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The public consultation about proposed changes to the National Planning Policy can be found at this link. It is long and designed for the benefit of consultancies lobbying on behalf of construction companies, but anyone can respond and say what they think. We must not let the developers have all the say.
Do not fall for the spin about commuter hubs, affordable housing, starter homes or brownfield sites in the green belt. The definitions they intend to use for these are so broad that the proposed changes will mean that anything is possible. A "commuter hub" is to be defined as anywhere that could have a frequent bus link to a station during commute hours. The definitions of "affordable housing" and "starter homes" will be widened to cover a range of schemes. The starter home scheme that offers 20% discounts to eligible first time buyers has already pushed the price of new homes up by 20% and it is paid for by excusing builders from making contributions towards infrastructure. These schemes are not to help young local buyers as claimed. They are equally available to buyers under 40 from anywhere in the EU. Worst of all, "brownfield sites in the green belt" is an undefined term which could soon be interpreted to mean the golf courses and solar farms that are springing up everywhere across the countryside. That is where they will build next. In short the proposed changes are a raft of measures designed to see the end of England's green belt and rural landscape.
|Green belt already lost (red) or threatened (green) in South Essex|
Britain has a housing crisis, but it is no worse now than it has ever been. Buying a first home has always been difficult. The present low interest rates may make prices higher but they are no less affordable than before when interest repayments were higher. That's because the size of mortgage repayments relative to salaries is the only factor that controls UK house prices. There are enough true brownfield sites in the country to build a million new homes, but aggressive developers want pristine greenfield sites which are cheaper and require less remedial work, making their profits higher. We must not let the government hand it to them.
In these times of austerity the government is taking away the funding that would be used to build new schools, health services and roads or to deal with the impact of flooding and pollution from over-development. This is infrastructure that will be needed to prevent our cities ending up like Beijing. Low paid workers are being squeezed out of London by expensive developments being snapped up by rich foreign investors to be left empty. They will be expected to commute back in on crowded overpriced trains whose capacity is already stretched beyond safe limits. Our roads will grind to a halt and the cars will fill the air with harmful pollution.
If you want a second opinion on the consultations see the articles in the Telegraph here and here and here
What follows is my extended response to the questions the government is asking. To kick the proposed policy into touch we will need many more people to respond in their own words. The document is long and there are many technical questions but even if you offer short responses to just a few questions it will let them know how the public feel. You have until 25th January 2015 but please respond using the online survey now. You are permitted to return and add additional comments later.
Q1. Do you have any comments or suggestions about the proposal to amend the definition of affordable housing in national planning policy to include a wider range of low cost homes?
Section 50 of the NPPF states that planning authorities should "plan for a mix of housing based on current and future demographic trends" This is a very important requirement since otherwise we get segregation of up-market properties from affordable housing leading to a fragmented society with heightened inequalities especially when it comes to the quality of local schools and health services.
However, this section of NPPF also allows developers to offer an "off-site provision or a financial contribution of broadly equivalent value" instead of the affordable housing that they don't want to provide. In my home area around Basildon I have noticed that developers almost always take such an alternative. The amount they pay is not made public but it is known to be very small compared with the actual amounts that would be required to build affordable housing elsewhere. The result is that affordable housing is in short supply, and when it is built it is likely to be concentrated around already deprived areas rather than in the mix that the NPPF demands.
Broadening the definition of affordable housing will not rectify this fundamental problem. It will only provide the developers with more ways of avoiding the construction of the type of housing needed. Instead the government should tighten the conditions so that developers cannot avoid the provision of affordable housing.
The government wants to extend its starter homes scheme to "all suitably-sized housing developments" This will mean extending it from houses built on brownfield sites to houses built on green field sites including green belt. I strongly disagree with this change.
Q2. Do you have any views on the implications of the proposed change to the definition of affordable housing on people with protected characteristics as defined in the Equalities Act 2010? What evidence do you have on this matter?
Q3. Do you agree with the Government’s definition of commuter hub? If not, what changes do you consider are required?
I do not agree. A commuter hub is being defined to include anywhere that could have a future service to a commuter stop regardless of distance or time the journey would take. This is sufficiently broad to include almost anywhere. A commuter hub should be defined only to include anywhere within walking distance of a stop. Denser housing can be accommodated by developing the many brownfield sites that are not part of the green belt.
Q4. Do you have any further suggestions for proposals to support higher density development around commuter hubs through the planning system?
Commuter hubs already have the highest density of housing that can be supported given constraints such as green belt. The commuter lines into major cities themselves are also already heavily overcrowded and are very expensive. Nobody who lives near a commuter hub wants more housing in the area. The new housing will be for low paid workers who are being squeezed out of the cities by high property prices because the demand for affordable housing within cities is not being met.
For example, I am aware of a "Cash Incentive Scheme" run by London councils for the last few years which pays its council tenants large sums of money to move out to areas such as Basildon so that the housing can be redeveloped with luxury accommodation. There are other similar schemes supported by the government's Right to Buy Social Mobility Fund. This makes it harder for locals outside the city to buy homes and creates dormitory suburbs from which low paid workers face long expensive over-crowded commutes that they can barely afford.
The government should instead be looking at schemes to build more affordable housing within cities. It would be even better if they could also encourage businesses to move jobs out of cities into surrounding areas instead of workers. In the 21st century technology is making communications much better than they have ever been, the government needs to be more forward looking and recognise that most businesses no longer need to be crowded together. Commuting brings nothing but pollution and unpaid time away from home for those who cannot afford to live in the cities.
Q5. Do you agree that the Government should not introduce a minimum level of residential densities in national policy for areas around commuter hubs? If not, why not?
What we need to avoid is developers proposing to build estates of very low density executive homes on green field sites because this is what gives them the maximum profits. It also avoids obligations dependent on the number of houses proposed. The government needs to find a way to enforce the existing NPPF requirement for mixed density housing in all areas. New legislation being introduced to put more pressure on councils to approve developments only gives them less leverage to control the nature of the developments.
Q6. Do you consider that national planning policy should provide greater policy support for new settlements in meeting development needs? If not, why not?
One of the major problems with existing policy is that the Objectively Assessed Need for housing is based one existing levels of housing in an area. This means that authorities which already have a high level of housing such as Basildon are expected to build larger numbers of extra homes even if they are surrounded by green belt and their infrastructure is already beyond maximum levels of capacity. The NPPF and PPG allows authorities to take such constraints into account but residents are told by the councils that the planning inspectorate will not accept that. The NPPF needs to be modified to make it absolutely clear that areas such as Basildon can safely choose not to build beyond their capacity.
Q7. Do you consider that it would be beneficial to strengthen policy on development of brownfield land for housing? If not, why not and are there any unintended impacts that we should take into account?
Strengthening policy to prioritise the development of brownfield sites is the most important thing that can be done, with some provisos. The best way to promote development of brownfield sites is to strengthen protection for green belt land, green areas within towns and wildlife sites. It would also be wise to end the starter home scheme and use the money for grants to help prepare brownfield sites for development.
Care must be taken that brown field sites in the green belt are not used where it would harm openness. Sites in the green belt that have been used for renewable energy projects or sports grounds including golf courses for example must always be returned to their original state when the use is discontinued. Allowed some developments in the green belt must not become stepping stones to housing development. This should be made explicit in the NPPF.
Care should also be taken with commercial sites. These should not be turned into housing developments if it means that further green field sites will then have to be developed for commercial use. Again there is a risk that a stepped approach will be taken to development of green field sites if the NPPF does not forbid it.
Finally, brownfield sites that are subject to flooding should not be allowed to become housing areas. The systems to prevent this need to be overhauled and brought under the responsibility of a single authority since at present it is hard to establish who is responsible for preventing projects that could lead to flooding.
Q8. Do you consider that it would be beneficial to strengthen policy on development of small sites for housing? If not, why not? How could the change impact on the calculation of local planning authorities’ five-year land supply?
More could be done to help individuals who wish to convert dwellings to smaller units or build on small plots of land where there is a need for affordable homes. For example it should not be necessary to pay councils for planning advice and planning application fees where individuals intent to increase the number of homes by small numbers by converting their property.
One part of the housing shortage is caused by the number of people per home decreasing (e.g. from 2.4 to 2.3 between the 2001 and 2011 census) Instead of building new homes to accommodate them it would be sufficient to subdivide existing homes and replacing larger old housing with smaller flats.
Q9. Do you agree with the Government proposal to define a small site as a site of less than 10 units? If not, what other definition do you consider is appropriate, and why?
The danger with defining a small site to be one of less than 10 units is that developers will divide up large areas of land and/or apply to build small numbers of executive homes on large areas of green field sites. A small site should be defined by the area to be developed rather than the number of units and care should be taken to avoid any possibility of advantage from dividing up sites.
Q10. Do you consider that national planning policy should set out that local planning authorities should put in place a specific positive local policy for assessing applications for development on small sites not allocated in the Local Plan?
No, such developments should follow the rules of the local plan and not be made into exceptions. Otherwise developers will be able to develop against the plan by simply picking off areas in many small parcels instead of one large parcel.
Q11. We would welcome your views on how best to implement the housing delivery test, and in particular • What do you consider should be the baseline against which to monitor delivery of new housing? • What should constitute significant under-delivery, and over what time period? • What steps should be taken in response to significant under-delivery? • How do you see this approach working when the housing policies in the Local Plan are not up-to-date?
When green field sites are set aside for housing they are likely to be taken up quickly by developers because they provide more profit. Therefore the delivery test should apply to brownfield sites requiring that they are developed before green field sites.
A further delivery test is required to ensure that affordable housing is being provided as a part of all developments. The planning authority needs to specify a minimum percentage of affordable housing for any development. This should not be allowed to be circumvented by the use of financial wavers or other means.
Q12. What would be the impact of a housing delivery test on development activity?
The impact should be to maximise the use of brownfield sites and provide the right mixture of housing in every development.
Q13. What evidence would you suggest could be used to justify retention of land for commercial or similar use? Should there be a fixed time limit on land retention for commercial use?
Land for commercial use should be retained unless employment levels in the area are very high and there is adequate other land for commercial use to support the anticipated future growth of the local population.
There should not be any kind of time limit on land retention for commercial use since if there were it would make it favourable for investors to buy commercial land and keep it unused until the time limit passes after which the land would consequently rise in value for housing development.
Where unused commercial land is sited in the green belt it should not be automatically used for houses because the criteria for allowing inappropriate development must be reconsidered. If greenfield sites are allocated for employment and then not used they must be returned to their former status. To do otherwise would be to create an easy way for owners of green belt and other green field sites to convert their land for housing.
Q14. Do you consider that the starter homes exception site policy should be extended to unviable or underused retail, leisure and non-residential institutional brownfield land?
No. Our economy runs in cycles and the purpose of land should not change during one part of the cycle leaving a shortage during another part.
Q15. Do you support the proposal to strengthen the starter homes exception site policy? If not, why not?
No. Councils are capable of making decisions based on local needs and do not need government policy to inhibit their decisions in this way.
Q16: Should starter homes form a significant element of any housing component within mixed use developments and converted unlet commercial units?
All new development should have a broad mix of housing types, but the criteria for development of converted unlet commercial units should be left to the local council who is in a position to take into account complex local factors such as the availability of parking spaces.
Q17. Should rural exception sites be used to deliver starter homes in rural areas? If so, should local planning authorities have the flexibility to require local connection tests?
No. This is just a means to stop local opposition to a planning proposal so I strongly disagree with it. Existing planning policies are adequate to determine whether a proposal should be approved or rejected and all arguments both for and against should be considered on their own merits.
Q18. Are there any other policy approaches to delivering starter homes in rural areas that you would support?
No. Starter homes in rural areas are mostly being providers for outsiders. People in England are very mobile and only rarely seek jobs near where they grew up. No special provision is therefore needed.
The amount people pay for homes is determined by their salaries and by interest rate levels. Buying starter homes has always been a challenge for young people. The present high cost of homes is due to low interest rates that make it easier to pay back a mortgage. The cost of a new home is not in any way determined by the cost of construction. In order to maximise profits, house builders will always adjust their price to adapt it to what people can pay. Up until the end of 2012 the house price index (see Halifax first time buyers monthly index) had been constant, since then the average price has risen steadily from £122,000 to £155,000. There has been no change in interest rates or salary inflation to account for this surge. The only thing that changed was the introduction of the starter homes scheme. Home builders have simply adjusted their prices to absorb the extra level of affordability that the scheme created with the result that people using the scheme are no better off. The situation is much worse for those who are illegible (such as buyers over 40) who now have a 27% higher price to pay.
This is not the only way the starter home scheme defeats its own objectives. By EU rules it has to be equally available to immigrants from other EU states so it also encourages more immigration that adds to the housing shortage. If the scheme is extended to greenfield sites it will reduce pressure on developers to prioritise brownfield sites. The scheme also excuses builders from paying the Community Infrastructure Levi which is so badly needed to provide some of the infrastructure to support new housing. In every way the scheme fails to delivery its objectives. The only sensible course of action is to end the scheme and use the funding to directly help develop brownfield sites instead.
Q19. Should local communities have the opportunity to allocate sites for small scale Starter Home developments in their Green Belt through neighbourhood plans?
People living in rural areas almost always want the area to remain rural. They do not want their green space built on. In other words the premise on which this policy is being based is utterly wrong.
Those who live in rural villages within the green belt understand that they cannot expect to be able to add extensions to their home. It is therefore disingenuous to expect them to accept new developments of housing estates which completely change the character of their area. The wording of these proposals tries to make us believe that these people want new starter homes so that young people can buy homes in the area. This is a distortion of the real situation. Most young people move to towns where they can find jobs. New houses in rural areas are for people who come from outside.
Neighbourhood plans will not help local people to set the policy they want, which would be to prevent any major development in the area. The neighbourhood plans would have to be in line with housing targets and policies set by the larger local planning authority. This means that sites in the green belt would have to be allocated for housing against the wishes of locals and the neighbourhood plan would be no more than a system for putting the blame of the choice on those local committees who formulate it.
The green belt was created with good reasons. Its five purposes in the NPPF are still valid. The majority of the public in England want to preserve its purpose. It is not true that they do not understand what the green belt is for or what it is like. Developers lobby to allow building on the green belt because they make more profit from green belt sites than they do on many brownfield sites. The CPRE has shown that there is enough space on brownfield sites to build 1 million new homes. There is no need to lose any of the green belt in order to provide starter homes for young people.
London and its surrounding counties are a beautiful place to live because of former green belt policy. There could be higher density housing in the heart of London as there is in similar financial cities such as New York and Tokyo. Higher density housing outside Greater London cannot be sustainable and would therefore contradict the NPPF. If the proposed policy changes are made the transport network will not cope and pollution from cars including nitrogen dioxide and particles will damage health. Carbon dioxide emissions will run out of control and we will never meet the emission levels agreed this year in Paris. Areas which previously absorbed rainwater will instead quickly channel water along roadside drains into rivers already prone to flooding. Because of austerity there will be no funding to provide new infrastructure including schools, health services and especially transport networks. The cost of upgrading roads runs into billions and is orders of magnitude outside what community infrastructure levies can support even if such funding was not curtailed by the starter home scheme.
For these reasons policy to support the green belt needs to be strengthened, not weakened as proposed in this policy.
Q20. Should planning policy be amended to allow redevelopment of brownfield sites for starter homes through a more flexible approach to assessing the impact on openness?
While the green belt is well defined by its boundaries, there is no clear definition of a brownfield site. If legislation is to allow development of brownfield sites in the green belt then an unambiguous definition will be needed that clearly does not include sports grounds, solar farms or other similar sites.
Development of sites in the green belt should only be allowed in exceptional circumstances. If the openness of a site has been lost due to previous allowed development then the council can already take that into account. The proposed changes to policy could only lead to less appropriate development being allowed. For example, some brownfield sites in the green belt used for purposes such as prisons and military bases do not have the necessary links to support housing. Others may be subject to flooding constraints. There is no need to change existing policy which allows all factors to be taken into account.
Q21. We would welcome your views on our proposed transitional arrangements.
I am opposed to these changes so the question of transitional arrangements is moot. However I would make the following observation: The government is pressuring local authorities to complete their local plans quickly. This is difficult enough in regions surrounded by green belt where land supply is very difficult and there is pressure to set high housing targets. The ambiguities in the NPPF increase the difficulty, but the worst problem of all is the continuous changes being made such as the ones proposed here. If any changes are to be made they should not take effect until after the current round of local planning is complete.
Q22. What are your views on the assumptions and data sources set out in this document to estimate the impact of the proposed changes? Is there any other evidence which you think we need to consider?
The proposed changes based on the following false assumptions:
(1) That a little bit of green belt can be released for housing
(2) That more houses will lower house prices
(3) That houses are needed because of growing local populations rather than the net influx of immigrants
(4) That infrastructure can be provided to support the needs of more housing in rural areas
(5) That local councillors and residents cannot make the right decisions about their neighbourhood.
In short the entire basis of the policy is wrong. The government needs to do more to ensure that urban brownfield sites are prioritised for development. They need to do more to control the influx of (often illegal) immigrants. They need to implement legislation that fully and unambiguously protects the green belt and other green field sites important to biodiversity. They need to support the wishes of the people of this country even when it conflicts with the profits of construction companies. They need to ensure that development which would be unsustainable due to pollution, flooding dangers, or overburdened infrastructure nver gets a chance to be approved. They need to think in terms of creating jobs in places where houses can be built rather than building impractical commuter hubs around cities. If they to think in terms of increasing the quality of people's lives and GDP per capita instead of just supporting the big corporations that have the resources to lobby. Above all they need to stop the dishonest spin that they use to try to get legislation such as this enacted against the wishes of the people of this country.
Q23. Have you any other views on the implications of our proposed changes to national planning policy on people with protected characteristics as defined in the Equalities Act 2010? What evidence do you have on this matter?