involvement, particularly in larger development schemes is usually quite inadequate. Council policy requires developers to carry out a public consultation prior to a planning application being lodged but most developers treat this as tick-box exercise – in fact many of them are just that – tick box surveys asking such vital questions as these extracts below from a recent consultation:

– Do you like the appearance and form of the revised development proposed?  
– Do you support the need for providing more homes in this part of the city? 
– Do you support the need for providing new office and other commercial units in this location that will create new jobs for the city?
– The majority of the revised scheme is ground floor plus six storeys in height rising to ten storeys.  (ie 1 + 10 = 11) Do you agree that taller elements of the scheme above six storeys are acceptable?
– Do you agree that new facilities such as a gym, roof top restaurant and café will benefit the area? 
– Overall, do you support the proposed mixed-use redevelopment of the site?

Pretty loaded questions – how the developers expect to get a fair response based on questions like that is anybody’s guess. That isn’t a proper public consultation. When we tried to find out the results, we were told they would only be made available after the planning application was lodged.

Other developers try to hide vital information like the heights of buildings by cutting off the upper storeys from their CGI perspectives. One public consultation was so bad we wrote an article about it entitled, …an exercise in public obfuscation? – https://www.brighton-society.org.uk/edward-street-quarter-an-exercise-in-public-obfuscation/

We consider that for large scale developments, initial proposals should be introduced for discussion with the local community well before the designs become set in concrete. By the time the public gets to know about them it is usually long after the initial proposals have been discussed with Council planning officers, design consultants such as Design South-East, and all the major decisions about plans, heights, appearance, car parking, effects on the adjacent areas of the city have already been finalised.

Groups of local residents and community groups just fight a losing battle against this system.

Does the proposed White Paper resolve this problem? Answer: No.

In fact, categorising development into growth, renewal and protected areas in order to speed up the planning process, will actually take even more influence away from the community.

Anyone who has had direct experience of protesting against large-scale developments will attest to the amount of time, dedication and energy it requires. The White Paper does nothing to encourage more community involvement. Just the opposite.

10. Design quality
Will the proposals improve the standards of design of buildings, streets, open spaces and amenities? Hard to see from an analysis of Pillar 2 which suggests that this aim could be combined with a policy of “fast-tracking” using designs from pattern books.

Lots of questions there too. Who writes the pattern books? Who ensures the diversity of detail to reduce uniformity and banality and create originality and creativity? What styles would be appropriate in different situations? Will there be pattern books which take account of local styles and materials? Will there be a pattern book for rural situations on the outskirts of villages? And another for suburban areas of large towns and cities? Will there be pattern books for low-rise high density developments or just for tall blocks of flats? Who resolves disputes?

An idea which appears to be superficially attractive is potentially full of loopholes, pitfalls and unforeseen consequences.

Will the proposed White Paper improve design quality? Answer: No.

The real problem is that developers and most architects working for developers, have no training or interest in designing buildings which are polite, respectful and sympathetic to their surroundings. The result is all too often an overbearing, unsympathetic building design which in terms of scale, height, materials and form has little relationship to the surrounding urban environment.

Developers actively encourage this attitude. How often do we hear the phrase “landmark building”? It invariably means a tall block with luxury flats on the upper floors projecting high up above its neighbours.

Design standards should also include space standards which are well above the minimum areas typical of most large-scale developments recently approved in the city. The UK’s standards are generally well below those of many European countries, which in the light of Covid-generated ‘working from home’ lifestyle, means that so many of our housing developments have totally inadequate spaces before they even get built.

These space standards should also include a substantial amount of private external open space, particularly as so many young families are forced into high rise blocks of flats without immediate access to the outside. This is yet another reason why low-rise high density schemes should be preferred to high-rise blocks.

Environmental and sustainable ‘green’ design should be insisted upon as part of the planning system but the standards would be better included within Building Regulations to allow them to be improved as technology develops without continually having to change the planning rules.

There are architects who can design good buildings. But developers rarely employ them.

Many developments often aren’t even designed by someone with a formal design training or qualification.

Local authorities rarely have in-house design expertise, so there is often no-one (apart from amenity societies such as ourselves), monitoring design quality. Fortunately this improvement is suggested in the White Paper. See our response to Question 20 below.

Addressing issues such as these will improve design quality – not pattern books.

11. Policy of land value capture
When planning permission was first made mandatory by the 1947 Town and Country Planning Act, it incorporated a provision that land was sold at ‘existing use’ value. This was intended to ensure that there would be a sufficient supply of land to enable housebuilders to obtain it at a reasonable price which would be reflected in a purchase price for new homes and would be affordable for a wide range of the population.

But this admirable policy intent was seriously watered down by subsequent legislation during the 1950s and early 1960s. Just like today in relation to the current planning ‘reforms’, pressures from development interests persuaded the government of the day to water down the principle of ‘existing use’ value. An example of this was the 1961 Land Compensation Act which ensured that landowners and developers were entitled to the full increased land valuation after planning permission was granted.

The result was a system which stoked speculation and restricted the supply of land at enormously inflated prices. So now, despite the increase in overall wealth in society, the proportion of younger people of family age who are able to own their own homes is a fraction of what it was 30 years ago. In 1991 in the 25 – 34 age group most likely to be young families, 67% owned their own homes; in 2019 it is only about 38%. That is an appalling indictment of past and present government housing policies.

Any properly reformed planning system would have to include two crucial proposals:

1. Firstly it would have to re-introduce the concept of ‘existing value’ back into the equation in order to ensure the community benefits most from the increase in land value rather than the developer.

The White Paper makes a few gestures in terms of reforming and simplifying the Section 106 and CIL (Community Infrastructure Levy), procedures – but that’s about all. It’s nowhere near enough.

2. Secondly it would also need to propose reversing the 1961 Land Compensation Act – one of the pieces of legislation which undermined the intentions of the 1947 Act.

Do the new planning reforms propose these crucial changes? Answer: No.

In fact they will strengthen the developers’ influence and disadvantage councils and the local community.

12. Affordable housing
Like so many areas of the country Brighton & Hove has experienced poor delivery of affordable housing in anywhere near the numbers required. We also have a growing problem of homelessness.

Re-balancing the planning gain situation suggested in para 11 above so that local authorities benefit much more from increases in land values than they do at present, could improve this situation.

At the moment they have to compete with large private developers for land suitable for housing. There is no contest.

Additional central government funding for affordable housing should be provided to local authorities and housing associations, and the current financial and procedural restrictions on both should be considerably relaxed.

Does the White Paper propose such policies? Answer: No

13. Windfall sites & SMEs
Planners invariably underestimate the contribution small windfall sites can make to meeting housing targets. Here in Brighton & Hove the number projected on an annual basis in the City Plan is only about one third of the number of sites that were actually developed on the same annual basis in the past few years.

The difference would amount to about 2000 new homes in the period up to 2030 – a not insignificant proportion of the 13,200 target set out in the City Plan.

A policy of encouraging and incentivising SMEs – who develop the smaller sites – would be likely to increase the numbers even more and reduce the imbalance whereby large developers tie up development land in their own interests, rather than building on it.

Does the White Paper do this? Answer: No

In summary, you will have gathered from the views set out above that we have a pretty negative reaction to the White Paper.

It occasionally includes tempting palliatives about improving appearance and design, but basically it seems to be primarily a Housing Delivery policy, not a Planning Policy in the wider sense of the term.

In overall terms it reduces the ability of local councils and communities to influence what kind of developments will occur in their local areas and puts more influence in the hands of developers, many of of whom are already acting against the public interest in gaming the system to maximise their profits.

And, like all radical proposals to make major changes to procedures which have been built up over a long period of time, we are very aware of the ways in which the laws of unforeseen consequences can cause major problems in the future.

There is enormous potential for those sorts of future pitfalls in this White Paper as it stands.

Part 2 – Brighton Society answers to questions

Question 1. What three words do you associate with the planning system in England?
Could be better

Question 2. Do you get involved with planning decisions in your local area?
Yes

Question 3. How would you like to find out about plans and planning proposals in the future?
Through on-line searches which are tailored to particular classifications. It would be very helpful if lists of planning applications could be classified in different ways. For example our local authority issues weekly lists of planning applications but if you want to find what applications have been made say in a particular Conservation Area or a number of Conservation Areas, such information is only available if you search the whole list. That can be very time-consuming. More short cuts to assist with more focussed searches should be developed in order to highlight major development applications and different types of application.

Question 4. What are your top three priorities for planning in your local area?
Protection of urban heritage
Good and polite design
Community involvement in the planning process

Question 5. Do you agree that local plans should be simplified in line with our proposals?
In principle this is an interesting idea – but we are dubious as to whether it would produce better results than the existing system of local plans. The merit of the existing system is that all areas, particularly in existing communities, can be fine tailored to the individual requirements of a particular area. For example under the current proposals, if there was a listed building such as a church within an area designated for growth, how would it be protected from harmful development in the surrounding area? Would “statutory presumption in favour” ensure this protection? We doubt it.

Question 6. Do you agree with our proposals for streamlining the development management content of local plans, and setting out general development management policies nationally?
We are strongly against any extension of the NPPF remit for development management. We have seen the disastrous application of NPPF policy to housing targets in Brighton & Hove. It doesn’t work in the overall interests of the city.

Question 7(a). Do you agree with our proposals to replace existing legal and policy tests for local plans with a consolidated test of “sustainable development”, which would include consideration of environmental impact?
It is not clear from the White Paper how this proposal would work in practice. It sounds as though current protections would be watered down, which we would disagree with in principle.

Question 8(a). Do you agree that a standard method for establishing housing requirements (that takes into account constraints) should be introduced?
We would be very suspicious of any “standard method”. The whole point of having a planning system is to allow particular solutions to be fine-tuned to particular areas or sites. Standard methods won’t do that. And it appears to propose retaining the Housing Delivery Test which, as we have highlighted in our preamble paras 3 and 4, has severely disabled the ability of our Council to control its planning policies.

Question 8(b). Do you agree that affordability and the extent of existing urban areas are appropriate indicators of the quantity of development to be accommodated?
This question has to be decided at the local level in accordance with the wishes of the local community.

Question 9(a). Growth areas. Do you agree that there should be automatic outline permission for areas for substantial development (growth areas) with faster routes for detailed consent?
No. Nothing should be automatic.

Question 9(b). Renewal and protected areas. Do you agree with our proposals above for the consent arrangements for renewal and protected areas?
No. We are very suspicious of the effects the NPPF is having on our local planning system. The focus must be on community involvement at the local level, not national policies imposed from the top down.

Question 9(c). Do you think there is a case for allowing new settlements to be brought forward under Nationally Significant Infrastructure Projects regime?
This doesn’t appear to be mentioned or discussed in the consultation paper.

Question 10. Do you agree with our proposals to make decision-making faster and more certain?
We agree that everyone would benefit from more certainty. But this is far better achieved by involving the community at a much earlier stage than it is at present.
It might also speed things up a bit but probably not a significant amount. That isn’t so important. One of the problems with large scale developments is the sheer quantity of information contained within a planning application. It is unrealistic to expect the local community – many of whom have other family and work commitments – to absorb and evaluate the complicated documentation that is involved.

Early community engagement could reduce this greatly to the benefit of both developers and the community.

Question 11. Proposals for accessible, web-based local plans?
Much of this information is already available in digital form, and most local community representatives are used to using it. That said, it could certainly be improved – for example 3D maps and models of the local built environment would be very useful in evaluating the impact or otherwise of development proposals on an existing neighbourhood, and would be a good way to involve the community in becoming involved. People understand models far better than plans and lengthy documents.

But these digital improvements should be made alongside the more traditional methods of imforming the public, such as notices on lamp posts and in the locality of proposed development and planning applications. Getting rid of these simple but effective and ionformative methods would be a retrograde step. Not everyone is digitally connected or aware.

Question 12. Do you agree with our proposals for a 30 month statutory timescale for the production of local plans?
No. It’s far too short. It takes time to get things right, particularly if the local community is to be closely involved. But the effort would be worth it – and potentially would much reduce the extent of subsequent opposition to developments which comply with the policies set out in local plans, and could result in a quicker approval process as a result.

Question 13(a). Do you agree that Neighbourhood Plans should be retained in the planning system?
Yes – most certainly. Neighbourhood plans could be one of the best ways to stimulate people’s interest and involvement in the planning process and give everyone – including developers – a feeling that they have a stake in making a contribution to the life of our communities.

Question 13(b). How can the neighbourhood planning process be developed to meet our objectives, such as the use of digital tools and reflecting community preferences about design?
There are no short cuts here. Setting up a neighbourhood forum is not the work of a moment. A successful neighbourhood forum needs to attract a lot of support, needs a lot of personal involvement from its members and involves a lot of time engaging with the local community.

The way it currently works is that programmes tend to be governed by deadlines for the various stages including engagement with consultants. There is a temptation to try to move too fast so that consultants become involved too early before policies have even been discussed, let alone finalised. The whole system needs to be much more flexible to accommodate particular local situations – otherwise time and money will be wasted.

Relaxing the timescales and procedures and providing more support from local planning authorities would be by far the best way of encouraging the growth of neighbourhood planning.

Question 14. Do you agree there should be stronger emphasis on the build out of developments?
Yes. The situation where developers obtain planning approval and then sit on the sites waiting for the value to go up is unacceptable, and contrary to the public interest. Financial sanctions should be applied to developers who do not start a continuous building programme within a reasonable timescale – say 12 to 18 months after approval, dependent upon the size of the development.

Question 15. What do you think about the design of new development that has happened recently in your area?
As far as large scale developments are concerned they are generally extremely poor. They are too tall, out of scale, unimaginative, unsympathetic to their surroundings, ugly and boxy and treat new public spaces as leftover canyons where the sun never shines… In a city with an exceptionally high number of beautiful heritage buildings, the majority of these new developments are an indictment of current standards of acceptable design, the ambitions of their developers and the abilities of their designers. This doesn’t seem to bother most local planning officers or planning committee members whose primary interest seems to be meeting government housing target numbers.

Question 16. What is your priority for sustainability in your area?
Today’s buildings and open spaces are our heritage of the future. The highest environmental, energy saving and design standards currently possible must apply.

Question 17. Do you agree with our proposals for improving the production and use of design guides and codes?
Yes. The words ‘local’ and ‘community’ are the essential components in the preparation of design guides.

Question 18. Do you agree that we should establish a new body to support design coding and building better places, and that each authority should have a chief officer for design and place-making?
Yes. Most local authorities including Brighton & Hove, do not have adequate in-house design expertise available. This is a constant source of concern to us as again and again we come across failures where one department such as Highways just do what they please in sensitive heritage areas without consulting the Heritage Team in the Planning Dept – or anyone else for that matter.

We would make the proviso that the design assistance must be locally based and have strong links with the local community. Too often (where it exists at all), design consultants come from miles away with no roots in the local community.

Question 19. Do you agree with our proposal to consider how design might be given greater emphasis in the strategic objectives for Homes England?
We have no experience of Homes England, but if they are able to help local communities provide more, better designed and affordable housing then yes, we would agree.

Question 20. Do you agree with our proposals for implementing a fast-track for beauty?
No. We have grave doubts about how pattern books would work – see para 10 of our preamble above.

We would support in principle – subject to further details on how that might work in practice – the idea of design guides and codes which are truly locally-generated, and are not imposed on local communities.

We would oppose extending permitted development to create “gentle densification”.
Who is to say such developments would fully comply with the applicable design codes? It would appear that the developer’s interpretation of compliance would be the only restraint – in which case that policy would be completely unacceptable.

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