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Our response to planning white paper consultation
Mebyon Kernow strongly objects to the “Planning for the Future” White Paper. It is our view that there are already many problems with the existing National Planning Policy Framework, not least because of the “presumption in favour” of development which has led to unchecked and damaging development that local communities have been unable to prevent.

But the proposed changes would undoubtedly make this situation even worse and be a disaster for Cornwall, its communities and environment.

PLANNING POLICY SHOULD BE DEVOLVED TO CORNWALL

In 2014, the UK Government recognised the Cornish as a national minority through the Framework Convention for the Protection of National Minorities, and pledged that the Cornish would be treated in the same way as the “other Celtic people, the Scots, the Welsh and the Irish.”

It is noted that the White Paper only relates to Cornwall and England, because planning is devolved to Northern Ireland, Scotland and Wales.

We call on the UK Government to fully meet its obligations through the Framework Convention and deliver a meaningful devolution settlement for Cornwall, which should include a National Assembly for Cornwall with the ability to take all decisions about planning and housing. This would include the powers to produce a Cornish National Planning Policy Framework and agree housing and other targets.

THE WHITE PAPER

The document includes numerous references to things such as tackling climate change, protecting green spaces, more building on brownfield land, the construction of beautiful homes and greater community involvement – but these claims are contradicted by the wider context of the document which is principally about making it easier for developers to develop!

Zoning (proposal 1)

Our members are extremely concerned at the proposal to zone the whole of Cornwall, and that land in “growth areas … would automatically be granted outline planning permission for the principle of development” and that there would even be “automatic approvals” for certain “pre-established development types” in other areas.

There is a lack of clarity in the document about how the zoning would work, but we feel it would be sub-standard to the existing planning system and there would be a risk of unregulated sprawl and unsustainable developments impacting on numerous Cornish communities.

Our members also strongly object to the “automaticity” of consent, which would undermine the ability of local residents to make meaningful representations on proposals for new housing and other developments in their areas. There is no evidence that communities would engage in the production of a Cornwall-wide policy document, rather than specific Neighbourhood Plans and / or planning applications.

Development management policies set at “national scale” (proposal 2)

Our members are strongly opposed to the proposals to further centralise the planning process in Whitehall with key development management policies “established at national scale.”

It is unacceptable that the decision-making capacity of local councils should be reduced. People in Cornwall know what is best for Cornwall, and should have the ability to set the planning policy framework that is used for the determination of planning applications.

Mebyon Kernow has no confidence that “national” policies imposed from Westminster / Whitehall will in any way understand or reflect what is distinct about Cornwall and its communities and heritage.

Our members are unhappy that the extent of policies in Local Plans would be reduced and we find it incomprehensible that local planning documents might be reduced to little more than "design guides and codes” for developments that have been automatically sanctioned through central government policies.

As noted previously, Mebyon Kernow aspires to see the creation of a Cornish NPPF and we would appeal to the UK Government to work with the people of Cornwall to maximise the policy development capability of bodies to the west of the Tamar.

“Standard method for establishing housing requirement figures” (proposal 4)

Our members are also strongly opposed to the imposition of a top-down “standard method for establishing housing requirement figures,” which would be particularly disastrous for the Cornish countryside and many of our local communities.

It is shocking that the UK Government has come up with a formula that would expect over 4,000 new properties to be built in Cornwall each year. Cornwall’s Local Plan already has an extremely high housing target of 52,500 new housing units over a twenty-year period.

It is frankly ridiculous to expect Cornwall’s next 20-year housing target to be increased to more than 81,000 dwellings. This truly unsustainable level of housing growth would have a significantly adverse impact on Cornwall’s environment and our public services. It would increase the number of dwellings in Cornwall by over 30% in just twenty years and it would equate to the construction of significantly more housing than presently located in the whole of the Camborne, Pool & Redruth area, and the Falmouth & Penryn Network Area, and the Truro & Roseland Network area.

It is little wonder that the formula has been described by some local government bodies as a “mutant algorithm.”

The idea that massively increasing house-building will reduce house prices is a fallacy. Over the last fifty years, Cornwall’s housing stock has doubled, whereas the problems with affordability have worsened.

It is also questionable that decision-makers in Westminster are actually that committed to measures which would reduce house prices or lower rents, as government policies in recent years have fed house price inflation and deliberately increased the cost of affordable housing.

Our members therefore disagree that any formula should include factors relating to affordability. Put simply, affordability problems are not a justification for an increase in the overall amount of housing, which would mostly be open-market non-affordable properties. Instead, this evidence should be used by central government to justify increased investment in proper affordable housing.

In addition, we would point out that this approach does nothing to tackle the issue of empty properties or to address the adverse impact of second home ownership on many Cornish communities – some of which can feel like ghost towns in the winter.

Automatic planning consents (proposal 5)

As noted above, our members object to automatic “outline planning permission” in growth areas and “automatic approvals” for certain “pre-established development types” in other areas for the reasons already explained.

It is clear that the White Paper fails to explain how the historic and natural environments of Cornwall will be safeguarded when automatic planning permissions are being allowed. For example, while designated landscapes and designated heritage assets will be protected, what about non-designated heritage assets or non-designated historic landscapes, and who will assess the extent of below-ground remains which might need geophysical survey?

Such issues demonstrate that the whole approach in the White Paper has not been properly thought through.

Mebyon Kernow members also oppose the imposition of large new settlements through the Nationally Significant Infrastructure Projects regime. We continue to be outraged that the so-called eco-town or garden village being built near Penwithick was imposed on Cornwall in spite of opposition from around one thousand people.

Speeding up of the planning process (proposal 6)

The priority for planning should be to make the right decision. This is more important than the speed of the application process and our members have experience that many delays in the planning process are caused by applicants putting in sub-standard information to the local council.

Mebyon Kernow is strongly opposed to suggestions that planning fees should be returned to applicants if developments are not dealt with within certain timeframes or are allowed on appeal.

The planning system needs to be fair and balanced, and to be seen to be balanced and fair. It must protect the Cornish countryside while allowing appropriate developments to go forward. The whole concept of refunding planning fees would show just how a planning system is tilted in favour of developers and landowners – rather than communities.

Thirty-month timetable for Local Plans (proposal 8)

Mebyon Kernow considers the proposal that local authorities should produce a new Local Plan (to a Government template) within a 30-month timetable to be ridiculous. In particular, our members have noted that the document states the initial stage asking for zoning suggestions should take only six months, while the drafting of the whole Local Plan (including the zoning of all land) should take only 12 months.

This is totally impractical, especially for a place the size and complexity of Cornwall – which is made up of numerous towns, villages and smaller settlements; urban, rural, coastal and industrial areas; and extends over a length of 75 miles.

There needs to be adequate time for there to be meaningful consultation and engagement with local communities in the production of planning policy documents.

A rushed plan will lead to bad planning outcomes and do damage to local communities.

Neighbourhood Plans (proposal 10)

Many of our members have been involved with parish councils and groups, which have worked extremely hard to produce Neighbourhood Plans and give a planning context to their local area.

It is clear that the changes in the White Paper would undermine the status of Neighbourhood Plans, and local communities will no longer be able to make decisions about where development should and should not be allowed in their local areas. This is a retrograde step which should not be allowed to happen.

In addition, the changes would make it much harder for residents to make meaningful representations on development proposals in their areas.

Sustainability (pillar two – planning for beautiful and sustainable places)

Mebyon Kernow would challenge the statement that “sustainability is at the heart” of proposals in the White Paper.

As noted above, the level of growth set out by the “standard method for establishing housing requirement figures” would increase the number of dwellings in Cornwall by over 30% in just twenty years. There is nothing sustainable about this extent of development, which would lead to the loss of a great deal of Cornish countryside and cause drastic and irreversible change to the character of Cornwall.

Design (pillar 2 – planning for beautiful and sustainable places)

Mebyon Kernow note the Government’s proposals about design guides and codes, which it is stated should be prepared “locally.”

It is the view of our members that all decisions about planning policy should be taken in Cornwall – it is not just about design, but also the scale of development and where it is located, etc.

A simpler framework for assessing impacts on environment (proposal 16) and conserving and enhancing historic buildings and areas) (proposal 17)

Mebyon Kernow is extremely worried that proposals in the White Paper will fail to safeguard Cornwall’s rich historic and natural environments.Our members feel that, with there being automatic planning permissions in growth areas and other zones, it is questionable whether enough attention will be given to the adverse impacts of developments on the environment.

While designated landscapes and designated heritage assets will clearly have some protection, this will undoubtedly not be the case with non-designated landscapes and non-designated heritage assets, which we would argue are very important.

For example, we would wish to see additional protections for Cornish hedges, some of which date to prehistory, and which could be lost if the planning system is dismantled in the manner proposed by the Government.

Infrastructure and affordable housing (Planning for infrastructure and connected place – pillar three)

Mebyon Kernow is extremely concerned at proposals in this section of the White Paper, which are lacking in detail.

It is the view of our members that Section 106 legal agreements have traditionally worked well in ensuring that affordable housing and other community benefits are delivered, while there has been great confusion around the Community Infrastructure Levy.

A reformed Infrastructure Levy appears very complex and it is understood that many planning professionals are querying how it will work. It also concerning how the consultation is asking questions about whether the same amount of affordable housing and whether it needs to be provided on-site.

It is the view of Mebyon Kernow that a key aim of planning should be maximise the percentage of properly affordable homes on developments and, in terms of rental housing units, they should be for social rent not the expensive so-called “affordable rent.”

The UK Government needs to ensure that the cost of affordable housing – both for rent and purchase – needs to be tied to the level of local wages, rather than being a slight discount from inflated rental or purchase costs. This is especially important in Cornwall, which is one of the poorest areas in Western Europe and where average wages are amongst the lowest in the United Kingdom.

Our members were also extremely concerned at the proposal in the recent “technical changes” consultation, which suggested that affordable housing would not be sought on sites of up to either 40 or 50 new properties. And while it states that this would not apply in designated rural areas (as defined by a 1981 Housing Order), this is problematic as many non-urban areas in Cornwall are shamefully not designated as rural areas.

Impact on people with protected characteristics (Equality Act 2010)

As noted at the start of this representation, in 2014 the UK Government recognised the Cornish as a national minority through the Framework Convention for the Protection of National Minorities.

But the authors of the White Paper have not considered the impact of the planning changes on the Cornish national minority and, in the view of MK members, the document fails to address the social, economic and housing problems being faced by the long-term residents of Cornwall, such as low incomes, poor economic prospects and limited access to properly affordable housing.

It is obvious that the construction of 81,000 – mostly open-market – new properties is not about meeting the needs of the people of Cornwall. It relates more to the feeding of an external market for property, which would likely lead to 150,000-180,000 new residents in Cornwall. It would also allow many wealthy families to have a second “home,” when many Cornish people do not have a first home.

The UK Government’s approach to planning policy, and indeed wider governance issues relating to Cornwall and the Cornish, clearly breaches a number of clauses in the Framework Convention.

A further submission will be made to the UK Government about the content of the White Paper and the Framework Convention.

PLEASE THINK AGAIN …

The members of Mebyon Kernow – the Party for Cornwall would ask the UK Government to rethink its approach to planning. The Planning White Paper would not be good for Cornwall and our members would formally request that all decisions about planning and housing are devolved to Cornwall.
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Published on 19th November 2020.

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