Memorandum submitted by the Town and Country
Planning Association
1. Summary of TCPA Submission
1.1 Climate change is the most pressing social,
economic and environmental challenge facing UK society today.
It will have a significant impact on all sections of the UK population,
particularly members of vulnerable groups, across geographical
and political boundaries. The changing climate with higher temperatures,
wetter winters and increasingly uncertain climatic conditions
across all the seasons will have a lasting impact on how people
live, work and play. Climate change will radically change the
way our towns and cities are planned, how they develop into the
future and, most significantly, the way that human society views
its place within the eco-system in the UK and beyond.
1.2 The Town and Country Planning Association (TCPA)
is working to influence policies now to ensure their implementation
for the benefit of future generations. Representing the views
of our cross-sectoral membership, TCPA is currently leading on
several strands of important policy development and project work.
This commitment is founded in our new manifesto, Towns and Countryside
for a New Age of Challenge (2009), in which we set out the vision
for the future. One priority is to plan for the future of our
towns and countryside to address, directly, the challenges arising
from climate change.
1.3 In this submission, the TCPA highlights
the following issues:
Statutory Basis: The statutory
basis for delivering climate change adaptation through planning
is in the right direction for the UK as a whole. However for the
respective UK nations there is a need to concentrate on delivery
at the grass-roots level led by local authorities,
Potential conflicts: The need
for a practical alignment between mitigation and adaptation in
terms of policies in development plans alongside advice and guidance
on delivering developments,
Resources: Significant resources
and greater capacity are needed to deliver adaptation measures
through co-ordinated spatial planning across national, regional,
sub-regional and local scales. However these are likely to adversely
affected through across the board planning reforms for development
planning and development management,
Inconsistent Information: The
inconsistency of available information and data sources to support
decision-makers looking at new development across the UK nations
may impede effective iterative adaptation action through the spatial
planning process.
1.4 In this submission, the TCPA highlights
the following opportunities:
To embed adaptation and wider sustainability
principles: Planning for the upturn in development provides
a timely opportunity to embed adaptation and wider sustainability
principles in development proposals.
To make more effective use of planning
obligations and infrastructure investment: The more effective
use of planning obligations and proposals for a new infrastructure
funding mechanism aligned with the local planning process will
ensure a co-ordinated planning and investment programme for adaptation.
To align existing monitoring and reporting
processes: Align with existing processes of monitoring and
reporting, including greater encouragement by central Government
for English local authorities to take up National Indicator 188
as part of their corporate reporting activity.
1.5 Finally the TCPA makes the following
recommendations:
Transformational change in spatial
planning: There must be transformational change in the culture
of spatial planning to place climate change and adaption at the
heart of decision making. This requires greater prescription in
national policy as to the importance of climate change.
A step change in the skills and education
of decision makers, both political and professional, in local
and regional government.
To establish a Climate Change Technical
Advice Body: A new technical advice body on climate change
is required to provide a trusted source of advice and information
for local government on climate change. This advice body would
agree key methodologies and data sets as well integrating the
advice of differing agencies on adaptation and mitigation.
2. About the Town and Country Planning Association
(TCPA)
2.1 Founded in 1899 the TCPA is the UK's oldest
independent charity focused on planning and sustainable development.
Through our work over the last century we have improved both the
art and science of planning in the UK and abroad. The TCPA puts
social justice and the environment at the heart of policy debate
and seeks to inspire Government, industry and campaigners to take
a fresh perspective on major issues, including planning policy,
housing, regeneration and climate change. Our objectives are to:
secure a decent home for everyone, in
cohesive, well designed communities;
empower communities to influence decisions
that affect their future; and
promote high-quality development through
better planning of the use of our land.
2.2 The TCPA is currently undertaking the following
major policy development and project work around climate change
adaptation:
From Autumn 2008The TCPA
is leading a 3-year project financed by the European Union European
Regional Development Fund under the INTERREG IVC Program called
GRaBS (Green and Blue Space Adaptation for Urban Areas and Eco-townswww.grabs-eu.org
). There are 14 partners, all with varying degrees of experience,
drawn from eight member states representing a broad spectrum of
authorities and climate change challenges. GRaBS is designed to
facilitate the exchange of knowledge, experience and good practice
in climate change adaptation strategies. For further information
see Annex 1.[4]
From July 2009TCPA established
a new Climate Change Unit. Led by TCPA's Chief Planner, Dr Hugh
Ellis, it will take forward the TCPA's climate change policy development
and campaigning work. A major part of this work will be support
for the Planning and Climate Change Coalition. The coalition will
be publishing a mock Planning Policy Statement or "position
statement" in the Autumn; and
On-goingTCPA continues
policy work on the review of Regional Spatial Strategies and UK-wide
policy consultations to ensure climate change adaptation is embedded
in decision-making and plan-making where appropriate and necessary
in pursuit of sustainable development through planning objectives.
MAIN TCPA SUBMISSION
The TCPA welcomes the opportunity to contribute
to this timely inquiry by the Environmental Audit Committee into
climate change adaptation. This Inquiry follows closely from,
and must seek to make the most effective use of, findings from
recent inquiries and studies by the RCEP (2009), EAC (2008) and
Pitt Review (2008) so as to avoid duplication of work. This submission
provides evidence under specific issues of interest outlined in
the Committee's Call for Evidence.
The Committee should note that the emphasis
of the TCPA's submission is on the capacity and capability of
the spatial planning systems of the four UK nations to deliver
on adaptation, in accordance with our area of expertise and
experience.
3.0 ISSUE 1: How well the overall direction for
work on adaptation has been set, the effectiveness of the statutory
framework (including the use of the Reporting Power and its accompanying
statutory guidance), the allocation of powers and duties and how
well issues like social justice are addressed in adaptation policies
OVERVIEW OF
THE PLANNING
SYSTEMS' CAPACITY
TO DELIVER
ADAPTATION
3.1 The TCPA believes that the UK's four statutory
frameworks as a whole, and as individually established by the
devolved administrations, are beginning to move in the right direction.
Public authorities broadly have the necessary duties and powers
to take adaptation action as part of carrying out their functions.
This is particularly with respect to the planning and development
of land although uncertainties exist with their application specifically
for adaptation purposes.[5]
While the TCPA does not question the UK's overall commitment to
adaptation action, our concerns relate to conflicting statutory
action taken amongst the four nations.
3.2 As an illustration, the TCPA commends the
Climate Change Acts as an important step for the UK as a whole
to build adaptive capacity in policy terms. However, unlike the
Climate Change (Scotland) Act 2009, the Climate Change Act 2008
applicable to England, Wales and Northern Ireland falls far short
of the mark in ensuring that the adaptive action is, and should
be taken, at the local level of implementation. The Scottish 2009
Act places a statutory duty on local authorities as a public body
to with respect to climate change. In contrast the 2008 Act simply
empowers the Secretary of State to require designated authorities
to report on their adaptation action. Of great concern to TCPA
is the fact that local authorities are not included in the draft
designated list, Wales has yet to take the step to identify such
a designated list of reporting authorities, and the duty for adaptation
in Northern Ireland is comparatively weak.
3.3 In addition, there continues to be uncertainty
and delay as a result of planning reforms implementing new development
plans across England, Wales and Scotland, and those emerging from
Northern Ireland. In particular in England the suggested abolition
of regional planning would create a potential hiatus in effective
planning between national and local levels and ultimately affect
the capacity and capability of planning professionals to deliver
effective and co-ordinated adaptation action.
3.4 The need that the TCPA sees for national
targets set at national level reflects the principle of subsidiarity
in which decisions should be made by the most competent local,
regional, national or international level. Climate change is a
global issue with targets agreed by international treaties, national
governments are responsible for national policy to deliveror
exceed such targets. In this context local authorities should
be free to determine how and where (in land use terms) to meet
the targets which apply to all other tiers of government as to
themselves. The TCPA case is that local authority abrogation of
international and national targets would be irresponsible and
hugely damaging to our chances of meeting the climate challenge
head on and thus nationally/internationally imposed planning targets
imposed are appropriate for all the players in the planning and
development system including local authorities.
3.5 To further highlight the TCPA's perspective,
we refer to the following statements taken from the executive
summary of TCPA's study commissioned by the Royal Commission on
Environmental Pollution (RCEP) to help inform their final report.
(Please see the full report attached as Annex 2 for further detailed
findings).[6]
3.6 The overall conclusions of the (RCEP) study
are that its findings reinforce the powerful statutory basis of
the UK planning systems. At its best, the system is capable of
integrating and giving spatial expression to a range of policy
priorities within the sustainable development paradigm. Policy-makers
and practitioners recognise that delivering adaptation needs to
be embedded within the development plan-led approach of the planning
systems. From national policy guidance to regional, sub-regional
and local development plans, measures to adapt the built environment
and various land use development activities need to be implemented
in an integrated manner.
3.7 But for now, the complexities of implementing
adaptation across stakeholders from different sectors, parallel
strategies and plans, and organisational structures and hierarchies
in the context of significant planning reforms have surpassed
the capability and capacity of planners and planning departments.
The study also indicates the lower tiers of the planning system
hierarchy are underperformingparticularly when measured
against the ambition of some national planning policy.
3.8 Therefore, it is imperative that policy-makers
take note of the findings of this report as well as the final
report from the RCEP, and seek to ensure that the institutional
capacity of the UK planning systems will be fit-for-purpose as
part of the wider co-ordinated effort to tackle the challenges
of climate change.
ELIMINATING CONFLICTS
IN PLANNING
POLICY AND
DELIVERY
3.9 Policy measures aimed at combating climate
change must be coherent and coordinated. Policies, and indeed
research and practical guidance, have focused particularly on
climate change adaptation or mitigation but never as part of a
coherent approach to sustainable development. TCPA believes that
specific research is required to address this issue in current
policy and range of existing practical guidance for planners.
3.10 In addition, cases of conflicts between
other areas of planning policy that could prevent planning authorities
effectively delivering on wider adaptation objectives. An example
of this is the "Effective Use of Land" policies (paragraphs
40-44) in Planning Policy Statement 3 on Housing. Government sets
a national target of 60% for the re-use of brownfield land for
redevelopment. Regional Spatial Strategies (RSS) and Local Development
Frameworks (LDF) have used this target to encourage urban regeneration
and discourage potentially sustainable greenfield developments,
rather than considering the benefits of proactive planning and
re-use of brownfield and greenfield land to form a network of
green infrastructure to contribute towards adaptation. Planning
authorities use the 60% target as an indicator of the preferred
level of development and consider the higher the percentage the
better.
4.0 ISSUE 2: The funding, support, training and
other resources available, including at a local and regional level,
for:
building capacity to adapt to climate
change;
specific actions to adapt to climate
change, such as investment in flood risk management or the resilience
of critical national infrastructure; and
helping individuals and organisations
conduct their own climate change risk assessments and judge what
actions they need to take.
IMPROVING INSTITUTIONAL
CAPACITY
4.1 The TCPA emphasises the scale of support,
training and resources needed to enable the delivery of effective
adaptation action. TCPA believes local authorities are best placed
to lead on this. However current demand for experienced and skilled
planners is increasing. This is in addition to planning resources
are being absorbed by the preparation of local plans under new
development planning processes. One of the first steps to ensuring
the necessary capacity to deliver adaptive action through planning
is having a sound policy framework in place. Recent research by
TCPA in partnership with Cushman and Wakefield found that less
than 15% of English local authorities have a sound core strategy
with similar slow progress and/ or out of date development plans
across Wales, Scotland and particularly Northern Ireland.
4.2 Furthermore, planners are expected to mediate
competing priorities in a wide variety of areas including housing,
economic development, transport and renewable energy planning,
including embedding adaptation measures. The skills required of
planners to be able to coherently communicate these priorities
is lacking. The Royal Town Planning Institute (RTPI), under its
`Planning to Live with Climate Change' initiative, promised to
take appropriate action to ensure climate change skills will be
part of the tertiary core curriculum for spatial planning as well
as continuing professional development. The TCPA will increasingly
commit its work programme to help raise awareness and profile
of climate change skills and knowledge as indicated through our
endorsement of the "Delivering Better Skills for Better Places"
action plan led by the Housing and Communities Agency Academy.
4.3 It is vital that the planning system responds
quickly to the risks posed by climate change. If the skills are
not there, the role of planning in delivering adaptation is hampered.
This is particularly relevant for adaptation measures, where negotiation,
risk assessment skills, and effective communication will be required
to affect change in development proposals. Generic and technical
skills need updating, improving and adapting to deliver on climate
change.
4.4 The TCPA highlights the following studies
and inquiries which examined the capacity of professionals, in
terms of skills and resources, and degree of effectiveness in
addressing current and emerging challenges:
Royal Institute of Chartered Surveyors,
Improving the Capacity of the Planning System in England and
Wales: A View from the Regions, March 2009.
Communities and Local Government Committee,
Planning Matterslabour shortages and skills gaps,
July 2008.
CAG Consultants, Capability for Local
Sustainability: Final Report, Sustainable Development Commission/
Defra, May 2008.
Audit Commission, The planning system:
Matching expectations and capacity, February 2006.
NEW CLIMATE
CHANGE TECHNICAL
ADVICE BODY
4.5 TCPA has been leading a Planning and Climate
Change Coalition to inform the CLG's forthcoming draft revision
of its Planning Policy Statement on Climate Change. The following
extract from the emerging draft makes the case for a new streamlined
technical advice body:
4.6 A Climate Change Technical Advice Body
(CCTAB)
The need for proper evidence gathering and
target setting requires tools and methodologies, and involves
considerable complexity and skills.
4.7 There is a need for a new body which
can supply the `heavy lift' on evidence gathering, and provide
a unified model for baseline conditions and target setting in
relation to both mitigation and adaptation. The CCTAB would build
upon the experience of other technical advice bodies for housing
(NHPAU), waste and aggregates and draw on existing expertise from
a range of agencies and organisations with a key role in the climate
debate (Such as EA and UKCIP). It would provide a technical bridge
between high level national climate requirements and detailed
localised policy delivery. Above all it would provide a simpler
and more certain process for regional and local policy making
with a substantial efficiency and delivery gains.
4.8 "CCTAB functions on mitigation and
adaptation
To provide strategic guidance to regional
and local planning authorities on climate change. To provide a
strategic technical bridge between the EU requirements, CCC and
regional and local authorities.
To provide agreed carbon assessment
tools, provide assessments and set targets on mitigation and adaptation
including making clear how differing carbon reduction regimes
interrelate and the role of spatial planning.
To understand energy capacity and
constraints through agreed methodologies, and to map these in
a way in which creates an agreed evidence base for development
planning and site allocations.
To ensure local authority and community
aspirations on climate solutions are considered in capacity and
constraint mapping.
To provide strategic guidance on the
risks and vulnerabilities of climate change and identify key adaptation
priorities, particularly where these have both inter regional
and sub regional dimensions.
To act as a resource centre, providing
reliable data and training to local authorities.
4.9 The functions of the CCTAB do not remove
the need for local data collection where LAs felt it was necessary
to provide more detailed understanding of particular issues. It
would, however provide a minimum standard of evidence to inform
policy development. It would therefore ensure that the system
was much better equipped to mediate between opposed interests
based on a rational and considered view of opportunities and constraints.
4.10 It has been suggested that CCTAB should
be a function of the Committee on Climate Change. This was primarily
because of the need for logical and transparent linkage with national
climate regime and because the committee sat above individual
departments and had a greater opportunity to drive an integrated
approach to climate solutions. However, this would require new
guidance from Government and major change to remit and skills
of the CCC. Some members of coalition favoured other options such
as CCTAB being a government office function. As result while the
coalition was unanimous in the need for improved technical integration
and standard sit did not reach a view as to who should host this
body."
BUILDING ADAPTIVE
CAPACITY THROUGH
POLICY AND
OPERATIONAL MEASURES
4.11 Within the GRaBS project, building adaptive
capacity is part of a process of working towards effective regional
and local adaptive action. It is divided into two key areas: policy
measures and operational measures:
Policy Measures: adopt new or
to strengthen existing strategic policies, which will provide
the incentive and regulatory framework to encourage future development
to incorporate climate change adaptation responses.
Operational Measures: put in place
new operational mechanisms that have the capacity to strengthen
climate change adaptation responses. Examples of such measures
include the establishment of a climate adaptation team in the
organisation and/or climate change adaptation partnership with
other stakeholders and the community.
4.12 The first expert paper of the GRaBS project
championed the contributing role of the planning statutory framework
in delivering adaptation through the various spatial scales of
development and spatial plans (Henderson, 2009). This was first
highlighted in TCPA's Climate Change Adaptation by Design (Shaw,
Colley and Connell, 2007), and Biodiversity by Design (TCPA,
2004).
4.13 The Committee should note that most studies
into the delivery of climate change adaptation, as reviewed in
the TCPA study for the RCEP, emphasised the lack of effective
delivery such as issues with development plans, capacity and coordinated
action while the necessary statutory and policy frameworks already
exist and are relatively robust. This takes the focus back to
improving capacity as highlighted in paragraphs 4.1 to 4.4.
4.14 The GRaBS project will also facilitate
the much needed exchange of knowledge and experience and the actual
transfer of good practice on climate change adaptation strategies
to local and regional authorities among partners.
DELIVERING POSITIVE
ADAPTATION ACTION
THROUGH PLANNING
MEASURES
4.15 As highlighted previously, the TCPA believes
that planning, and the planning system, is vital in delivering
adaptation action to enable necessary development while securing
measures to improve built environment resilience.
4.16 At the development level, implementing
adaptation measures through hard infrastructure to increase the
resilience of the built environment can take several forms and
at different scales. This ranges from region-wide green and blue
(water) infrastructure network to the provision of local green
spaces, gardens and permeable surfaces as part of development.
Their provision in terms of planning to construction requires
financing. Certainly local authorities cannot be expected to completely
foot the bill for their provision if these effects are attributed
directly to the proposed development. Therefore planning authorities
are empowered to use planning obligations or developer contributions
to legitimately secure financial or in-kind contributions from
planning applicants:
England and Wales: Section 106 of the
Town and Country Planning Act 1990 and the Community Infrastructure
Levy of Section 205 of the Planning Act 2008.
Scotland: Section 75 of the Town and
Country Planning (Scotland) Act 1997.
Northern Ireland: Article 40 of the Planning
(Northern Ireland) Order 1991.
4.17 Studies commissioned by the responsible
government planning departments in England (Crook et al,
2006 & 2008), Wales (Rowley, 2007) and Scotland (McMaster,
2008) highlighted a wide-ranging use of planning obligations by
planning authorities to finance infrastructure, including environmental
infrastructure.[7]
They looked at variations in the ability of planning authorities
to successful secure contributions based on the method for calculating
contributions, robustness of the local planning policy frameworks,
and the degree of dedicated staff resources. Their findings indicate
the primary justifications for those LPAs that are more able to
secure contributions are due to clear policies in place and better
experience in the process. Again, this takes the focus back to
improving capacity to deliver robust policies and plans as highlighted
in paragraphs 3.9 to 3.12.
4.18 The Community Infrastructure Levy (CIL)
provides a significant opportunity to create a fair and transparent
way of recovering value uplift created by the grant of planning
permission. However we are concerned whether CIL will be properly
directed towards tackling climate change by ensuring it can support
wider adaptation measures in local communities.
5.0 ISSUE 3: The monitoring and evaluation of
work on adaptation, including thoughts on how progress on adaptation
can be quantified and success measured
5.1 The TCPA believes it is right for the Committee
to identify monitoring and evaluation as an important issue. It
will increasingly become essential in delivering effective adaptation
action through planning. Monitoring against indicators of how
well adaptation is delivered through the planning system must
be embedded in the existing processes of monitoring and review
in plan-making as a statutory responsible of the relevant authorities
of all UK nations with the exception of Northern Ireland :
England: Regional Planning Body for the
Regional Spatial Strategy,[8]
Mayor of London for the Spatial Development Strategy for London[9]
and Local Planning Authority for the Local Development Framework.[10]
Wales: Welsh Assembly Government for
the Wales Spatial Plan[11]
and Local Planning Authority for the Local Development Plan.[12]
Scotland: Scottish Ministers for the
National Planning Framework,[13]
the Strategic Development Planning Authority for Strategic Development
Plan[14]
and the Planning Authority for the Development Plan.[15]
5.2 TCPA accepts that unlike mitigation measures
in energy generation and CO2 emissions, adaptation measures can
be difficult to measure and do not enjoy a comparatively comprehensive
set of datasets. However the TCPA believes that a picture of progress
on, and opportunities for, adaptation action can be painted through
examining indicators to report on policy and operational measures:
Inputs: eg. time and financial
resources.
Outputs: eg. production of relevant
plans and programs.
Outcomes: eg. quantitative and
qualitative surveys on specific aspects of adaptation action,
organisation, processes, professional and citizen views.
5.3 These indicators can be formulated from
publically available datasets related to the built environment's
impact and contribution to climate change adaptation, including
and not limited to:
Local council annual report on corporate
resources and activities.
Biodiversity indicators from regional
and local biodiversity action plans.
Green infrastructure indicators from
local open space strategies and studies, including green belt
data.
"Blue" infrastructure from
the Environment Agency, strategic flood risk assessments and flood
management plans.
Development management and changing land
use statistics from local authorities and collated by the responsible
government department (England- Department for Communities and
Local Government, WalesDepartment for Environment, Sustainability
and Housing, ScotlandScottish Executive Planning Directorate,
and Northern IrelandThe Planning Service).
Other development statistics such as
the number of development schemes with SUDs, use of developer
contributions etc.
5.4 However there are serious issues with the
consistency of data collection arrangements by the relevant local
authorities as well as the relevance of indicators to policies.[16]
The TCPA recommends that further research be commissioned to establish
a set of common indicators for measuring progress towards effective
adaptation action.
5.5 In addition, The TCPA believes that the
national indicator as part of the local authority's comprehensive
area assessment framework in England, NI188, is a welcome step
towards addressing the monitoring and evaluation issue highlighted
by the Committee.
5.6 Finally, the Climate Change Act 2008's adaptation
reporting duty is another important statutory mechanism to measuring
progress within the planning and development system (see comments
to ISSUE 1). However draft consultation proposals not to include
regional and local planning authorities as adaptation reporting
authorities in England is an indication that the Government does
not fully appreciate the scale of impact developments can have
on the resilience of the built environment and the potential contribution
planning can have to increase this resilience.
SUMMARY TRENDS
IN CURRENT
PLANNING STATISTICS
RELEVANT TO
ADAPTATION
5.7 Currently progress on adaptation can be
measured and reported through the statutory requirements highlighted
above, by examining the nature of planning statistics, particularly
about collective decisions made on individual planning applications
and the trend of changing land uses. This would provide the necessary
link in assessing how adaptation has been properly filtered down
from policy to implementation, aspirations to reality, spatial
planning to developments on the ground.
5.8 Local authorities provide planning performance
information to the relevant government departments and they are
collated on a quarterly or half-yearly basis. TCPA found that
the scope and availability of the statistics varies considerably
from nation to nation. This may partly be due to full statistics
not being analysed and published. This would have some impact
on the effectiveness of monitoring progress through the spatial
planning systems for the UK Adaptation programme and Adaptation
Sub-Committee's work.
5.9 In undertaking a scoping review for the
development statistics currently available, TCPA highlights key
trends for England. Full outputs from this exercise are presented
in Annex 3.
5.10 Changing patterns of land use of urban
vacant and derelict land indicate a growing trend towards the
intensification in the urban areas, in particular the increase
in development on previous residential land use. While the redevelopment
of previously open space and agricultural land have been steadily
decreasing or stabilising, the primary concern is the proportion
of minor development of less than 5 hectares (ie on urban back
gardens and small plots of land) being redeveloped.
5.11 Without proper control of householder and
minor developments through the removal of permitted development
rights the incremental loss of urban backgardens will have a large
impact. This will be greater than larger scale developments which
go through a more rigorous environmental assessment and coherent
masterplanning process.
5.12 TCPA believes an URGENT CALL for further
detailed study of development statistics is required in the UK
to fully comprehend their implications for adaptation action.
REFERENCE DOCUMENTSChang,
M, Dickins, S and Ellis, H, August 2009, Helping to Deliver
Climate Change Adaptation through the UK Planning Systems,
TCPA, London.
Crook, T, Henneberry, J, Rowley, S, Smith, R S and
Watkins, C, August 2008, Valuing Planning Obligations in England:
Update Study for 2005-06, DCLG, London.
Henderson, K, June 2009, GRaBS Expert Paper 1.
The case for climate change adaptation, TCPA, Available on
www.grabs-eu.org/downloads/20090617_GXP.pdf
House of Commons Environmental Audit Committee, July
2008, Climate change and local, regional and devolved government,
Eighth Report of Session 2007-08, TSO, London.
McMaster, R, U'ren, G, Carnie, J, Strang, G &
Cooper, S, 2008, An Assessment of the Value of Planning Agreements
in Scotland, Scottish Government Social Research.
Royal Commission on Environmental Pollution (RCEP),
forthcoming, Adapting the UK to Climate Change.
Rowley et al, August 2007, The Use and
Value of Planning Obligations in Wales. A Report to the Welsh
Assembly Government, WAG, Cardiff.
Shaw, R, Colley, M and Connell, R, Climate Change
by Design, TCPA, London.
TCPA, 2004, Biodiversity by design, TCPA,
London.
TCPA, March 2008, TCPA Submission to the Pitt
Review Interim Report Recommendations, TCPA, London.
TCPA, June 2009, Towns and Countryside for a New
Age of Challenge. A Manifesto from the TCPA, TCPA, Available
on www.tcpa.org.uk/data/files/tcpa_manifesto.pdf
STATISTICAL DOCUMENTSDepartment
for Communities and Local Government (CLG), August 2008, Development
Control Statistics, England, 2007-08, CLG, London.
The Scottish Government, 2007, Planning Performance
Statistics 2004-2007.
The Scottish Government, January 2009, Statistical
Bulletin: Planning Series. Scottish Vacant and Derelict Land Survey
2008.
Annex 3[17]
PLANNING STATISTICAL ANALYSIS FOR ADAPTATION
ACTION
The TCPA has conducted a brief analysis of the
most recent statistics available for land use and development
management datasets for England and Wales. The range and depth
of the statistics vary among the UK nations as there is no single
UK source, and partly contributes to a lack of statistical evidence
base for adaptation.
ENGLAND
As an illustration of the potential cumulative
impact of development on adaptation, the TCPA examines the following
development control statistics from the Department for Communities
and Local Government.
Figure 1

Data source: CLG, August 2008, Development Control
Statistics, England, 2007-08, Table 1.6
Residential development is defined by Use Class
C3 Of the Use Class Order 1987 as amended. Major is 10 or more
dwellings, or where the number is not given a site area of a half-hectare
or more. Minor excludes householder development and Change of
Use.
Figure 1 above shows that householder planning
applications are by far the largest category, with 296,800 applications
decided in 2007-08. This is followed by applications for new dwellings,
with 79,600 applications decided. Although the majority of these
applications are minor, housing and residential development is
the main land use activity of planning departments in terms of
proportion of applications, and will have a major influence on
construction and climate change.
Figure 2

Data source: CLG, 2008, Development Control Statistics,
England 2007/08, Table 1.4
Figure 2 shows that for the year ending March
2009, 4,420 planning applications for major residential developments
were approved (65% of total applications decided), and 36,992
approved for minor residential developments in the same period
(64% of total applications decided). The numbers of residential
development applications being approved have fallen since the
previous year, which saw 6,285 major and 44,144 minor residential
applications approved. However, there were proportionally fewer
minor applications decided in 2007-08, so producing a rise in
the rate of approval of minor applications from 63% in 2007-08
to 64% in 2008-09.
Housing shortages, and subsequent increased
house building and applications for development as already discussed,
in England is creating changes in land use. The amount and type
of land use change can be indicative of the level of sensitivity
to sustainable development issues. Figure 3 below shows that the
amount of land changing to residential use has generally experienced
a decline since 2000.
Figure 3

Data source: CLG, July
2009, Land Use Change Statistics, Table P222
Between 2000 and 2003 dwelling density on previously
developed land was 31 dph, rising to 47 dph between 2004 and 2007.[18]
For the same time periods, dwelling density on not previously
developed land increased from 23 dph to 30 dph.
Figure 4 shows that in 2008 the majority of
land changing use to accommodate new residential development was
not originally residential. However, over recent years this amount
has declined significantly, from only 18% of land in 2000 already
residential in use, to 39% in 2008.
There has also been an increase in the amount
of previously developed land (+17%) being changed to residential
use between 2000 and 2008, and so a decline in the percentage
of not previously developed land being used for residential development.
Particularly of note is the decline in the amount of agricultural
land changing use, from 34% in 2000 to 24% in 2008.
Figure 4

Data source: CLG, July 2009, Land Use Change Statistics,
England, Table P226
Figure 5 below shows a decline in flood risk
land changing to residential land, from 404ha in 2002 to 256ha
in 2005. However, the data begins to show a rise in land use change
again, which may be the result of advances in flood management
and house building techniques.
Figure 5

Data source: CLG, July 2009, Land Use Change Statistics,
Tables P252 and P222
Previously developed land statistics are another
indicator of sustainable development and ability to adapt to climate
change. Figure 6 shows the overall amount of previously developed
land available has declined between 2001 and 2007 from 65,500ha
to 62,130ha, while the proportion of this land currently in use
has increased.
Figure 6

Data source: CLG, October 2008, Previously Developed
Land that may be available for Development: England 2006 &
2007, Table P301
The percentage figures of new dwellings built
on designated green belt land over the past few years is also
encouraging. A decline from 4% of new dwellings built on green
belt land in 2000 to 2% of new dwellings in 2007 has occurred.[19]
WALES
There is no data available for planning applications
approved or for land use changes, to compare with data for England.
However, there is data available on the number of planning applications
decided, and the speed with which planning applications are determined.
In 2007-08, a total of 34,243 planning applications were decided
across Wales, 62.3% of which were decided within 8 weeks of being
received.[20]
Figure 7

Data source: WAG, January 2009, Development Control
Quarterly Surveys
Figure 7 above shows there has been an increase
in the speed with which minor residential and householder applications
have been determined over the past few years. However, this data
does not tell us the numbers of applications approved and those
rejected, and so while this may indicate improvements to applications,
if many are being rejected it could mean that applications are
not meeting the required standards.
2 October 2009
4 Not printed. See Annex A of Helping to Deliver
Climate Change Adaptation through the UK Planning System,
prepared by the Town and Country Planning Association, published
August 2009. Back
5
In reference to the sustainable development duty, use of well-being
powers, use of planning conditions and agreements, and use of
compulsory purchase orders. Back
6
Not printed. See Helping to Deliver Climate Change Adaptation
through the UK Planning System, prepared by the Town and Country
Planning Association, published August 2009. Back
7
For example in the study for England found that financial and
in-kind contributions for open space rank relatively high on par
with contributions towards transport and travel (Crook et al,
August 2008, Chapter 3). Back
8
Section 3 of the Planning and Compulsory Purchase Act 2004. Back
9
Section 340 of the Greater London Authority Act 1999. Back
10
Section 35 of the 2004 Act. Back
11
Section 60 of the 2004 Act. Back
12
Section 69 of the 2004 Act. Back
13
New Section 3A(6) to the Principal Act introduced by the Planning
etc. (Scotland) Act 2006. Back
14
New Section 4 (1) (b) to the Principal Act introduced by the 2006
Act. Back
15
New Section 16 (1) (b) to the Principal Act introduced by the
2006 Act. Back
16
This issue was noted in the East Midlands Regional Plan Annual
Monitoring Report 2007-08. Back
17
Annexes 1 and 2 not printed. Back
18
CLG, July 2009, Land Use Change Statistics, England, Table P223. Back
19
CLG, July 2009, Land Use Change Statistics, England, Table P241. Back
20
WAG, January 2009, Development Control Quarterly Survey, January
to March 2008. Back
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