Comment

Raynsford Review: Key points

The final report of the Raynsford Review was published on Tuesday 20 November. The review began in June 2017 with the primary focus of appraising the kind of planning system that England will need from 2020 with the aim of identifying the ingredients for a successful and positive planning system.

Whilst the conclusions of the report make for interesting reading, Turley’s view is that there is little genuine need for such a root and branch review of the planning system at a time when there is a need for certainty and a focus on delivery. Yet another round of review and change is not what is needed right now. In addition, given the make-up of the panel and the objectives of the review itself, there is a danger that its approach is skewed to an academic, rather than practical perspective and that the focus on the politics of planning is too dominant. We are supportive of positive steps to focus the planning system on delivering the homes and jobs we need and in this regard, the report does identify food for thought on key areas.

Our views on the key points covered in the report are outlined below.

Accountability and participation

One of the central themes emerging from the review is the current lack of accountability and active participation which the public feel they have in planning decisions. The report is clear that planning is an important part of our democracy, but clear accountability is often perceived to be missing and consultation is often considered tokenistic. The review notes that communities and local authorities must have the powers they need to positively plan for the future and enable stakeholders to shape developments which have an impact on health and wellbeing.

In order to address these issues the review proposes 24 recommendations.

Local Plans for local people

One of the principal proposals is for a new kind of positive and powerful Local Plan which should be effective and which commands the confidence of all sectors. This new status would ensure that planning decisions that depart from the plan are strictly the ‘exception’ and that the status of the plan is pre-eminent. The report acknowledges that whilst this would be a major cultural shift it would help to build trust among all sectors, particularly the local community. There is also a push to make plan-making more efficient without removing key stages of public consultation which, it was felt, would undermine trust further. It is claimed the existing inefficiencies could be reduced by removing the duty to co-operate and seeking to ensure that plans are prepared on fixed timescales which align with others in the sub-region to ensure meaningful co-operation takes place.

The report taps into the feeling that there is a need to return local level powers that have been centralised. The most urgent of such issues is seen to be the restoration of control over the conversion of office and commercial buildings. There is also a push to ensure that communities play a greater role in making decisions.

Those in the development industry are likely to recognise many of the issues identified in the report, but will feel that these stem from the lack of positivity in plan making from local authorities and lack of positive engagement from the local community in planning for development needs.

Tier it up

Recommendation 12 of the review seeks to address this by promoting a smarter structure for planning which would consist of four interlocking tiers, which aim to ensure that development needs are identified and met.

This includes the creation of a National Sustainable Development Plan (NSDP) which would set out a national housing strategy which indicates preferred areas for strategic growth. This would take into account all of the Government’s national strategies including the Industrial Strategy, Infrastructure Needs Assessment and NHS strategies. This plan would provide key data on national and strategic growth issues.

The second tier would be sub-regional strategic plans which are acknowledged as providing value for the co-ordination of regional development but it was felt that the different levels of accountability were difficult to justify. It is made clear that the model of strategic planning in London is the most logical, with the accountability offered by the GLA and the London Plan, and a return to the standard regions of England would be a marked improvement on the current chaotic arrangements.

The third tier would be strengthened local development plans which would be the key co-ordinating strategy, but would reflect the ambition of being more people-centred.

The review advocates that a duty should exist which requires development plans to include policies which plan for the full range of housing needs, with a particular emphasis on high quality and affordable homes.

It is suggested that this duty is coupled with a requirement to ensure that plans are reviewed every five years, with a sanction that central Government intervention would occur where this does not take place. The review concludes that under these controls it would be much harder for a plan to be judged as ‘out of date’ during the five-year lifetime of the plan.

The fourth tier would comprise Neighbourhood Plans, which remain optional but would be subject to the same legal requirement as Local Plans in relation to sustainable development.  

National Strategic Development Plan

It is clear that the proposals and recommendations are the product of some serious thought. The involvement of the community in decision making can be a positive if a duty to meet identified housing needs is planned for, and if policies are reviewed every five years. However, the failure to adopt the proposals in totality could lead to development needs not being met if, for instance, the National Strategic Development Plan (NSDP) was not compiled as envisaged.  

The review makes reference to the legal framework that currently underpins the English planning system, claiming this has become more complex and confused. The question needs to be asked: would the addition of a new tier of plan making, in the form of the NSDP, address this point or add a further layer of complexity?

23 November 2018