Consultation on the government's planning white paper, which was published in early August, closed yesterday.
In its submission to the consultation, the RTPI described the proposed new standard method for establishing housing requirements as a "centralised and data-driven formula [that] cannot possibly embrace all the possibilities inherent in a truly proactive planning process, where constraints and opportunities are developed through an iterative process".
It added that "introducing top-down housing targets and reliance on household growth projections at a time of major uncertainty due to Covid-19, the economic climate, Brexit and increased environmental challenges appears risky".
The white paper proposes the creation of a new zonal planning system with land designated as either "growth", "renewal" or "protected" areas.
On the proposals for the creation of renewal areas - which the white paper descibes as built-up areas where "smaller scale development is appropriate" - the RTPI said that such a designation is "too simplistic to deal with the complexity of existing urban areas, and it appears that these are what is left over when the other two designations are determined".
"As envisaged, these would cover the entirety of England's existing built up areas, from long established suburbs to industrial areas actually needing renewal", the response said.
Commenting on the proposed growth areas, which would have outline permission for the principle of development conferred by adoption of a local plan, the response said that "providing the consenting process envisaged will require a huge upfront investment of time and resources by local authorities and developers at the plan-making stage: to identify site constraints, secure infrastructure funding, designate sub-categories of land, and progress the accompanying masterplans and local design codes".
It warned that this will have "significant resource implications for the wide range of stakeholders and government agencies that are involved in bringing development forward, including public transport operators and utility providers, and require a step-change in how they engage in plan-making".
However, the RTPI also said that growth areas could provide greater certainty for developers and communities, if supported by upfront infrastructure investment, and clear policies, masterplans and design codes to ensure high standards.
Elsewhere in its response, the RTPI said it is "not convinced" by the proposed fast-track for beauty.
"Schemes which comply with provisions in the plan and site-specific design codes should find an easier route through the planning system, however good design and speed are rarely compatible".
It added: "Relying on tick-box approaches to design has never delivered enhanced outcomes".
On the proposal to scrap the existing Community Infrastructure Levy and section 106 planning obligations systems and replace them with a new consolidated national infrastructure levy, charged as a fixed proportion of development value above a set threshold, the RTPI said that this "could create an equally complex system with a different set of risks".
The response said that a single national levy "could not address the significant variations in market values across the country. This could undermine the levelling up agenda unless mechanisms were in place to redistribute income, which would complicate the process".
Other responses to the white paper have been published by:
- The Town and Country Planning Association (TCPA)
- The Greater London Authority (GLA)
- The Royal Institute of British Architects (RIBA)
- The Campaign to Protect Rural England
- The Bartlett School of Planning
- The Design Council
All of Planning's white paper coverage can be found here.