Written evidence submitted by the Campaign
to Protect Rural England|
1. The Campaign to Protect Rural England
(CPRE) is concerned that the proposals set out in The Plan
for Growth, which was published alongside the 2011 Budget,
are incompatible with commitments set out in the Coalition
Agreement that the Government will be the "greenest ever"
and will "radically reform the planning system to give neighbourhoods
far more ability to determine the shape of the places in which
their inhabitants live."
2. In its inquiry into the environmental impact
of the Budget we suggest that the committee considers how the
Government will deliver on these promises, particularly in relation
to the following points:
of the critical role of planning in delivering long term, sustainable
economic growth while also promoting environmental and social
goods must not be lost in a rhetoric of the planning system as
a "barrier to growth";
presumption in favour of sustainable development must be based
on a sound definition of "sustainable development",
and this presumption must not override the plan-led system of
commitment to continued protection of the Green Belt and Areas
of Outstanding Natural Beauty (AONBs) is welcome. The abolition
of the target for housing development on previously-developed
land, however, combined with incentives for development that do
not favour quality and need, could seriously undermine protection
of non-designated, yet still valued, green space;
Budget implies that the role of the planning system is to deliver
jobs and economic growth. It is unclear how this can be reconciled
with its role of economic, environmental and social objectives.
3. CPRE welcomes the opportunity to submit
evidence to the Environmental Audit Committee's inquiry into the
Budget 2011 and Green Taxes. As a leading environmental charity,
we have worked to promote and protect the beauty, tranquillity
and diversity of rural England by encouraging the sustainable
use of land and other natural resources since our formation in
4. CPRE champions the role of planning in
protecting the environment while securing appropriate development
and effective local involvement. We welcomed the Coalition's original
aspirations for planning reform, which recognised the importance
of involving people in local decision-making, but are deeply concerned
by the package of planning reforms announced in the Budget, which
suggest that some in Government have a confused view of the role
and value of the planning system.
5. CPRE believes that, to be sustainable,
future economic growth must remain within environmental limits,
acknowledging that natural resources including land and landscape
are finite. We welcome therefore the commitment included in The
Plan for Growth to the continued protection of Green Belt
land and AONBs.
6. This commitment was accompanied, however,
by a series of statements that threaten seriously to undermine
the ability of planning decision-makers to take into account environmental
and social considerations as well as economic ones. CPRE believes
that these statements arise from the misconception, articulated
repeatedly throughout the Budget speech itself and the accompanying
literature, that the planning system acts as a barrier to economic
7. For example, a Written Ministerial Statement
by the Minister for Decentralisation, Greg Clark MP, published
on 23 March, stated "there is a pressing need to ensure that
the planning system does everything it can to help secure a swift
return to economic growth". This statement represents a fundamental
shift from the planning system as a mediator between economic,
environmental and social priorities to one focused on delivering
economic growth alone. And such a shift is contrary to existing
planning legislation which states that the objective of the planning
system is to contribute to achieving sustainable development.
Much about the ongoing reform of the planning system is still
to be clarified by the Government, and we recommend that the Committee
considers how the environmental objectives of planning are not
lost in a push for short term, unsustainable economic growth.
8. CPRE believes that, on the contrary,
for over 60 years the planning system has operated as a democratic
process that advances public, not sectional, interests by mediating
between different aims; local and national, economic, environmental
and social, short-term and long-term. In doing so the planning
system has successfully delivered sustainable development. It
has played a crucial role in protecting the countryside from inappropriate
development and in securing the holistic regeneration of urban
9. The Budget proposes that to resolve the,
we believe misconceived, "problem" of an overly obstructive
planning system, the Government will "introduce a new presumption
in favour of sustainable development, so that the default answer
to development is 'yes'". CPRE welcomes the qualification
that this development must be sustainable. We suggest therefore
that to provide greater certainty for all, and to identify the
common goal towards which all participants in the planning process
should be working, the Committee should reiterate the recommendation
made in its recent short report, Sustainable Development in
the Localism Bill, and recommend to Government that it enshrines
in the Bill a short definition of sustainable development using
the principles set out in the UK Sustainable Development Strategy.
These principles are:
(i) living within environmental limits;
(ii) ensuring a strong, healthy and just society;
(iii) achieving a sustainable economy;
(iv) promoting good governance; and
(v) using sound science responsibly.
10. Even a sound definition of sustainable development
must not override the presumption in favour of the development
plan that is currently defined by planning legislation.
This presumption allows for a "plan, monitor, manage"
approach to development, meaning that development is delivered
in response to evidence of need. Such a strategic approach protects
the countryside from ad hoc, unnecessary and unsustainable development.
We recommend that the Committee explores how a sound presumption
in favour of sustainable development could be reconciled with
the established plan-led system of development.
11. The Budget also included the abolition of
a national target for the proportion of new housing to be delivered
on previously-developed land. The justification for the abolition
of this target, as included in The Plan for Growth, is
that it has "helped to drive up land prices in certain areas
and would increasingly limit the supply of new housing, which
would harm first time buyers in particular".
12. CPRE believes that one of the biggest environmental
successes of recent years has been the regeneration of many of
our urban areas due to development being targeted towards "brownfield"
sites, and that this has also protected vast swathes of countryside
from unnecessary development. As a result of the previously-developed
land target introduced to Planning Policy Statement 3: Housing
(PPS3) by the previous Labour Government 80% of new homes built
in 2009 were on previously-developed land. This is as opposed
to 56% on previously-developed land in 1997.
13. CPRE believes that the loss of a target for
development on previously-developed land, combined with the use
of incentives to encourage development regardless of quality or
need, could seriously undermine the ability of the planning system
to direct the right kind of development to the right places, with
potentially seriously damaging consequences for the countryside.
14. While the commitment in the Budget to the
continued protection of the Green Belt and AONBs by the planning
system is to be welcomed, CPRE is extremely concerned about the
level of protection that will be afforded to non-designated green
space in the wake of the abolition of the previously-developed
land target and the implementation of development incentives.
This "ordinary" countryside makes a profound difference
to well-being and must not be disregarded. While supporting the
inclusion of empty home refurbishments within the scope of the
New Homes Bonus incentives scheme, we strongly question whether
the Government's policies are strong enough to promote urban regeneration
and a brownfield first approach to development.
15. In particular, we would have welcomed some
consideration of equalisation of VAT on house refurbishments and
new build. Such a change, we believe, would provide a significant
fiscal incentive for both individuals and business to invest in
bringing empty homes back into use, and thereby complement the
New Homes Bonus, which is not weighted towards rewarding environmentally
sensitive house building. In place of fiscal incentives, we look
to the forthcoming National Planning Policy Framework to give
clear guidance to local authorities that they should prioritise
refurbishment of existing empty dwellings and development on brownfield
16. CPRE recommends that, in considering all
of the issues described above, the Environmental Audit Committee
addresses in particular how contradictions in commitments to environmental
health, economic growth, local involvement in planning and the
perpetuation of a plan-led system of development might be reconciled.
20 April 2011
14 S.39 Planning and Compulsory Purchase Act 2004 Back
S.38 Planning and Compulsory Purchase Act 2004 Back