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05.09.2022

Dear Prime Minister: A Planning & Environmental Wish List

After a summer of hustings, debates, and garden party faux pas, a new Prime Minister is finally entering Number 10. 

Whatever your thoughts on the outcome of the Conservative leadership election, it is probably safe to say that our new leader is going to have a lot on their plate. 

As such, Claire and I thought it might be helpful if we set out a few thoughts on how this shiny new government might want to approach its planning & environmental agenda. Sort of a crib-sheet, or wish list, if you will. 

So, more in hope than expectation, please find below our miniature manifesto. 

A New Approach to Energy

The country can no longer put energy on the back burner*. Particularly, given the role that energy pricing, and energy security, is playing in the current cost of living crisis. 

Now that campaigning is over, it is time to stop making tub-thumping comments, about stopping the expansion of solar and wind farms, and get serious.

The country urgently needs to find local, reliable, alternatives to imported gas and oil reserves. We do not have the luxury of time. Pinning all our hopes on commissioning new nuclear power stations or the end of the war in Ukraine is, frankly, foolish.

Solar and wind farms can be brought online relatively quickly and can really help meet our energy needs in the short term, but only if the government stops getting in the way.

We need to fund alternative sources of energy to provide a complete energy mix and remove the current pricing strategy which means that cheaper sources of energy are sold at the same price as the most expensive.

We also need to bring back and expand micro generation for domestic use and selling surplus energy into the grid. If you are that worried about the loss of farmland for solar generation, it wouldn't be a bad idea to make roof top generation schemes cheaper and more attractive to the general public.

This will, of course, require that we sort out the grid - it needs extra capacity - but if you are serious about banning petrol cars by 2030, that needs to happen anyway.

Oh, and don't forget about the need to tackle demand. It is likely that this level of energy insecurity will last for a while, so we can't waste the supply that we have. Bring back and expand retro fitting insulation to make homes and public buildings more efficient. Whilst you are at it, a public awareness campaign over the passive load of electrical appliances and other energy saving tips  that don't involve wearing more jumpers, might not be a bad idea...

Finally, don’t reinstate fracking. It will not help.

Water, Regulation & Reservoirs

As should be clear from recent headlines, something has gone very wrong with the country's water supply. Unless our new Prime Minister wants their term in office to be literally mired in sewage, we need to do something about it.

This will cost money, but it is vital. It makes no sense for something as essential as water to be controlled by a monopoly. There is no such thing as a genuine market or consumer choice when it comes to our water supply, and it is currently far too easy for water companies to put profit before infrastructure. 

We either need to re-nationalise water, or regulate it properly, which means beefing up the Environment Agency and following through on that promised amendment to LURB.

Also, please preserve the water quality rules from the EU which saw a dramatic increase in water quality of our surface water courses and coastal waters. Not all 'EU red tape' is actually disposable. We do actually need some of it.

Speaking of things we need: we must invest in water infrastructure. No new reservoirs have been built since privatisation. This needs to change to adapt to a rapidly changing climate.

We also need to capture water differently due to the changes in rainfall patterns. We need to protect against drought in the future.

This is something we have to do now. If we put it off, the country will come to regret it.

Close the Revolving Doors at DLUHC (for a while...)

England is in the middle of an acute housing shortage. We are trying to fix it with a planning system that is close to breaking point. 

The reasons for this are myriad, complex and interconnected. There is no silver bullet. No single solution. Tackling the crisis will take a concerted effort, over a considerable period of time, by people who truly understand the sector.

The constant churn of senior ministers at DLUHC has not helped. In fact, it just adds to the sense of uncertainty and instability which is leading many local planning authorities to delay or defer work on their local plans.

The department has had seven secretary of states and eleven housing ministers in the past ten years. It is rare for an appointee to remain in place for more than eighteen months. 

This level of turnover makes it almost impossible for the politicians in charge of resolving our housing crisis to truly understand it. A situation which does not help the consistency or quality of decision making.

If the new Prime Minister is serious about tackling the housing crisis, we need a significant period of stability at DLUHC.

Take Local Government and Civic Infrastructure Seriously

If you were to identify a 'golden thread' running through the Levelling-Up Agenda, it would be local government. 

Planning, social care, high street regeneration projects, waste collection, highway improvements and even the development and location of new schools are all the responsibility of local government. 

In order to have a shot at reducing regional inequalities, we need vibrant and effective local government. At the moment it is barely functioning. 

The problems in the planning system are plain for all to see. Years of budget cuts and under-investment has resulted in severe staff shortages almost across the board. Morale is also at rock bottom, with comparatively low public sector pay making it extremely difficult to attract and retain new officers. This urgently needs to be addressed.

Additional resourcing, and revitalised training and support systems, are desperately needed if we are to reduce delays in the planning system - both when it comes to policy formation and determining individual planning applications.

A mechanism for effective strategic planning is also essential if we are to tackle cross-border issues: such as water neutrality concerns, the delivery of strategic infrastructure projects or maybe, you know, attempting to actually meet our housing needs.

The issues of under resourcing, however, extend far beyond the planning system. Every single part of local government is feeling the pinch. As inflation erodes councils' spending power still further, more and more councils are likely to end up in trouble: Croydon, Slough and Thurrock may just the first in a depressingly long list of authorities in need of financial assistance from central government. 

And lets not forget the other civic institutions that are needed for a functioning society - such as the courts.

Whilst planning litigation is generally thought of as a civil matter - made up of judicial review challenges, statutory reviews and other public law claims in the administrative court; most planning enforcement cases ultimately end up in the criminal courts. The criminal justice system is creaking at the seams, which is having a knock on effect on enforcement cases.

There is very little point in strengthening planning enforcement powers (which the LURB arguably does), if Councils are prevented from effectively prosecuting breaches because of a lack of capacity in the Court system. It is also grossly unfair on defendants for the stress and potential consequences of a criminal prosecution to be kept hanging over their heads for years on end, with little hope of resolution.

Preventing legal aid barristers from striking is not going to fix the problem. I'm afraid that the entire justice system requires investment, and quickly.

Stop Demonising Developers and Deifying the Green Belt

You cannot solve our housing crisis without building houses. That requires two things: 

  1. Land, and 
  2. A development industry. 

Recent anti-development, and particularly anti-house builder, rhetoric has been far from helpful in this respect. We have not have a significant government-led house building programme for a number of years now and, as a result, we are almost entirely dependent on private sector house builders to deliver new stocks of both market and affordable housing. The government is going to need their help and cooperation if we to increase our overall levels of housing delivery without a major state-backed development programme.

Whilst we are on the topic of unhelpful rhetoric, we need to have a honest grown-up conversation about the green belt.

The green belt is an urban containment policy, designed to prevent urban sprawl. It is not a comment on the ecological or agricultural value of the land in question. We have other planning designations for that. 

Green belt does not mean green field or even open countryside. It just means that the land is located near a major city or urban conurbation.

In and of itself, that is not a good reason for it to be treated as sacrosanct.

Take a Breath, Engage with Stakeholders and Think Things Through 

And finally... please be aware that the planning system, and indeed our environment, is intricate and highly complex. There is a genuine risk that poorly thought through government policy could make things worse... rather than better... So please, take a breath, genuinely engage with those who work in the sector and keep a very close eye out for those pesky unintended consequences...


*pun fully intended (and wholly unauthorised.... Claire has not signed off on it)

Speaking on BBC One's Sunday with Laura Kuenssberg, Foreign Secretary Ms Truss said action on energy bills would be "vital" for people and the economy.

She added that further support would need to go "hand in hand" with a plan to boost domestic energy supplies, arguing the UK had become too dependent on international energy prices.

Mr Sunak said further energy payments to pensioners and the low-paid, beyond those he announced as chancellor, should be targeted at pensioners and the low-paid.

He has argued his suggested cut to VAT on energy bills would also provide some help for all.

He also said he couldn't rule out the prospect of blackouts over the winter to ration supplies, as the situation was "serious" and "every tool in the toolbox" would be needed.”