Consultation Deep Dive: Questions 9–15 from the Site Threshold Reform Paper
In our final blog on the Planning Reform Working Paper: Reforming Site Thresholds this blog looks at the final set of questions (9 – 15) included within the Paper and explores some of the key themes that might arise..
Building on our previous blog post, we now look at Questions 9 to 15 of the Planning Reform Working Paper: Reforming Site Thresholds. These questions explore the practical and policy challenges around timelines, design, Section 106 agreements, and inclusion.
Question 9: Are the proposed determination periods right?
Would shorter timelines work better once wider planning fee reforms are implemented?
What it’s about: Timely decisions are essential—but can local planning authorities (LPAs) keep up if statutory deadlines are shorten?
Supporters might say: More predictable, faster decisions would benefit all developers.
Concerns might include: LPAs may need fee reform or more staff first; shorter periods without capacity = more refusals or poor outcomes.
Question 10: What S.106 barriers do SMEs face?
And what reforms could help deliver affordable housing without burdening small developers?
The issue: Negotiating S.106 agreements is often too slow and complex for SMEs.
Ideas might include:
- Standardised templates,
- Upfront infrastructure charges instead of drawn-out negotiations,
- Exemptions or simplified obligations for small schemes.
Balance needed: Still need to fund affordable homes fairly.
Question 11: What are the barriers to very small sites?
And how could design codes help?
The challenge: Small sites (fewer than 5 homes) often struggle with viability, awkward access, or planning resistance.
Design code solutions might include:
- Clear parameters for layout and materials,
- Fast-track consent if codes are followed,
- Flexibility on parking or density in urban infill.
Question 12: What kind of design code rules would help unlock development?
Useful rules might be:
- Maximum building heights or setback distances,
- Plot ratios,
- Roof types or materials in heritage areas.
Why it might matter: Predictable design expectations give SMEs and landowners confidence to build.
Beware: Too much rigidity could stifle creativity or limit use of modern methods of construction.
Question 13: Are there other issues/opportunities to ensure success?
This is your open floor.
Suggestions might include:
- Improved LPA digital systems,
- Local land registers for small sites,
- Community engagement tailored to small projects.
Question 14: Environmental Impacts
What should the government consider under the Environmental Principles Policy Statement?
Key points:
- Cumulative impact of many small sites,
- Risks to habitats on rural edge sites,
- Opportunities to improve urban biodiversity if done well.
A balance is needed: Streamlining mustn’t mean weakening protections.
Question 15: Equality and Inclusion
What are the impacts on people with protected characteristics?
Important issues:
- Accessibility for disabled people,
- Affordable housing provision for low-income households,
- Community safety and amenity.
A good planning system should deliver fair outcomes for all—especially the most vulnerable.
Final Thoughts
The second half of this consultation goes beyond site sizes—it digs into how the entire planning ecosystem functions: from decision timelines to affordability, environmental protection, and equity. Getting these elements right is essential to a planning system that delivers both speed and quality.
Ready to Respond?
Deadline: 9 July 2025
Submit your views: GOV.UK Consultation Page
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