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Analysis of the Planning White Paper 2020

Updated: Sep 16, 2020

Planning for the Future: What might it mean for Warrington?




It was something of a surprise to learn that the Prime Minister had been in Warrington on the day the new government planning White Paper was published – 6 August 2020. South Warrington, too – the proposed location of seven thousand homes on the green belt. And at a Barratt housing development. Of all the places...!


The Our Green Warrington team had been waiting for the White Paper for weeks, having been aware of broad government policy statements on the future of planning and housing development since March this year.


Last weekend, ahead of the publication of the White Paper, the BBC and other media sources announced that under the proposed changes to our planning laws building on the green belt would be “banned”. If this was to be the case there would be a potentially significant impact on Warrington Borough Council’s Proposed Development Plan - for mass housing estates and distribution warehouses across Warrington’s countryside.


So, now that the white paper has been published, will building on the green belt be banned?


Not really, is the short answer.


Headlines for the proposed planning changes focused mainly on fears over the consequences of “relaxing” existing planning laws and the threat of (even more) poor quality housing being thrown up without adequate oversight. The threat here isn’t government policy per se, nor to an extent even local council policy and attitude, it is the risk that housing developers, not known for their concerns over quality and sense of place would be allowed to run amok, unchecked, throwing up even more cramped, unattractive, cookie cutter, subpar housing in which we would have no choice but to live.


The government proposes that instead of dealing with planning applications on a case by case basis, there will be national guidelines and design codes to which developers must adhere. If they do this then there would be fewer barriers to building and little opportunity for local councils or indeed residents to raise objections. This understandably has set alarm bells ringing in planning departments across the country. We will have to see what the proposed rules and codes look like before commenting further but it would appear that once design codes and rules are set, there will be less power to challenge development at a local level. Whether you think this is a good idea or a bad idea may depend on your experiences of local council decision making when it comes to planning and development.


The broad thrust of the proposed new planning law process is modernisation, simplification, accessibility and facilitating the building of homes more easily. It is proposed that a more “zonal” approach be taken by local authorities in identifying land when producing their Local Plans for development in the area.


Under the new scheme land would fall into three categories for councils:


Growth areas suitable for substantial development


This is where outline approval for development would be automatically secured for forms and types of development specified in the Plan;


The White Paper states;


“We envisage this category would include land suitable for comprehensive development, including new settlements and urban extension sites, and areas for redevelopment, such as former industrial sites or urban regeneration sites. It could also include proposals for sites such as those around universities where there may be opportunities to create a cluster of growth-focused businesses. Sites annotated in the Local Plan under this category would have outline approval for development (see proposal 5 for more detail). Areas of flood risk would be excluded from this category (as would other important constraints), unless any risk can be fully mitigated.”


Reading the phrase “urban extension sites” may give cause for worry, given the Local Plan specifically intends for an “urban extension” and “garden suburb” to be the site of seven thousand homes in South Warrington. However, the plans relating to these developments would still have to overcome the fact that they are to be built on green belt, or “constrained land”.


Renewal areas suitable for some development


The White Papers indicates that this “would cover existing built areas where smaller scale development is appropriate. It could include the gentle densification and infill of residential areas, development in town centres, and development in rural areas that is not annotated as Growth or Protected areas, such as small sites within or on the edge of villages. There would be a statutory presumption in favour of development being granted for the uses specified as being suitable in each area.”


Protected areas


This is where, as the name suggests, development is restricted.


The White Paper says,


"This would include sites and areas which, as a result of their particular environmental and/or cultural characteristics, would justify more stringent development controls to ensure sustainability. This would include areas such as Green Belt, Areas of Outstanding Natural Beauty (AONBs), Conservation Areas, Local Wildlife Sites, areas of significant flood risk and important areas of green space.


"It would also include areas of open countryside outside of land in Growth or Renewal areas.


"In these protected areas any development proposals would come forward as they currently do now - through planning applications being made to the local authority and judged against policies set out in the National Planning Policy Framework."

The National Planning Policy Framework says the following about building on the green belt:


Protecting Green Belt land


“Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans.


Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period.


Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This will be assessed through the examination of its strategic policies, which will take into account the preceding paragraph, and whether the strategy:


a) makes as much use as possible of suitable brownfield sites and underutilised land;


b) optimises the density of development in line with the policies in chapter 11 of this Framework, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and


c) has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.


Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.


The National Forest and Community Forests offer valuable opportunities for improving the environment around towns and cities, by upgrading the landscape and providing for recreation and wildlife. The National Forest Strategy and an approved Community Forest Plan may be a material consideration in preparing development plans and in deciding planning applications. Any development proposals within the National Forest and Community Forests in the Green Belt should be subject to the normal policies for controlling development in Green Belts.

In other words, only the same protections will be in place for preserving the green belt. No more, no less.


Having read the White Paper in detail it seems that the following *could be key issues for Warrington.


*Other views are available!


Effective and prompt use of existing brownfield sites and identifying new brownfield sites that have become or will become available in the short and mid term.


This could provide housing, leisure and employment opportunities for the town. The need to prioritise existing brownfield sites has been stewing for a while and the White Paper could assist in creating a moral, political and legal imperative to focus on building on and renewing brownfield sites before anywhere else, including green space. While Warrington Borough Council’s own proposed Local Plan does state that the intention is to prioritise brownfield sites first, it has been all too easy in the past to favour green field land that requires no real work before building is started.


In the coming months and years there will no doubt be evolving opportunities for both growth and renewal of brownfield sites in the Warrington area so this obligation has to be an ongoing one. Fiddlers Ferry is one such opportunity, as is the site of Unilever behind Bank Quay station when it closes and is removed. Warrington Borough Council and their associates have already drawn up interesting plans for the area surrounding Unilever – called The Waterfront. The proposals include homes, employment areas and a country park. The location is surrounded by the Mersey and Our Green Warrington would love to see this area revitalised in an attractive and quirky way.


Beauty in our housing and built environment.



From Chapelford to Westbrook to Appleton to Burtonwood to Lymm to Winwick to Woolston to Grappenhall – and more. How many more generic, box houses are going to be crammed into bland housing estates?


The government says, “Planning matters. Where we live has a measurable effect on our physical and mental health, on how much we walk, on how many neighbours we know or how tense we feel on the daily journey to work or school. Places affect us, from the air that we breathe to our ultimate sense of purpose and wellbeing.”


They wish to “be more ambitious for the places we create, expecting new development to be beautiful and to create a ‘net gain’, not just a ‘no net harm’.”


“But improving the process of planning is only the starting point – we want to ensure that we have a system in place that enables the creation of beautiful places that will stand the test of time, protects and enhances our precious environment, and supports our efforts to combat climate change and bring greenhouse gas emissions to net-zero by 2050."


This is certainly to be welcomed – we absolutely need to move away from a monopoly of the large developers building car dependent estates of housing packed in so tightly you can see what your neighbour is watching on TV. We need to be more creative in the developments we build.


The White Paper says, “Ask for beauty and be far more ambitious for the places we create, expecting new development to be beautiful, and to create a ‘net gain’ not just ‘no net harm’, with a greater focus on ‘placemaking’ and ‘the creation of beautiful places’ within the National Planning Policy Framework.”


The issue of ugly buildings and their surrounding environment has long been discussed and there is consensus that the aesthetics of our built environment has a profound effect on our sense of worth, our mental health and our sense of place. The message seems to be cutting through – it was notable that in a recent Warrington Guardian report on a planning application for blocks of flats in the town centre the application contained the following;


“Appearance is reserved for determination at a later date but given the importance of the site within the town centre and the relationship to two conservation areas and a number of listed buildings (including The Kings Head and Three Pigeons pubs) the use of high quality materials will be essential.


"The applicant has indicated that the palette of materials would be influenced by the site’s historic context and could include brick, metal cladding and bronze detailing."


The render of the proposed building looks pretty good, although the 'myth' and 'reality' of proposed development renders versus their final appearance could fill a blog of its own. Perhaps it will. It would also be important for people who live there to have outside space, preferably their own private area. And there should be green where possible. For inspiration look at the Bosco Verticale in Milan or BedZED in South London.


The White Paper also says the government wishes to “make it easier for those who want to build beautifully through the introduction of a fast-track for beauty through changes to national policy and legislation, to automatically permit proposals for high quality developments where they reflect local character and preferences.” and “to provide better information to local communities, to promote competition amongst developers, and to assist SMEs and new entrants to the sector, we will consult on options for improving the data held on contractual arrangements used to control land…To address this challenge, this autumn we will publish a National Model Design Code to supplement the guide, setting out more detailed parameters for development in different types of location: issues such as the arrangement and proportions of streets and urban blocks, positioning and hierarchy of public spaces, successful parking arrangements, placement of street trees, and high quality cycling and walking provision, in line with our wider vision for cycling and walking in England with effective inputs from the local community, considering empirical evidence of what is popular and characteristic in the local area.”


Interesting.


We do need to provide opportunities for smaller, more original and imaginative housebuilding organisations to offer an alternative, better vision for where we live. We absolutely do need more beautiful housing and we hope that public pressure continues to build in this regard as well; the many, many surveys and polls carried out demonstrate quite clearly that average people are dissatisfied with the housing they are offered and are weary of ugly housing and bland estates.


As we’ve said before, we deserve better. But how will the proposed changes practically allow us to do this? How do we facilitate more beautiful buildings and places? How do we demand that unimaginative plans for mass housing be reconsidered? What mechanisms will be in place to allow us to do that?? With yet another Barratt housing development currently being built in South Warrington who gets to challenge these powerful developers? Does a typical Barratt house meet the new design code? How will we as a community influence these codes? What will “improving the data held on contractual arrangements used to control land” mean in practical terms for challenging arrangements between local authorities and the big developers?


These would be good queries to raise of the government at this stage – the White Paper is open for a 12 week consultation period and you are invited to have your say – so ask the questions.


Warrington green space, the green belt and the environment



This is one of the big issues for South Warrington – Warrington Borough Council has a current Local Plan that provides for seven thousand houses across green belt and green field in the forthcoming years. The plan has been challenged robustly and thousands of people responded during the “consultation” period due to outcry at the proposed destruction of the countryside in Warrington. The public’s responses thus far do not seem to have deterred the council. Will the new planning laws change that?


The government wishes to “promote the stewardship and improvement of our precious countryside and environment, ensuring important natural assets are preserved, the development potential of brownfield land is maximised, that we support net gains for biodiversity and the wider environment and actively address the challenged of climate change.


“In line with the ambitions in our 25 Year Environment Plan, we want the reformed system to play a proactive role in promoting environmental recovery and long-term sustainability. In doing so, it needs to play a strong part in our efforts to mitigate and adapt to climate change and reduce pollution as well as making our towns and cities more liveable through enabling more and better green spaces and tree cover.”


As we have explained above, the rules permitting development on green belt are that such building may only take place in “exceptional circumstances”. Warrington Borough Council has sought to circumvent this rule by claiming that housing numbers / need will be such that all brownfield sites will be exhausted in due course and therefore they must build on the green belt.


However, the council’s projected growth and associated housing need has already been challenged as a basis for building on the green belt – and as a result of the pandemic those projections will need to be revisited again. There also seems to be more scope for cross borough / county collaboration on housing numbers. This is a clear opportunity to pause and reflect on the current Local Plan, and the council should take it.


The proposed planning changes do not actually afford our green spaces and green belt any additional protections – the same rules apply as before. However, after so much political emphasis on our environment and green space we would hope and expect that the “exceptional circumstances” which permit development on green belt would be more stringently applied. If you question the government about nothing else in this consultation period, question this.




Having our say on what is built and where in Warrington


There has been concern that the proposed changes may reduce the power of local democracy when presented with development plans for their local area. There is also concern that limiting the consultation process will open the gate to rampant, ugly, substandard building everywhere with little opportunity to object.


The White Paper notes that “for too long, planning and planning decisions have felt out of reach from too many people. The Government has heard how the combination of technical jargon and traditional models of community engagement discourages people from having their say on decisions.”


And so the government says it wishes to “move democracy forward in the planning process and give neighbourhoods and communities an earlier and more meaningful voice in the future of their area as plans are made, harnessing digital technology to make it easier to access and understand information about specific planning proposals. More engagement should take place at the local plan phase.”


For those who object to the proposed changes, concerned that local democracy and the power we have to influence the planning process will be eroded: How’s that currently working out for you?


The White Paper says that the proposed changes will “improve the user experience of the planning system, to making planning information easier to find and understand and make it appear in the places where discussions are happening, for example in digital neighbourhood groups and social networks.” It also says that the “New digital engagement process will make it radically easier to raise views about and visualise emerging proposals whilst on the go on a smart phone”


How this will work in practice with our local council?


At present it is not easy to locate the correct information on Warrington Borough Council’s website and while, for example, over three and a half thousand responses were sent to the council’s proposed Local Plan, it is not clear exactly what cognisance has been taken of these responses and whether or not the council has any intention of taking them properly into consideration. In fact, only last week, the Warrington Guardian reported anger from local residents at proposals to dramatically expand the Omega site - when they had not been given sufficient information. Cllr Steve Wright is noted to have said, “I have made representations in the past about the way we alert people to things like this and we do the minimum I think… I think in matters like these we should go a bit further and try and make sure people are fully aware of what is being proposed, rather than just the basic minimum.”


And while easier digital accessibility is to be welcomed there are many people who don’t interact online and who do rely on the “signs on lamp posts” and adverts in local newspapers and libraries. What about these people? Can we not have both? Again – ask the questions.



Conclusions


It should be remembered that this is a “White Paper” – it’s not a new set of laws yet and the government have asked for responses from the public. So this is where you come in.


None of these proposals are set in stone and the White Paper does offer different options. We would encourage everyone to read the White Paper in full (yes it is actually longer than this blog…) and respond to the questions posed during the twelve week consultation process.


So on the basis of the proposed planning law changes will Warrington Borough Council have to rethink their current Local Plan and essentially start from scratch? Our Green Warrington would make the following observations:


There are some good ideas for development of current brownfield site that would likely fall into the “Growth” and “Renewal” categories in the Local Plan. There is also evidence of planning for homes in the centre of town, building adjacent to railway stations to reduce car use and for radical regeneration of the River Mersey area.


However, there is a strong argument that our economic environment is changing so rapidly that what may have seemed like reasonable growth and development projections even in 2019 are now out of date and must be revisited. This will affect future housing calculations. The White Paper acknowledges that with regards to Local Plans, “much of this evidence becomes dated very quickly, and production times often render policies out of date as soon as they are adopted”.


Importantly, the Local Plan does not have real provision for regenerating residential areas of Warrington that have been forgotten and overlooked for decades: the areas where there is deprivation, higher crime and few amenities – areas that have little green space, no trees and poorly designed “homes” with small windows and concrete views. Why is there not a plan to “green up” and make more attractive these places? Why should people who live here be ignored if the Local Plan is for the whole of Warrington? Not everyone can afford to live in an executive three or four bedroomed new build home – why should earning capacity be a bar to a green and beautiful place to live?


The Local Plan and current processes for public engagement employed by the council do not accord with the White Paper's aim of greater local democracy and input at the planning stage.


In light of the public’s views on the importance of green space and nature as a result of the pandemic is it really conscionable that a plan to build seven thousand houses on green belt proceeds? From an environmental perspective, should the council be permitted to eradicate vast areas of Warrington countryside and green space, leaving future generations with a severely depleted natural environment?


There is a moral and ethical imperative to protect and enhance our countryside and develop greater access to green space for everyone. The current Plan foresees the opposite. There is no justification for building on the green belt - and any arguments the council may have relied on in the past carry even less weight now.


Warrington Borough Council should take a moment in these extraordinary times to reflect and rethink what Warrington should be as a town, with an eye to our environment, our need for beauty and nature and plentiful green space and whether or not in fact, we could be almost a “national park” town – with our peculiar and wonderful situation of having the countryside next door.


HAVE YOUR SAY


The consultation process for the proposed planning changes is going to last for twelve weeks. Please read the White Paper in full and respond constructively – let’s see what we could do about strengthening rules on green space development and make a contribution to our future generations’ environment.




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