1. Introduction
The Eastern Powerhouse (EPH) is an independent, business-led, membership body that represents the East of England. Our goal is to drive economic growth and investment in infrastructure to enhance productivity across the region. By collaborating with the private sector, universities, colleges, local authorities, and political parties, the EPH serves as the unified voice of business leadership in the East of England. Our core mission is to maximise the region's assets and unlock growth opportunities for investment, achieving local, national, and global impact.
On behalf of our members, we have compiled this response to the consultation on proposed reforms to the National Planning Policy Framework and other changes to the planning system. Our primary focus is the need for wider regional consideration in planning for economic growth, particularly the need for investment in vital infrastructure, without which growth cannot be achieved. Our response does not easily correspond to the specific questions that are asked as part of this consultation, but we have tried to align where possible.
2. Infrastructure
The EPH agrees that the Government should improve the current water infrastructure provisions in the Planning Act 2008 (Question 84). Britain has not built a new reservoir since 1992. Since then, the population has grown by 10 million. Development of new residential and commercial development in the East of England is severely constrained by challenges to the supply of water. A new reservoir is proposed by Anglian Water and Cambridge Water to be situated near Chatteris and March in Cambridgeshire. However, this reservoir is not scheduled to operate until 2035 at the earliest. Once built this reservoir will take five years to fill.
Ambitions to grow Cambridge or any other part of the East cannot be achieved without this. Streamlining the planning system for nationally significant infrastructure projects is important in overcoming resistance from local communities and regulators and signalling to investors that development can be brought forward in a viable timeline. Making planning decisions easier and less contestable will significantly reduce ‘planning costs’ making major infrastructure development (including transport and energy) more affordable. This would bring the UK in line with other G7 nations.
The EPH believes that there are other areas of water infrastructure in the East of England that could be improved (Question 85). Excess rainwater stored in the Ouse Washes, is currently pumped into the North Sea. Instead of wasting this water the EPH has proposed a network of small reservoirs on agricultural land adjacent to all the drains, dykes and rivers that form the Fens. Each one could hold enough water to supply 2,800 homes per year. Most large farms in the Fens already have at least one reservoir and most farm managers are highly experienced in reservoir management. Planning for such a network would require strengthening duties to cooperate between different authorities (Para 24), ideally by reinstating Regional Spatial Strategies.
3. Spatial planning and strategic development
The EPH believes that the NPPF must be amended to support effective co-operation on cross boundary and strategic planning matters (Question 12). Regional Spatial Strategies, revoked by the Coalition Government in 2010 through the Localism Act, are needed to bridge the gap between the local and national level and to address the inertia that is hindering development. Government should establish a 'spatial' vision and strategy specific for each region to:
Identify in general terms areas for development or regeneration over a twenty-year period
Outline housing figures for local authorities to take forward in their local plans
Develop regional strategies for transport and energy
Establish key priorities for investment, particularly in infrastructure.
This should address regional and sub-regional issues that may cross county, unitary authority or district boundaries. It should include spatial development strategies produced by Mayoral Combined Authorities, where plan-making powers have been conferred. All regions should have a planning equivalence to the London Plan to help pump-prime development and distribute growth more evenly across the region.
4. Green Belt and land value
The EPH agrees with the proposed definition of grey belt land (Question 23). Development should in most cases be on identified brown field and then areas of the Green Belt comprising Previously Developed land. However, most Green Belt land in the East of England is north of Greater London and around Cambridge, which is constraining the growth potential of the Cambridge economy and the need to connect the region along the ‘Tech Corridor’ to London.
We agree that the NPPF should support the release of land in the right places, while allowing local planning authorities to prioritise locations (Question 28). But this must be done in line with a wider strategic plan to identify the most sustainable development sites in the region over the longer term. The focus for development should be along transport corridors between major settlements and employment sites in the region.
Rail infrastructure is vital to growth and planning should enable development around existing stations and lines to facilitate third party funding, via private sector investors. Network Rail is an important public sector landowner in the region. These assets, along with land owned by County Councils, should be brought forward for development as a strategic priority within the Government’s proposed ‘golden rules’.
Government should set indicative benchmark land values for land released from or developed in the Green Belt, to inform local planning authority policy development for strategic priorities. (Question 37). This would enable land value to be captured for investment in supporting infrastructure for housing and business premises.
The Government should also reduce the scope of viability negotiation to set out that such negotiation should not occur when land will transact above the benchmark land value (Question 39). Further to this, the NPPF should minimise the culture of planning by appeal, which is holding back development.
5. Housing
The EPH supports the proposal that where development is policy compliant, additional contributions for affordable housing should not be sought. Bringing forward affordable mixed tenure housing, especially in high demand areas is essential in providing for mixed communities and enabling social mobility (Questions 34 & 40). The mix of affordable housing required should meet identified local needs, across both affordable housing for rent and affordable home ownership tenures, rather than standardised targets e.g. 10% of all housing development (Question 48).
We agree that local planning authorities should consider the particular needs of those who require Social Rent when undertaking needs assessments and setting policies on affordable housing requirements. Community-led development, especially in rural areas, should be incentivised through rural exception sites and green belt development outside of the planning envelope to maximise land value capture for affordable housing and social rent (Questions 52 & 54).
The EPH notes that changes to planning won’t in itself build more houses. Capping the price of agricultural land for housing use (e.g. x3) will not encourage landowners to bring forward land for development. While increasing local authority powers to compulsory purchase land will only be effective where authorities are in favour of development. The UK has continued to fall short in the delivery of new homes since the state withdrew from housebuilding. The cost of building (including land) and the requirement to provide affordable housing requires government funding, to intervene in the market and make housing affordable, especially in areas of high demand.
The EPH also notes that the introduction of zonal planning could help to control land values and provide certainty for developers and builders, particularly with the designation of large developments and urban extensions, allowing for accelerated growth. However, it is essential that there is enough flexibility within the planning framework to meet demand (e.g. student and retirement homes) particularly for smaller parcels of land.
Many planning permissions don’t get built out for a number of reasons, often to do with viability. Time limits on planning consents should be shortened to 12-months windows to prevent delays in development.