Summer Newsletter 2024

The King’s speech on 17 July promised ‘planning reform … to accelerate the delivery of high-quality infrastructure and housing.’ The Planning and Infrastructure Bill will streamline the delivery process for critical infrastructure, reform compulsory purchase compensation rules, improve local planning decision-making, increase local planning authorities’ capacity, and use development to fund nature recovery.   

This is all very promising, but what do we, in the industry, think successful reform of our planning system should look like?  Firstly, it should be plan-led, to build much-needed certainty and consistency, increase trust and fairness, and reduce piecemeal development and litigation. 

At the national level, we need a spatial plan or land use framework, coupled with development management policies that address the critical issues of housing, urban regeneration, infrastructure delivery, climate change, nature recovery, the water environment, and health & well-being.  Multifunctionality of land use will be key to delivering these policy agendas.  

At the strategic, sub-regional level, we need spatial development strategies that define the best locations for housing, infrastructure and other forms of sustainable development, while protecting and enhancing the environment and social and cultural capital.  As noted in Josh Allen’s piece in this newsletter, Green Belt reviews must be undertaken at the sub-regional level, as part of spatial options assessments. 

Looking ahead, we’d welcome consultation on the overall effectiveness of Green Belts, in the context of other policies and designations for shaping growth while maintaining separation between settlements and protecting the environment around our town and cities.   

Local plans should be focused on strategic site allocations, design and place-making, delivery and monitoring. 

We encourage the government to underpin their ambitious reforms with transparent and objective appraisal of policies and programmes, so that the full range of social, environmental and economic impacts are understood, and any trade-offs are identified and weighed in the balance. 

We’d also like to see more digital planning, which can offer the data, tools, consultation, and engagement required for plan-making. 

Finally, research and engagement with industry and planning professionals will offer valuable lessons from the experience of previous policy changes and set a positive, evidence-based course for future planning.  

Resourcing, of course, will be critical in terms of funding local planning authorities and statutory bodies to increase capacity and provide the skills necessary to advance sustainable development. 

With our well-established team of around 100 planners across the UK, LUC is ready, willing, and looking forward to playing our part in driving lasting and positive change. 

Onshore development in England will once again be treated the same way as other infrastructure projects and we look forward to the government setting out wider changes to support renewable energy development. They have pledged to consult on incorporating large onshore developments into the Nationally Significant Infrastructure Project regime and encourage faster decision-making.

LUC is pleased to see the government’s recognition of the important part that local communities play in backing renewable infrastructure. There is agreement that host communities should benefit from these developments, and we fully support the commitment to publish an update to the Community Benefits Protocol for Onshore Wind in England.

Before being elected, Labour also promised to establish a green energy plan and set up ‘ Great British Energy ’ – a publicly owned company to accelerate infrastructure projects and decarbonise our energy by 2030, place windfall taxes on big oil and gas firms, triple solar power, and quadruple offshore wind.

Extensive grid upgrades will also be crucial to enable these clean energy projects to connect and export. We are all aware of the contentious nature and lengthy consenting periods for these and the need to pour more resources into our decision-making bodies.

As ever, the devil is in the detail, which we eagerly await.

Here at LUC, we urge our new government to not only have clear and ambitious plans around renewable energy but also to communicate honestly with the general public on both the challenges and enormous opportunities it will bring.

We suggest a brave and ambitious national campaign to inform the British public that in order to reach net zero and have energy security, cheaper bills, cleaner electricity, and community benefit funds we must be able to embrace more turbines, more solar farms, and, crucially, more overhead lines to connect these projects to the grid. Albeit in an environmentally sensitive way that protects our landscapes and biodiversity and benefits us all.  It is possible but would require great political courage.

LUC has continued to support our clients on wind, solar, battery storage and grid connection projects throughout the UK. In recent months, as a result of our clients anticipating a change of government and ensuing change of policy, we have been carrying out more and more onshore wind site finding and site feasibility assessments in England.

We are more than ready to pick up where we left off and help both old and new clients bring forward sensitively designed wind and other energy developments in the future.

The new government plans to hit the ground running. A written ministerial statement is likely to be released imminently, outlining plans for a series of New Towns across the country and requiring all local authorities with Green Belt land to regularly review their boundaries to ensure they meet their housing needs. This is likely to be followed by a new draft National Planning Policy Framework (NPPF) consultation outlining details of the key areas of planning policy reform. 

The consultation should propose revoking the changes in the last iteration of the NPPF published in December 2023 relating to the weakening of housing targets and the sentence ‘Once established, there is no requirement for Green Belt boundaries to be reviewed or changed when plans are being prepared or updated.’ (Paragraph 145) 

It should also suggest returning to more strategic regional and/or sub-regional planning, which will likely influence the scale at which Green Belt reviews should be undertaken and how New Towns are identified and planned. We also hope to see a clear definition of the term ‘grey belt’, its ‘golden rules,’ and its influence on the Green Belt review process. 

It is important to note that reforms relating to plan-making, regional or sub-regional planning, and the planning of New Towns have massive potential but will take many years to bear fruit and start delivering significant housing and economic growth, whereas more specific potential development management reforms, such as revisions to the range of appropriate or not inappropriate land uses in Green Belts set out in the NPPF, could start yielding results within months.   

Green Belts are often misunderstood by the public and politicians. Much of the rhetoric surrounding reform focuses on issues on which this spatial designation has no notable control – landscape beauty, health and wellbeing, climate change and biodiversity to name a few. 

Our recent Green Belt Summit revealed a consensus among planning professionals for a significant rethink about Green Belt planning to cater to the country’s modern planning challenges. The summit proposed a National Plan to tackle the nation’s strategic planning challenges, namely the housing, climate change, biodiversity, health and well-being, energy, and food security crises, which could influence national Green Belt policy over the long term.  

There was agreement among planning professionals that Green Belt boundary reviews should be done at a more strategic regional or sub-regional scale, instead of at the current, more piecemeal Local Authority level. The summit also suggested using new garden towns to curb the incremental sprawl of existing built-up areas, the merging of neighbouring towns, and gradual encroachment into the countryside.  

In speculating about the potential scale and significance of reforms over the short and longer term, it is important to bear in mind that Green Belt policy is one of the oldest, most popular and therefore politically sensitive policy areas in our history. Radical changes like the abolition or renaming of the designation, or a national redrawing of its boundaries are unlikely.

Regardless of the details, the direction of travel is clear, and we are looking forward to working with national, regional and local government and developers to shape sustainable patterns of development across the country over the next five years and beyond. 

LUC works closely with Local Authorities on Sustainability Appraisals and Environmental Impact Assessments, and the announcement of the reforms in 2023 caused widespread uncertainty.  Some clients asked if they should pause work, or perhaps attempt to start an Environmental Outcomes Report instead. We also saw many of our clients taking a shorter-term view when commissioning Sustainability Appraisals, choosing to procure work in stages, to keep their options open ahead of possible changes. 

During the reform consultation period, the SA/SEA and EIA regimes were criticised by the Conservative Government as a laborious, pointless and inaccessible process, but how much of the criticism was motivated by a desire to distance the UK from anything that originated from the EU is up for debate.

The introduction of the SEA Regulations in 2004 contributed to the UK having arguably one of the most sophisticated and effective environmental assessment regimes in existence worldwide. However, it would be imprudent to say there is no basis for some of the criticisms levelled at the SA/SEA regime – it’s clear that the length of reports is off-putting and that the worry of legal challenge based on a failure to meet the requirements of the SEA Regulations has, at times, detracted from the real purpose of SA/SEA as a tool for helping to secure sustainable development.

With a newly elected government, we at LUC are asking ourselves: ‘How will this affect the planning reforms that did not materialise under the Conservative Government that introduced them, in particular the move to EORs?’

The Labour Party’s manifesto asserted that ‘Britain is hampered by [our] planning regime,’ and promised to, ‘set out new national policy statements, make major projects faster and cheaper by slashing red tape, and … update national planning policy to ensure the planning system meets the needs of a modern economy’. However, it is not yet clear that there is a specific plan to either support or scrap the Conservatives’ LURA reforms.

Our new government may not want to go back to the drawing board on this issue and may well see the current proposals as consistent with their stated aim of speeding up the planning system. However, like the Conservatives, they may discover that streamlining and simplifying statutory assessment regimes is not as simple as it may first appear and may not result in ‘cutting red tape’. In our view, there is a lot to be said for an alternative option of modifying the current regime rather than scrapping it.

There is much about the current regime that works and works well. Our hope is that the new government takes the opportunity to engage more closely with industry practitioners to establish which reforms would genuinely improve the delivery and effectiveness of EIA and SA/SEA, and which aspects of our current regime should be retained.

Against the backdrop of uncertainty created by the Conservatives’ 2023 reforms, the general election and a new government, there is still a fundamental uncertainty about when or if EORs may be introduced. It seems, for now, that it remains ‘business as usual’. LUC remains committed to sustainable plan-making and supporting our clients through the complexity and confusion that continues to linger in our sector.

The greenest shoots of placemaking are in Wales. A Placemaking Charter Guide was introduced in 2020 by the Placemaking Partnership and is well-used by local authorities to establish cross-cutting plans to regenerate towns and stimulate new investment. 

Labour’s pre-election campaign focused on large ‘top-down’ approaches to housebuilding, transport and job creation. They also proposed devolution of planning powers and expansion of the transport, skills, housing and employment remit for existing Combined Authorities.  

Within its first week of power, the new government restored housing targets of 1.5 million homes and instigated a pro-infrastructure review of the NPPF and a nationwide review of green belt boundaries. They also moved forward with making funding available for more planning officers, who could be deployed, in part, to deliver placemaking approaches to planning and regeneration at local authority level.  

It took a matter of days for the term ‘Levelling Up’ to be removed from the department responsible for housing and communities. This suggests the government may make good on its promise to move the allocation of funding for regionally and locally strategic capital projects away from the competitive ‘beauty contest’ of bidding for Levelling Up funding to greater de-centralisation and devolution, though time will tell if this is the case. 

With intentions to return to a plan-led approach to development and proposals for a generation of New Towns alongside urban extensions and regeneration, it’s encouraging to see the potential to adopt a placemaking approach and deliver growth simultaneously. With a new government, we could see a more local and crosscutting approach to improving towns and cities, which is encouraging from our placemaking and place-shaping perspective. Within days of the election, the new government’s changes to planning, regeneration and placemaking hit the headlines immediately and were even given top billing in the  King’s speech .  

In practice, placemaking is an ongoing process that is the sum of many different actions that improve how a place functions and how it is experienced. At LUC, we recognise that there is no one-size-fits-all approach. Successful placemaking requires a mix of large-scale or ‘top-down’ investments alongside the ‘marginal gains’ of small improvements that collectively make a big difference.  

Our bespoke and multidisciplinary placemaking services value local distinctiveness alongside broader strategic priorities such as biodiversity, carbon reduction, and climate resilience. We recently worked with the  Lake District National Park Authority  to prepare a turnkey Design Code to guide their decision-making on planning applications. By providing clear design requirements (code) within a framework of good design principles, our work has set a new benchmark for design codes in rural areas. We hope to see more use of design codes to enhance local placemaking. 

LUC’s experience and expertise can support the placemaking process through strategies and plans, regeneration frameworks, design codes, improving biodiversity, heritage-focused regeneration, promoting active travel, or creating healthier and better-connected places.  

These much-needed, affordable homes must be delivered promptly. Having a secure home is vital to support healthy communities. But, these homes need to be sustainable and attractive to live in and supported by ample green infrastructure. 

Good design sits at the heart of this mission. This seems obvious but is too often overlooked because of market economics. Even with constrained budgets, we can still deliver beautiful, high-quality places to live. 

Design work should start at site acquisition and be environmentally led. Environmental constraints should be at the forefront when developers make investment decisions, avoid overpaying and underdelivering, or worse, leaving potential housing sites dormant for years. 

Refreshed local planning policies should support clear plan-led approaches to development, balanced with habitat creation. This will help us to deliver the quality, place-led homes we need. Well-thought-out open space not only improves the well-being and quality of life of residents but also helps to increase biodiversity and consequently, contribute to tackling the climate crisis.

Increasingly, residential landscapes are made to work harder, acting as multifunctional vessels, designed with overlapping and sometimes conflicting demands. Policy-driven measures for play, urban greening and biodiversity enshrine minimum standards within the landscape. Additionally, there’s a need to build in climate resilience, catering for extremes in rainfall and providing planting that can adapt to a warming climate. This approach is essential to ensure our green landscape can be enjoyed by future generations while remaining affordable to deliver and maintain. 

Early consideration of management funding models will ensure open space does not become a financial burden. Positive management will engender community cohesion, encourage people to engage with the landscape and give residents pride in their living space.

The management company model funded through service charges has come under pressure due to affordability. With local authorities not wanting to adopt open spaces, the question is who will maintain these valuable community assets? Community Trusts may be one answer, or developer endowment guaranteeing a sustainable funding mechanism. Design flexibility is another consideration. Traditional landscapes with prescribed uses are often no longer appropriate and fail to encourage residents to engage. Designing opportunities for community development can encourage more collective responsibility for managing green spaces. 

All of this requires a supportive and flexible policy environment. The new government will need to invest in local planning, with good design at its heart to help achieve viable, attractive places to live. Highway authorities must adapt and work with landowners to make green sustainable drainage systems a standard element of modern highway design.  

The key to successful placemaking is landscape. It binds new settlements together, facilitates movement, and provides places for recreation while nurturing our natural environment. It is the pivotal role of the landscape architect, working within a collaborative team, to design, and integrate these multi-layered requirements. LUC’s designs at  Rochester Riverside  in Kent exemplify this, delivering successful place-led development on a former brownfield site.