Friday, 5 February 2016

Government consultation on changes to planning policy

The government has launched a consultation on proposed changes to the National Planning Policy which will introduce new rules making it easier for developers to build on green belt especially near rural commuter hubs. This includes anywhere with a train station near London so it will severely affect small towns and villages in South Essex such as West Horndon, Corringham and Shenfield.

Do not be fooled by the talk of commuter hubs, starter homes, neighbourhood plans and brownfield sites in the green belt. The definition of a commuter hub covers everywhere in South Essex. The definition of affordable homes and starter homes will be enlarged so that almost any kind of home can be included under this legislation. The neighbourhood plans will not allow the green belt to be defended. They will just enable the local authorities to blame local residents for the choice of development site, just as the government uses local plans to blame councils for setting high housing targets. Brownfield sites in the green belt could include sites where solar farms and even golf courses have previously existed creating stepping stones to development in the heart of the countryside.

According to the spin only small amounts of the green belt will be affected but building in these areas will seed new developments that will grow to join up towns in just the way that the green belt was intended to prevent. The map produced by the South-East Essex Action Group Alliance shows huge areas of green belt in the area which are now being considered for release to the developers. Already they are being eyed up by construction companies. A raft of new measures being floated in by Osborne on behalf of the treasury will make it much harder for our local councils to defend our green belt against this onslaught.

This goes against everything the Conservatives promised prior to the election when they placed themselves as the party that would defend the green belt. I am not against house building but there are plenty of suitable brownfield sites to build on and those will go unused because the developers always prefer the pristine green field sites where it is cheaper for them to build. The difference adds to their profits, not the price of the houses which is determined by salary levels and interest rates rather than construction costs.

The government says they want to hear what we think and what follows is my response. It is not what they want to hear and they wont want to listen, but they asked for my opinion so I will give it. The vast majority of British people agree that the green belt should be protected. There will be plenty of responses compiled by planning consultancies on behalf of developers. If you want an idea of what they will be saying have a look at this article from the property reporter. Counter arguments will only come from us, the public. If we don't respond now the government will be able to say that the changed policy is what we wanted. Dont give them that privilege.

My answers to the specific consultation questions follow. If you wish to respond too then please do so in your own words. This can be most easily done via the government web portal at You will notice that the questions are loaded towards the responses that they want and steer away from contrary views, but don't let that stop you saying what you really think.

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 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.

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 Tower Hamlets 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.  This 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 polution 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.

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 exisiting 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 large 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 authorties 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.

Other areas such as Uttlesford which have less housing are under very little pressure to build new homes. These are the areas where new settlements can be created along with new jobs and new infrastructure.  New green belt should then be established around the new settlements to prevent over population. This is how new towns such as Basildon were established in the past and it makes much more sense than current policy.

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 borwnfield 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.

However, 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 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 when 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 ther eis 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.

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 developped 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 main 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 favorable 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.

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 authorites have the flexibility to require local connection tests?

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 very 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 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 it's 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 ome 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. It's 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? 

Seeding problem and unsuitable locations

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 relevant observation: The government is pressuring local authorities to complete their local plans quickly. This is difficult enough in regions surrounded by green belt where setting targets 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 affect 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?

immigration, changing policy

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?


No comments:

Post a Comment