What do we think about the implications on the planning reform working paper on site thresholds published at the end of May?
If you can’t keep up with the swathe of working papers dropping lately, this one looks to introduce a graduated approach to applications to create a ‘medium’ level in addition to changes to the existing minor and major categories. The hope is to make medium sized sites easier to build for SMEs.
Also, consideration of making a ‘very small sites’ threshold, i.e. sites of less than 0.1ha and including windfall developments in the form of change of use.
The big question – is this a positive step? Or another false promise of speeding up the planning system while actually bogging everyone down with new legislation/procedures?
Challenges of medium-sized sites
My view is that medium sized sites can be difficult. They often have all the same technical constraints and political issues as big sites but without the space and/or values to deliver solutions or other planning benefits.
I’ve also dealt with so many sites that had a capacity of 12 or so dwellings, but a minor scheme for 9 dwellings has been pursued because it’s more viable as a minor scheme.
However, beyond contributions, the Paper recognizes that there is little difference between how planning applications for 10 homes are treated in the system compared to those for 100s of homes.
In that regard, I think a lot of us would be pleased to see the consideration of all minor schemes being decided under delegated powers.
Relaxation on BNG
In a planning environment where we see even single unit schemes needing BNG reports, often drainage reports and highway reports (usually contained to access only), and then still ending up at committee, something does need to change.
I welcome a potential relaxation on BNG for minor developments – although it does feel like there could be something between the total exemption being considered and the clunky small sites metric we have right now.
Perhaps a simple ‘no net loss’ approach, or automatic off-site contributions being required?
The nuance of ‘medium level’
In terms of the new ‘medium level’ it does seem that a threshold of 10-49 homes is potentially too wide, depending on the urban vs rural nature of the area. A 49-unit flatted scheme in central London can be relatively straightforward whereas in more rural locations adding 49 new houses to a village could be the largest extension in its history.
Although the relaxations for this scale of development are limited, determination periods remain the same, while looking to try and agree S106s more quickly. It’s likely that local validation checklists would remain the same and therefore local requirements could remain quite onerous.
In fact, many 9-unit schemes could be 15-unit schemes. Further, many 20-30 unit schemes struggle to provide on-site affordable housing as registered providers don’t want to take on just a few affordable rent units, BNG is not deliverable onsite, and the other contributions can be hard to agree. It might work better to lower the threshold of medium sized sites and increase the help being offered.
It is a worthy effort but possibly requires more thought on the key issues facing this scale of development, with a more radical overhaul potentially required.
