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Proposed Changes to the Planning Framework

The government recently issued two consultation papers proposing changes to the planning framework for England.  These proposals will significantly impact Chorleywood by changing the target number of houses in the Three Rivers district, and the rules that control them.  

You may have seen national press coverage of the problems many commentators see in these proposals.  Below is a summary of our key concerns with the first consultation on “Changes to the Current Planning System”, which the government intends to build into the current Local Plan process in 2021. 

We have submitted our formal response to the government, with a copy to our MP, in order to ensure Chorleywood views are considered when parliament decides the outcome of this consultation.  Thank you to all those who completed our online form showing support for our response.  

CRA have also reviewed the the second consultation white paper "Planning for the Future" ( and submitted our response for the 29th October 2020 deadline. Overall the White Paper is very high level and, whilst it contains some elements that appear on the surface to address some of the existing problems in the current planning system, without fully understanding the detail that will underpin these concepts, it is hard to provide many detailed comments or to be certain they will address the problems. As such we are keeping our response (which can be found here) at a fairly high level focussing on the following main areas of concern:
  • The need for housing requirement targets to take into account constraints on available land due to Green Belt, AONB, Conservation Areas and wildlife sites so that housing is not required to be built in or directly impacting these areas.
  • The need for the local voice to be clearly heard in deciding the categorisation of land, the design requirements for new housing and the final design of new development.
  • The need for infrastructure to be provided before new development is undertaken.
A full copy of the government’s consultation paper is available at

If you wish, you can provide your views directly to our MP at or by submitting a response to the Ministry of Housing, Communities and Local Government at

Here are our key concerns with the first consultation, on “Changes to the Current Planning System”:

A. The standard method for assessing housing numbers in strategic plans

The key element is a change to the calculation of houses each local authority must deliver. The current methodology being used by TRDC in drawing up our new Local Plan mandates the use of outdated housing demand projections which significantly distort the results. A change is highly desirable. But we cannot support the new proposal.

For context, over the last 3 years Three Rivers delivered 186 new homes every year in line with its 2013 Local Plan. The new calculation increases this number to 588 new homes per year, a huge 216% increase. Delivery of this increased target in Three Rivers, which is 80% Green Belt, cannot be achieved without significant development of our Green Belt land.

In particular:
  • Despite the government’s repeated commitment to protecting the Green Belt, and the PM’s personal endorsement of this in his answer to our MP’s question in PMQ’s, there is no allowance in this first consultation for constraints on land availability due to Green Belt to be considered. And this new calculation will probably take effect, in 2021.

  • The government says it will address land availability in the second consultation, on “Planning For the Future”, but that will not take effect until much later, 2022 or 2023. Too late for Three Rivers and our Green Belt!

  • It makes no sense for the second consultation to make allowances for land availability constraints when by then, for TRDC and similar areas, allocations of Green Belt to development might already be locked in under our new Local Plan. We simply cannot see how the Government can proposed this irrational timing, which cancels out their promise of protecting Green Belt.
We strongly believe that the new calculation must take account of constraints on land availability at district level due to Green Belt, Areas of Outstanding Natural Beauty, National Parks or Conservation Areas.
  • The calculation has a base target of 0.5% of the current dwelling stock or the latest ONS forecast for average annual homes growth for the next ten years, whichever is greater. The use of the 0.5% of base factor adds an extra 157 houses per year to Three Rivers’ target. It will also mandate many new houses in areas where there is no great future demand, such as London. The result is high targets for new houses in the South East, while reducing the targets for new houses below current levels in many northern parts of England. This is not levelling up. It means building new homes in the wrong place, and / or districts missing their targets because they are impossible to meet.
We strongly believe that the 0.5% of dwelling stock should be removed from the calculation. It is not needed to meet the government’s overall target of 300,000 new houses, and it produces hugely anomalous results across the country.

There are two other important technical issues with the proposed calculation that we want changed. You can read our full reasoning on these points at the link at the end of this note. In summary:

We strongly believe that a cap on the yearly increase in house building targets should be reinstated, so that building capacity and land availability can be phased in. Large step changes in building rates are impractical and undesirable.

We strongly believe that the calculation should include a factor for mortgage interest rates in calculating the affordability ratio. Without this the calculated housing targets will be volatile, with potentially unstable and unintended consequences.

B. Delivering First Homes

The proposals increase the Affordable Housing discount for first time buyers to 30% - 50% of market value, and houses bought through the scheme can only be sold to other qualifying first-time buyers, in perpetuity. We believe this will lead to poor quality houses being built, and could trap families in unsaleable houses.

We believe a regulatory framework must specify quality standards for Affordable Housing alongside any changes to the discount levels.

We believe a provision should be added to allow sales to other buyers providing the discount at purchase is repaid, plus a share of any profit made on the sale.

C. Small sites planning policy

To help small and medium-sized developers, the proposals increase the level above which developers make Affordable Housing contributions to local authorities from 10 homes to 40 or 50 homes. But large developers also build small housing schemes! The proposals will allow large firms to avoid making Affordable Housing contributions, and increase their competition with small and medium-sized developers. This is not help for small firms!

It will also very significantly reduce the level of contributions towards to affordable housing which goes against all Government stated policy.

We strongly believe that relief from Affordable Housing contributions for small schemes must be limited to small or medium development firms and that a lower figure than the proposed 40-50 houses should be used as the threshold for Affordable Housing contributions.