RIBA responds to two DLUHC planning consultations
The Department for Levelling Up Housing and Communities (DLUHC) has sought input on the Infrastructure Levy and Environmental Outcomes Reports consultations. This blog looks at RIBA's response which focuses on the need for improved natural and built environments and how the planning system can implement these proposals.
Technical consultation on the Infrastructure Levy
The Levelling-Up and Regeneration Bill (LURB) establishes the framework for the new Infrastructure Levy (the levy) to replace developer contributions from the Community Infrastructure Levy and Section 106 planning obligations, with the intention of improving community infrastructure, streamlining planning and addressing regional imbalances. Last year, we welcomed this – however, now we must ensure it delivers this.
Equalising regional imbalances
The new levy must ensure that developers fairly contribute to infrastructure. Currently, some regions receive a larger share of developer contributions than others. The levy is an opportunity to make sure the least affluent regions and communities equally benefit from developer contributions – and government should work to guarantee this happens.
Preserving affordable and social housing
There is a risk that the new levy will not facilitate affordable and social housing, with the proposed value threshold in the levy potentially worsening regional imbalances. This is because it is suggested the levy would only be imposed on a developer's revenues from permitted development rights when the project's square footage value exceeds a specific threshold.
Higher property values in London and the south of England would mean that these areas continue to receive the most benefit from the levy. As the housing crisis deepens, the government must work harder to ensure everyone can access a safe and secure home.
Balancing cost and non-financial solutions
Varying construction costs across regions affect project profitability and feasibility. This can discourage home construction and hinder financially viable projects in less affluent areas. Therefore, generating funds for infrastructure and ensuring developers contribute to it is crucial.
However, the levy should not solely focus on financial contributions but also consider non-financial benefits like job opportunities, training programs, and community investments, fostering well-rounded community development influenced by new developments.
A new approach to environmental assessment
The government are also establishing a new approach to environmental assessment – known as Environmental Outcomes Reports (EORs). The EORs will contain a series of outcomes, which are yet to be defined, though it will likely measure biodiversity, air quality, water, waste and cultural heritage, in line with the EIP23.
To ensure the new system delivers a sustainable environment it must align with the UN Sustainability Development Goals and acknowledge the interconnectedness between the built environment, climate change, natural habitats, as well as human health and wellbeing. If government fails to include areas such as the changing climate, adaptation and how these intersect with population and human health, it will risk environmental protection.
Once the LURB becomes law, the government will have the ability to define the outcomes and the regime in greater detail. We will continue to engage with government as this happens.
Supporting planning departments to deliver
To deliver these proposed complex changes within the planning system, the government must invest and equip local authorities with the right knowledge and skills. Planning teams nationwide are already under pressure and adapting to new requirements will likely exacerbate this. We continue to advocate for well-resourced planning system, which includes relevant design expertise.
What next?
We continue to work with the government to improve the planning system and embed sustainability in all projects. This is vital to deliver houses and communities that are safe, sustainable and suitable for everyone.
