Response to Planning For the Future White Paper. October 2020

Herefordshire Sustainable Transport Group has been making the case for active travel, public transport, and innovative schemes for a number of years, and in recent months has been in extensive communication and cooperation with the present Herefordshire Council, helping them to develop a sustainable healthier transport system for Hereford City and its environs. Obviously a major factor in this is the need to reduce carbon emissions.

We would like to comment on the Government’s latest white paper on Planning for the Future mainly from the perspective of the need to thoroughly incorporate better planning for transport to be integrated in new build estates as recommended by Transport for New Homes.

In general, the Government’s latest proposals, promoted as the solution to England’s housing shortage are radical, deeply worrying and pay scant recognition to the issues of car dependency in new out of town developments. They fail to address climate, ecological and health emergencies, or to value biodiversity and to create better communities.

They propose as a target that housing should be carbon net zero–ready by 2050. This is woefully, suicidal, inadequate. Every development should not only be carbon neutral but should be generating more power than it uses. The current proposal for housing to be ‘carbon net zero-ready within 30 years is simply not good enough in the current state of climate emergency.

There is a serious risk that in centralising more decisions they will erode local democracy, encroach on our beautiful countryside, do nothing to reduce emissions, and not result in a reliable increase of affordable housing. Potentially this is a developer’s charter, which removes local democracy, silences residents and threatens local environments.

While we understand that there is a need to bring forward more homes, we would dispute that the current system is a severe obstacle to this as a result of delays. Under the current system, both scrutiny, including involvement of local democratic bodies and pressure groups ,and professional advice ,often result in the design of a development being improved during the planning process. It would be a backward step if this were lost.

The suggestion of a single ‘sustainability test’ devised by central government is not satisfactory; it must take account of local circumstances, and new developments are best considered with informed contribution from local communities including local parish and town councils and local interest groups such as our own.

The simplistic ‘zoning’ arrangement, dividing England into just three categories fails to capture the physical, social and environmental aspects of the country and is wrong.

The intention to zone land into Growth/ Renewal/Protected categories tips the balance of the planning system further in favour of large-scale development and land-buying industries. The zones are too broad and do not accommodate local characteristics. The designation of Growth and Renewal areas must be co-designed with local residents. Growth zones must first past environmental assessments / sustainability tests. The zoning system must recognise the importance of open countryside and other undeveloped land as distinct from designated land such as AONB, National Parks etc. Additional categories of land use are needed to allow local areas to set local targets, for example: renewable energy generation, food production, rewilding and nature, and nature-based carbon sequestration.

Nothing is proposed to ensure that development takes place only in sustainable places, with a commitment to a major shift from car journeys to sustainable modes of transport. Building in the wrong location leads to more traffic, car-based living, more isolation and less walking or cycling. We shouldn’t be forcing people to live car-dependent lifestyles in the future.

The proposals are in conflict with government policies to reduce carbon emissions, promote more active travel and less isolated lifestyles, and regenerate town centres. There is undue emphasis in the White Paper on accelerating the construction of homes in the countryside away from major urban areas. By pushing new homes so far away from jobs and services, in places where public transport is very limited and walking and cycling are not viable, the reforms are likely to encourage more car-based sprawl.

One improvement possible would be a requirement that all new homes should be designed suitably for working from home.

Infrastructure spending must be ring-fenced to ensure the necessary infrastructure is provided to fully support development, especially infrastructure for low carbon living and increased biodiversity – including electricity grid capacity, climate change adaptation, public transport, local shops and green spaces. Infrastructure levy money must not be used for other types of spend, unrelated to development or for ‘council tax reduction’. The new levy should not only be based on the type of housing but on the carbon and environmental credentials of a building and site, including safe sustainable active travel and public transport, effectively offering a discount to those developers who build to the highest environmental standards.