Housing Voice

Engaging with the planning system

Case Study: The Diocese of Leicester

Accidentally volunteering yourself for a job. Everyone’s done it. For Sian Rigby, being lumped with a task had unexpected benefits.

Sian is the Development Worker for Together Leicester, a joint venture between the Church Urban Fund and the Diocese of Leicester working with churches to tackle poverty and change lives. When she started her job, she researched the social issues that were going to affect the county. She soon found that there was a ‘Strategic Growth Plan’ out for consultation, which would shape the future of the county until 2050. She asked around to see if the Diocese was preparing a response. Ultimately, she was asked to do it herself!

It was really important for them to respond, because the Diocese is going to be significantly affected by the growth being planned. Sian also thinks that they’ve got a lot to give. They have a church in every existing community, so they can be a bridge between local people and regional institutions. This is particularly key in Leicestershire, where there can be friction between the city and the surrounding county. As one of the few institutions which covers the whole of the county, the Diocese can work for the common good.

Sian didn’t expect to change the strategy significantly, but felt that the Diocese should be responding nonetheless, because churches can act as a ‘prophetic voice’. She set out to ‘balance not holding back necessary growth with ensuring justice and accountability’. This meant acknowledging the need for housing, emphasising the importance of community building and affordable housing, whilst also thinking about how the plans for new development would affect current residents.

Why should churches engage with the planning system?

‘Use the power the church has, but use it well’ – Revd Clare Dowding, St Paul’s Marylebone.

Responding to planning consultations is something that every church, diocese, district or synod can do. Consultation processes often get heated, with a NIMBY (not in my back yard) attitude prevailing. Responses get polarised, and it is hard to get constructive feedback, even though this is crucial to seeking solutions. At their best, churches can offer something different. Churches should see this as part of their mission, speaking into the issues affecting their communities to stand up for the common good and prioritise the vulnerable. Through this, we can model a new way of being church.

You may not be able to say that your church made a difference – others may have made similar suggestions, or your suggestions may be ignored – but taking part in the process is still an important thing to do, because it demonstrates a long-term commitment to the whole community.

It’s also crucial for the church. Churches are often significantly affected by development plans. In particular, new housing developments can leave out the need for a church building. Sian urges churches to respond to consultations, because if we don’t, ‘we have no basis for complaining’.

The process itself can also be beneficial. There are lots of reasons for this. Firstly, it can help you to know your area better – something which is no bad thing for a minister, community worker or even congregation member aiming to carry out mission. It also forces you to think about the long term, something that churches sometimes aren’t very good at. This may lead you to reassess your own mission – if there’s going to be an influx of families in your area, do you need to focus more on children’s work? Thinking about how future growth will present new opportunities for mission can help to put an area’s short-term problems into perspective.

The basics

There are all sorts of planning consultations that churches and regional church bodies can respond to for the good of their communities! These include:

• Master plans – a long-term document which guides future development and planning permission.
• Local authority plans – such as local plans and area actions plans. Some churches even respond to consultations on highway changes, because all aspects of planning also influence community.
• Planning applications – whether brought by individuals or developers.
• Neighbourhood Plans – developed by community representatives – such as a Parish or Town Council, a Neighbourhood Forum or another community group – these must be approved by a referendum of local people, but there should also be consultation during their development.

Processes vary, but increasingly responses involve submitting a web form, with a combination of open questions with text responses and closed questions about whether you support particular aspirations of the scheme and/or how they have been carried out. It may be worth doing a mock run on the website, noting down the questions asked, and then basing your response around that. These forms should give you the option to explain that you are responding on behalf of an organisation, which will give your response more weight. In other situations – especially in regard to planning permission – it may be a case of submitting a written submission. After the consultation period has finished, a general report on the consultation will generally be released, explaining how it is being taken into account.

The best way to keep track of these is to visit the website of your local council. However, some news and consultations may be put out through the developers themselves, so if you know that there is a developer planning a large project in your area, you may want to keep an eye of their website as well. It’s also helpful to cultivate relationships with councils and developers, who may let you know when consultations open, or may even do some informal consultation with you at an earlier date.

Selling yourself: what has the church got to bring to planning consultations?

You’re a key stakeholder – whether as an individual church or regionally. Churches provide services for the area and may also own significant land.

You’re a bridge between individuals and institutions. Most institutions are just that – an organisation. A church is not only an institution, but also a group of people. Other organisations struggle to represent the people to whom they’re connected. Highlight the size and makeup of your congregation.

Regional church bodies (districts, dioceses, synods)

You have geographic spread. Most responding organisations will have a narrow geographical focus. For consultations on county or city plans, this gives your response more weight. You’re not going to prioritise your immediate neighbourhood over others, because you have a responsibility to the whole district or region: you can put localism aside for the greater good.

But, you’re still connected to the community. Through your churches, your response should be informed by an understanding of the local context. This is knowledge that even councils cannot readily access, so your response is very valuable. If you can, quote individuals from different churches who have highlighted issues within their specific area.

‘We have a church in every community. Therefore, we are one of the few institutions that literally covers the whole of the county’ – Sian Rigby, Together Leicester.

Representing your church: what do you have a mandate to say?

Consultation about consultation: It’s important to involve as many people as possible in preparing your response. If you’re speaking on behalf of the church, then that includes speaking on behalf of its members. So, if you’re writing from a local church, talk to others within your congregation. If you’re talking on behalf of a group of churches (synods, dioceses, districts), you should contact local churches if possible. Finally, always make sure that you have permission from your church leader or church body to respond on your church’s behalf.

You don’t have to take a side. But this doesn’t mean that you don’t have important things to say! Churches often explain that they don’t have a view on the whole scheme, but want to make it work if it goes ahead. They lay out how the scheme could be adapted to prioritise the needs of those who are in greatest need.

Is it in your patch? If the consultation is about a local housing scheme, then reply as an individual church. An individual church could also respond to a district-, county- or city-wide consultation, but it will usually be more effective if you respond as a group of churches – diocese, district or synod. It’s also likely to mean that the response is better informed.

Representing God: what needs saying?

Community is crucial to human flourishing, and should be a main focus of church responses. According to Justin Welby, the Archbishop of Canterbury, housing is ‘the architecture of community’. ‘Building new housing without clear community values and aims will lead to the same problems being repeated again in the future.’ 

So, how do you prioritise this in your response? Archbishop Justin has some examples: ‘no new estate should be built above a certain small size without the developer having to create areas for meeting, halls, space for shops and exercise, schools, clinics, centres of counselling and support, places of worship and other community facilities to ensure a clear community focus.’ Also think about how any new developments integrate social housing with private housing, and old housing with new.

Be a prophetic voice for those who can’t speak. Very few people will advocate for those who will live in the new developments, or who may not yet even be alive. Try to stand up for these people. Balance their need for a vibrant community with protecting the community already there.

Amplify people’s voices. While you should encourage people to respond to consultations on their own where they can, many will not. Therefore, consultations are often dominated by just a few polarised – often negative – voices. If it’s clear that a community is in favour of a scheme, highlight this. If there are concerns, then highlight these too, but try to do without promoting NIMBYism, for example by presenting potential solutions to the problems you raise.

Speak for those at the margins. We don’t knock down luxury apartments to build new homes, we generally knock down poorer quality housing. It’s not NIMBYism to stand up for these people. As Revd Clare Dowding from St Paul’s Marylebone said, churches should ‘leverage’ their public role to speak for those who can’t or won’t speak for themselves.

‘This is a community and that’s as important as any conversation about [lack of] housing’ – Revd Clare Dowding, St Paul’s Marylebone.

Affordability is a justice issue. Affordable housing allows people to live life in its fullness, and helps communities to flourish. This doesn’t mean that every new home needs to be below market rates, but that, as Archbishop Justin says, there should be a ‘significant proportion of genuinely low-cost housing on all developments… so that there is genuine social diversity and mobility of population and thus the mixing of different groups in ways that enable the formation of relationships and communities.’ 

The current definition of ‘affordable’ housing is 80% of the market rate, which is often completely divorced from what someone on the average local income can afford. Ask for clarification of what the price and tenure of new affordable housing will be, and highlight the needs of the community. In particular, ask what proportion of new builds will be social housing.

Protect God’s kingdom. As Archbishop Justin has said, ‘the issue of climate change and the environment must be faced’ when we are building housing. With new housing, suggest that developers meet a high environmental standard – such as Passivhaus. This prioritises well-insulated houses and low carbon boilers. Another big issue is green space. This is not only key for the flourishing of both individuals and community, but it is also vital for the planet. While grass lawns are great, other forms, such as wild flowers, can contribute more to biodiversity and absorbing carbon. Also prioritise sustainable transport in your replies, by encouraging provision for walking, cycling and public transport, and emphasising the need to discourage car use.

Provide scrutiny. Do the details match up to the headlines? Suggestions shouldn’t be made in an accusatory way but ensuring that individual elements of the plan don’t undermine the overall vision is a valuable service that you can provide.

In the Diocese of Leicester’s response, they highlighted that planned housing along new rural roads contradicted the plan’s commitment to restrict growth in rural areas.

Engage even if you don’t want the scheme to go ahead. You may not – personally, or even as a church – be in favour of a particular development. It may be a conservation issue, or it may not provide the infrastructure to balance the increased pressure on services. Nonetheless, you should still respond with helpful suggestions, even if you’ve highlighted your opposition to the scheme as a whole. It may well go ahead, and there’s no point throwing the baby out with the bathwater.

What is required?

You need to know your patch well. However, this knowledge can be built up during the process – Sian had only just arrived in her diocese when she wrote a response on their behalf. If you need more local knowledge, involve others as much as you can.

How long will it take?

This depends on what approach is being taken. The actual writing of a response rarely takes too long, but the more research you do – on the area’s needs, and on the background and detail of plans – the better.

Consultation and collaboration within churches will increase the timespan over which the response is formulated but may reduce the amount of time taken for those putting together the response, as they do not have to understand every aspect of the scheme themselves.

Know what’s going on. To take your engagement to the next level, it’s important to stay on top of what plans there are for new housing, so that you can react when a consultation comes out.

Keeping an eye on the plans for development in your area is ‘part of seeing the vision and challenge to which God is calling you’ – John Rose, Churches Together in All Lincolnshire.

All of the advice and guidance provided in these resources is based on conversations with churches and organisations that are directly involved in responding to housing need in their local area. The advice in this sheet is thanks to:

Revd Clare Dowding, St Paul’s Marylebone
Sian Rigby, Development Worker at Together Leicester
John Rose, Churches Together in All Lincolnshire