The Town and Country Planning Association are leading a review of the planning system and an interim report is available https://www.tcpa.org.uk/Handlers/Download.ashx?IDMF=8c619109-a721-4efc-8eac-c9ba8ecee4b5 for comment at raynsfordreview@tcpa.org.uk by 16 July.
I have complimented those involved
in this valuable exercise in a providing carefully considered and comprehensive
review of the planning system but then suggested that the Review adopts an
undesirable focus on ‘people’.
This is entirely understandable, and has not been to the exclusion of
references to the environment and biodiversity, but I believe that the interim
report is unduly anthropocentric. I am also coming round to the view that
planning at bioregional level and putting nature first (not to the exclusion of
people) could be made an attractive governing principle to which the warring
factions might be persuaded to subscribe. To do so would require a significant
amount of further research to make the case that biodiversity should be
prioritised.
Climate change also receives passing mention but
carbon emissions could also form a powerful governing principle as they attach
directly and indirectly to all forms of development and land management
(eg UNCTAD estimate that food systems are
responsible for 50% of carbon emissions). The threat to remove the current
duties imposed under the 2008 Planning
and Compulsory Purchase Act and 2008
Planning Acts could be acknowledged and proposed to be retained.
My concern started by looking at the 9 Propositions, none of which mentions the issues of biodiversity loss, soil degradation and local/regional food systems and agroecology. This would be regrettable, but understandable if the Review adopted the approach that the law should remain unchanged (where there is limited control over agricultural practices – mentioned as a consequence of the 1947 Act) and concentrated solely on planning policy. But the Proposition 6 actually suggests a change in planning law without any awareness that changes to the law (ie changes in agricultural practices could be development requiring permission) could prevent further erosion of the natural environment.
My concern started by looking at the 9 Propositions, none of which mentions the issues of biodiversity loss, soil degradation and local/regional food systems and agroecology. This would be regrettable, but understandable if the Review adopted the approach that the law should remain unchanged (where there is limited control over agricultural practices – mentioned as a consequence of the 1947 Act) and concentrated solely on planning policy. But the Proposition 6 actually suggests a change in planning law without any awareness that changes to the law (ie changes in agricultural practices could be development requiring permission) could prevent further erosion of the natural environment.
Analysis (extracts from Review followed by comment in
italics)
1. Given that a very large proportion of the
country is in use for agriculture (including horticulture and horsiculture) and
forestry, it is an anomaly that these uses are largely outside the scope of
planning controls. A description of how
the existing system could and should be promoting sustainable forms of
agriculture and forestry can be found at:
The case for changes to the system (ie the legislation is made at:
2. Many
national agencies have overlapping and ill-defined responsibilities. For
example, the growth area of the Cambridge–Milton Keynes–Oxford corridor
is defined by the work of the National Infrastructure
Commission, supported by the work of the Infrastructure. ..and Projects
Authority and Homes England, but their remit and accountability are separate
from those of the local authorities that ultimately have to drive
implementation on the ground. The decisions of multiple central government
departments and their agencies and other sub-regional bodies such as Local
Enterprise Partnerships, each with their own remits, will also be vital to the
success of the growth area.
Given the
sensitivity in the area affected by the proposed Expressway (a road being
promoted by the Treasury and Highways England) to enable car dependent
housebuilding between Oxford and Cambridge) I might be over-reacting to sense
some support in the Review for this evidence free central Government support
for a major new road. The NIC has both
supported the Expressway and condemned building of this type of road (in Congestion, Capacity and Carbon). The
scepticism about the Expressway is reflected in the suspicion of the LEP and
associated Growth Board where ‘growth’ appears to limited to outdated and
destructive models.
3. PROPOSITION
2: Planning with a purpose: The basic purpose of planning is to improve the
wellbeing of people by creating places of beauty, convenience
and opportunity….The
suggested statutory purpose of planning
would be to, to positively
promote the spatial organisation of land in order to achieve long-term
sustainable development. In the Planning Acts, ‘sustainable development’ means
managing the use, development and protection of land, the built environment and
natural resources in a way, or at a rate, which enables people and communities
to provide for their social, economic and cultural wellbeing while sustaining
the potential of future generations to meet their own needs. I would suggest that the ‘purpose’ of protecting and manage natural resources
goes much further than meeting human needs and should be nurtured by the land
use planning system for its own sake.
4. Permissions alone are now running well
in advance of demographic need,
(A Holmans: New Estimates of Housing Demand and Need
in England, 2011 to 2031.Town & Country Planning Tomorrow Series Paper 16,
Sept. 2013. Available at https://www.cchpr.landecon.cam.ac.uk/Downloads might
not be the best reference as the important trend is what happened after 2013.
5. EMERGING POLICY THEME 3: THE POWERS OF THE EXISTING SYSTEM
While the majority of the evidence submitted to the
Review focused on the recent reduction in the power of the existing system, there was a small but significant strand
concerned with the broader questions of the scope of the
spatial
planning system, and the case for the expansion of powers over land uses to
deal with climate change and biodiversity and to create a ‘people-centred’ system which
reflects human needs and behaviour. One example this was how planning could be
positively used for upland catchment planning to integrate the regulation of
land uses to reduce flood risk and build resilience. This would require an
expansion of control over agricultural land use and forestry and is
particularly relevant to places such as Cumbria or the vulnerable coastal strip
from the Humber to the Thames(p39)[emphasis added] The Review did not make it clear how biodiversity could be given
sufficient protection without a change to the ‘powers of the Act’ probably to
include agricultural use(s).
6. QUESTION
2: WHAT IS THE PURPOSE OF A SPATIAL PLANNING SYSTEM, AND HOW SHOULD THIS BE
EXPRESSED?
• Living within environmental limits:
Respecting the limits of the planet’s environment,
resources and biodiversity – to improve our environment and ensure that the
natural resources needed for life are unimpaired and remain so for future
generations. This is less anthropocentric
but would not be achieved without more fundamental changes that are being
considered un the Review.
7. Support for the
SDGs is welcome as is the cross –reference to the 25YEP. However, there is no specific mention of Goal
15: Protect, restore and promote sustainable use of terrestrial
ecosystems, sustainably manage forests, combat desertification, and halt and
reverse land degradation and halt biodiversity loss that does not say that this would be for human benefit.
8. QUESTION 3: WHAT SHOULD THE SCOPE AND
POWERS OF THE SPATIAL
PLANNING SYSTEM BE?
Its remit goes beyond land use planning to encompass a
broad concern
with how the management of land and buildings impacts,
for example, upon people’s health and wellbeing. The ‘powers’ should include the protection of biodiversity and soils
not just because this is essential to human health and wellbeing.
9. Proposition 5: A new commitment to
meeting people’s basic needs
While measures to increase public participation would
improve the process of planning, they need to be accompanied by rights to basic
outcomes which
reflect the minimum standards that people can expect
from planning. These outcome rights are an important balancing measure to
ensure that the needs of those who may not have a voice in the planning
process, including future generations, are reflected in the outcomes of
decisions. These rights might include:
• a right to a home;
• a right to basic living conditions to support
people’s health and wellbeing, secured through minimum design standards which
meet people’s needs
throughout their lifetime; and
• a legal obligation to plan for the needs of future
generations, through, for example, consideration of resource use.
These rights
should be embedded in the law and policy but so should an obligation to protect
nature.
10. Proposition 6: Simplified planning law
This displays an understanding that the current
legislation (since the exclusion of agricultural and forestry uses in 1947) is
not fit for purpose. If the Review can make out a case for change based on
other Propositions then this would be an opportunity to bring agriculture and
forestry under control. http://dantheplan.blogspot.co.uk/2016/01/if-agro-ecology-is-different-how-can.html
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