Saturday, February 11, 2017

The Housing White Paper

 I will not include the full 7 page  response to the Housing White Paper (found through Google) but would encourage readers to  read the proposals and send their ideas to, Planningpolicyconsultation@communities.gsi.gov.uk   asap

To a very large extent the HWP  amounts to further tinkering with the planning system justified on the basis that the recommendations would be so profound and long-lasting that there would be no further meddling required!?   The HWP  is subtitled “Fixing our broken housing market". The Government refuses to understand the extent to which  it is the market in  land which is broken and that it would be by capturing the land value attributable to residential development  that many of the problems of housing supply could be fixed. However, there also needs to be a greater understanding of the planning and housing ' system'.   This means that by finding  and triggering a virtuous circle(s)  more can be achieved  and more predictably than by fiddling with  every little part. It is in this respect that by building almost exclusively two bedroom dwellings the whole housing  stock can  be brought into balance with housing needs (those of smaller households of young and old)  in a way that makes efficient use of land, materials and labour and results in lower costs of owning/renting and  living.

The HWP  seems to be a serious attempt by the Government to avoid its obligations in terms of reduction of carbon emissions.  There is no clear intent to ensure that unsustainable development (i.e. that which does not consume  its own smoke)  does not benefit from the presumption in favour of sustainable development set out at paragraph 14 of the National Planning Policy Framework.  It is most important that responses to the White Paper expect the Government to ensure that housing supply is consistent with the internationally agreed target of 1.5° of global warming. In the context where reductions will be very hard to achieve in industry, power generation, agriculture, transport and the military it is in the housing sector where building must be carbon neutral or negative.

Despite all the evidence to the contrary, the Government   continues to believe that increasing the supply of housing will reduce its price (and  not that it is the inflated price of land which is the main culprit).    The work by Oxford Economics  behind the Redfern Review  provides the latest explanation of how adding just 1% ( in practice much less) to a  stock of over 20 million houses will not influence the price.  The importance of this  relatively small increase to the housing stock is that  this scarce resource must be used with extreme care.  In order to  meet the  genuine needs for  housing the elderly  (and others in need of care) every new dwelling will be required to follow the models described in the HAPPI 3 family -  which include cohousing.  

The Government is playing with the idea of a national industrial strategy. In this context it could be suggested that  this could and should be complemented by a national spatial plan to  demonstrate how to make better use of the land and infrastructure than piling more pressures on the south-east. 

There are many other issues raised by the White Paper for readers to get their teeth into including the future of green belts and new categories of (un) affordable housing. The suggestion that larger sites be subdivided to  make the delivery of dwellings more certain could be supported especially as  local planning authorities are required to provide serviced sites for self/custom-builders.

Wednesday, February 1, 2017

Sadomasochism and land use planning


The more I reflect on the pain inflicted by the planning system on those seeking to promote genuine sustainable development (not the kind currently being espoused and supported by the central and local government) the more perverse the situation seems to be.    It would be reasonable to expect the land use planning system to be doing all it can to deal with the problems associated with industrial agriculture, the loss of bio-diversity, growing levels of homelessness, climate change, the crisis in social care and life threatening levels of air pollution.  If the system finds that it cannot create a vision for a more sustainable future and have this reflected in its development plans and decisions then it seems to be particularly perverse for it to intimidate, frustrate and mentally torture those courageous individuals and groups who have a vision and the energy to make progress in the areas of local/regional food systems (embracing permaculture or agro-ecology), genuine reduction in car use, and co-housing.   Which brought me to search the meaning of Sadomasochism in Wikipedia as, “the giving or receiving pleasure from acts involving the receipt or infliction of pain or humiliation”.  Whilst there may be few if any individual planners who derive pleasure from the acts and omissions which are responsible for holding back progress towards a sustainable society, environment and economy, there is evidence of some satisfaction (ie sadism) or complacency in the operation of the planning system which makes creative people (ie masochists) suffer in their often futile attempts to have their visions accepted and their plans approved.

A different but possibly more justified and inevitable form of sadism is requiring those outsiders (masochists) wanting to engage with the planning system to understand the difference between policy and law and to make intelligible the legislation and associated policies that are most helpful to their case.  As an example, for those with a particular interest in permaculture, Local Development Orders might be one of the most promising parts of the comprehensive statutory code within which the planning system operates.  This is the power as set out in the Town and Country Planning Act 1990,
‘60 Permission granted by development order.
(1)Planning permission granted by a development order may be granted either unconditionally or subject to such conditions or limitations as may be specified in the order.
(2)Without prejudice to the generality of subsection (1), where planning permission is granted by a development order for the erection, extension or alteration of any buildings, the order may require the approval of the local planning authority to be obtained with respect to the design or external appearance of the buildings.
(3)Without prejudice to the generality of subsection (1), where planning permission is granted by a development order for development of a specified class, the order may enable the Secretary of State or the local planning authority to direct that the permission shall not apply either—
(a)in relation to development in a particular area, or
(b)in relation to any particular development.”

But to many of those wanting to change the world, reading and seeking an understanding (including how this section is regarded by their local council) is tantamount to torture.  I should add that LDOs would probably only be really, as opposed to potentially, helpful were there to be a legal distinction between permaculture and industrial agriculture. 

Again reference to the law is interesting as there is a 1947 definition of ‘agriculture’ in the Act at  s.336, Interpretation,

“agriculture” includes horticulture, fruit growing, seed growing, dairy farming, the breeding and keeping of livestock (including any creature kept for the production of food, wool, skins or fur, or for the purpose of its use in the farming of land), the use of land as grazing land, meadow land, osier land, market gardens and nursery grounds, and the use of land for woodlands where that use is ancillary to the farming of land for other agricultural purposes, and “agricultural” shall be construed accordingly;”

Readers could consider what distinctions could be included in definitions of land uses that would fit the purposes of a world post 2017 and which could be implemented through Local Development Orders?



Friday, January 20, 2017

Planning and 'post truth'

I know that the abuse of language featured in a previous Blog but the 'inauguration' of one of the greatest exponents of lying prompts a further mention of the notable achievements of the planning system in this area.  In fact planning could lay claim to have pioneered this use of language in a civic sphere.

Town and Country Planning - The foundation of the present system is the 1947 Act bearing this title but, in fact there is no effective controls over forestry and farming that are the dominant uses in the 'country'.  But neither has there been any 'planning' (in the sense of aiming to achieve a vision of an overall public good) only a system reacting to economic and political demands.

Planning by appeal - a description used when there is heavy reliance on decisions taken by or on behalf of the Secretary of State when deciding appeals against the refusal of permission by LPAs.  This should be 'permission by appeal' as no planning is involved (see Town and Country Planning above).

Sustainable development - this is described in the National Planning Policy Framework as the  'golden thread' running through both plan-making and decision-taking.  A less appropriate analogy would be hard to imagine as this 'thread' is continually broken and mangled. And gold reputedly does not tarnish. The 'purpose of planning' is introduced in the NPPF as achieving sustainable development which is then said to be that which does not disadvantage future generations.  The role of planning has now been made subordinate to building regulations in the (joint) failure to ensure that new development 'consumes its own smoke' so that future generations do not have to.

Affordable housing - established by the Court of Appeal as a material consideration on the basis that the planning system could (and should?) legitimately differentiate between a dwelling that could be afforded by a person on average local earnings (subsequently agreed to be about 33% of earnings to be spent on accommodation) and one that would not.  Currently described in the NPPF as 80% of a market rent which in some parts of the country could be more than 50% of average earnings and only then made 'affordable' through Government assistance (ie £29 billion of Housing Benefit).

Community - This term keeps cropping up to justify all sorts of developments which serve to reinforce privacy (and loneliness - As Philip Slater said, “The longing for privacy  is generated by the drastic conditions that a longing for privacy produces.”    The pursuit of loneliness  1968).

Reduce - a term that crops up in planning policies which has become synonymous with 'mitigation' which actually  means 'increase', but not quite as much as might have occurred without some interference.  Cannot be relied upon when substantial and measurable 'reduction' ie carbon emissions from buildings and traffic, is actually necessary.

Garden Cities/Towns/Villages - Welwyn Garden City was completed in 1930 but neither this nor the new settlements  subsequently built as new towns included the market gardening zones included in the original concept of Ebenezer Howard.  When para 50 of the NPPF refers to 'Garden City principles' it means a branding to make large scale new housing sound more acceptable and nothing about the inter-relationship between the new settlement and the surrounding countryside.

Objectively Assessed Need - The 'need' assessments being relied upon are to be found in Strategic Housing Market Assessments or SHMAs (despite Ministerial statement that these contribute to the assessments and are not determinative - another post-truth?).  SHMAs confuse 'demand' with 'need', recommending larger houses to be built in the private sector than for social rent.  SHMAs also fail to acknowledge the declining levels of household size and unsustainable level of under-occupancy by emphasising the real and objective need to provide attractive downsizing options for all sectors.

I had previously suggested that the Courts might be interested in the corruption of language in this way and could provide a corrective to the above terms, in particular 'sustainable development' and 'affordability'.



  

Community Infrastructure Levy: food and carbon

I have been remiss in my failure to address the potential for using the Community Infrastructure Levy  (CIL) to help the planning system help those engaged in sustainable development.

Charging schedules should include the following two items fundamental to sustainable development of the District.

1.  Regional food systems are and will become increasingly important to the sustainability and resilience of local areas.  These should be recognised as essential elements of sustainable development - the golden thread running through plan-making and decision-taking.  CIL should be used to overcome the 'barriers' in accordance with paragraph 161 of the NPPF.  The infrastructure needs that should be financed through CIL are a supply of affordable residential smallholdings and local food processing facilities.

2.  Although the NPPF is introduced on the basis that the purpose of planning is to achieve sustainable development which is said to be development that would not disadvantage future generations, none of development taking place and planned to take place in the District meets the simple test of sustainability; that it 'consumes its own smoke'.   In these circumstances CIL should be used to sequester or off-set these emissions.  Infrastructure projects should be identified and developed through these developer contributions to neutralise the emissions from both new building and the emissions from the new traffic and the consequent increase in congestion.  Funding should be provided to existing organisations working to reduced carbon emissions within the District.

Friday, January 6, 2017

Oxford Real Farming Conference 2017


This post is written as in immediate response to the 2017 Oxford Real Farming Conference without repeating previous posts relating to previous ORFCs which can be found on this Blog.

The context is a meeting of about 850 of the most intelligent, thoughtful, likeable, sociable, concerned, able, etc etc people – with a very even gender split and an average age below 50.  This year was described as taking place in a “crisis” leading to a belief that there might be opportunities to be found in the process of ‘creative destruction’.

The interventions made by DanthePlan are shared here.  Firstly, repeating the message that the land use planning system must be seen to have significant potential for positive change; dependent on the delegates individually and collectively engaging in all the ways which are available in plan-making and decision-taking to educate public authorities of the ways in which agro-ecology should be supported and privileged in the public interest.  Under the heading ‘planning authorities’ should be included the Treasury, DCLG, Defra and BEIS.  The hierarchical nature of the system has the advantage that any Government Minister (Health is also involved) can change Government policy with almost immediate effect.

The ways in which the food supply system is already being addressed is set out in the National Planning Policy Framework were described in the post of 9 December 2016.  The law relating to planning applications (ss 70 and 38(6)) relies on the concept of “material considerations” of which there are a formidable number implied by the concept of ‘agro-ecology’ and already being taken into account by planners..

Carbon emission – possibly the most important if the sequestration of carbon in ecologically farmed soils is the best way of reducing concentrations from 400ppm to 350ppm.
Climate change adaptation – agro-ecology implies a diversity of farming/growing systems relying on relatively high levels of manual labour which in turn implies greater resilience than the industrialised  farming systems dependent on fossil fuels for growing large acres of monocultures.
Bio-diversity – smaller scale organic farming would be more conducive to diversity of flora and fauna.
Soil health – already implied by the weight being given to the protection (or not) of Best and Most Versatile Land (BMV).
Transport – Local or regional food systems should reduce ‘food miles’ arising from production, processing and distribution.
Employment – there are examples of livelihoods being made from  very small acreages indicating the potential for local jobs from small scale farming/growing.
Physical and mental health – This is where town and country planning started (eg Garden Cities) and there are moves in and close to Government to raise the profile of health benefits from food growing.  A Natural Health Service would imply a significant increase in opportunities for local growing. Care farming is also gaining recognition.
Housing – Land worker housing is by definition meeting the need for local and affordable housing.
Viability – applied to test the economic sustainability of new rural enterprises in the countryside and to the affordability of contributions being made through planning agreements/obligations under s106.  Given the dependency of most existing farms on subsidies this measure should be applied with very great care.
Food distribution – as well as the transport impacts, the issue of the ready availability of relatively unhealthy foods (ie fast food outlets near schools) is working its way into planning policy and decisions.
Flooding – concentrating on the absorbency of soils through pasture, swales, tree/bush planting, and mulching, agro-ecology and forest farming could have an important role to play in reducing flooding.
Landscape impacts – By increasing planting of trees and hedges the landscape od small scale farming will be materially different to that of industrial agriculture.
Rural Building – Ideally, the centre (housing and buildings) of most agro-ecological enterprises would take place close to existing settlements which would minimize the visual impact of what would be smaller buildings than those of large scale farms.
Recreation – opportunities for play and recreation are already given significant  weight on plan-making and decision –taking.  The role being played by community farms/woodland and orchards is already being recognized.
Localism – high up on the Government’s agenda and reflected in the neighbourhood planning taking place under the 2011 Localism Act.  Small scale farming is mostly relying on local labour, local housing and local markets.
Community development – similar and complementary to localism. Community farms (inc community supported agriculture – CSAs) could actually demonstrate real elements of community involvement beyond the prevalent rhetoric.
Waste reduction – waste recycling is intrinsic to agro-ecology from the growing, processing, distribution (and even the consumption) of animal and vegetable produce.
Heritage landscapes – small scale growing can be more sensitive to the protection of ancient hedges, trees and archaeological remains than industrial scale operations with heavy plant and machinery and windblown chemicals.
Access to land – the opportunity to start or develop an agricultural enterprise will often depend on the affordability of both the land and housing.  If the public benefits of agro-ecology have been established, then planners should assist with the availability of affordable housing and land through development plans and in deciding applications (see use of s106 in previous posts).
Sustainable development – lastly but probably the most important.  The presumption in favour of sustainable development (implying a presumption against unsustainable development) is the golden thread running through plan-making and decision-taking. 

These are 20 matters that must be taken into account and given appropriate weight (ie in what ways would the public interest be advantaged or damaged?) if brought to the attention of decision-makers when considering the merits of applications for agro-ecological developments.   More importantly, if these are significant public benefits (what other ways are there to reduce carbon concentrations?) then agro-ecology should encouraged at ministerial level and  promoted through local plans and neighbourhood plans. Given the significance of the differences between different farming regimes (carbon again) the Government should look at changing the law to require permission to be required to change farming operations.

The extent to which these benefits are being recognized is work being carried out by Luke Owen at Coventry University http://www.coventry.ac.uk/research/areas-of-research/agroecology-water-resilience/ and at the Elm Farm Research Centre.


Monday, December 12, 2016

Greenprint for survival



The Blueprint for Survival was written by a number of people associated with The Ecologist. Although the problem of greenhouse gases had not emerged in 1972, all the other existential problems have got steadily worse. 

I would highly recommend reference to the blogger who writes under ‘Greenprint for Survival’ and having said that, I would like to add my own take on this concept following on from a thought provoking conference held by Sustain into ‘common good land uses’.  It seems that there is a stark choice between pursuing these minority pursuits as exceptions to the norm which can be demonstrated to be beneficial to some and not harmful to the majority (ie not against the public interest). Or, in order to be accepted (eg to get planning permission) it should be explained how these uses of land and buildings are an important and indispensible part of how the mainstream should be looking in the creation of a sustainable and resilient society (ie in the public interest).

Whilst I believe that diversity should be celebrated and that the planning system should find space for individuality, imagination, innovation and the ‘quirky’ (the inspector’s view in supporting a shark sculpture in a suburban roof) I think that it is important that common good land uses should mainly be presented and explained as being in the common and public good.

This is a big ask that I think is predicated on a fair description of the really big issues that will be faced in 2017 and for the foreseeable future. 

The public issues in the most critical position appear to be:
-       loss of biodiversity and soils,
-       insecure supplies of trustworthy food,
-       a transport system that cannot cope with increase in motorized mobility,
-       to set a trajectory to peak GHGs by 2020 and zero by 2050,
-       to finance and run acceptable health and social care services
-       inequitable supply and distribution of housing,


On the last two points I would like to quote Angela Brady past president of the Royal Institute of British Architects, "Were running out of time
for this tidal wave that's coming towards us. I'd like to see London
Mayor Sadiq Khan say that 10% of new development is given over to
co-housing. We need exemplars for others to follow.)  That is 10% of
say 30,000 per year? which equals 3000 units or 100 schemes.  That's a few
more then are being planned today?

On the questions relating to nature/food and carbon I would propose that the preparations of bio-regional plans become the norm.  All development plan are drawn up subject to extensive public consultations.  Unfortunately, the test of soundness is mostly limited to what is in the plan (eg is there a 5 year housing land supply) and not what is missing. However, if NGOs or local residents can show what dire consequences would arise from the plan as submitted, this would be an opening for pro-activity and the presentation of a different or additional plan which deals primarily with natural capital at a regional scale.  Data could include, inventories of flora and fauna, wildlife corridors, river catchments, soil types and quality, farming regimes (arable or pasture), designated nature reserves, forests and woodlands.  The mapping (with OS help?) could show areas of decline and areas designated for improvement.  There could also be a carbon account which identifies the potential for carbon sequestration in plants and soils.  Such a plan would be  a huge undertaking and would always be ‘work in progress’. However, it would be providing information that should be used and relied on by decision-makers when considering the use of all undeveloped land.  There could also be signals for use in urban areas, including the recreation and health care needs of the urban  population.

It would be this kind of framework or Greenprint that common good land uses could be most easily seen to be in the common good and public interest.

The crisis not mentioned but real nonetheless is in the type of 'democracy' we will be experiencing while these important decisions are waiting to be made.

Friday, December 9, 2016

Making comments on local and neighbourhood plans


Apologies for the blog length but this might be useful for those prepared to engage with the planning system

A guide for making representations on development plans:unitary plans, local plans and neighbourhood plans

Food and Planning
I am afraid that the length of this paper breaches all rules for Blogs but I feel that there is an important message that the NPPF might actually be fit for many purposes and what really matters is the lead being given by the person sitting in the position of the Secretary of State for Communities and Local Government.  The position is now held by Sajid Javid- formerly a Business Secretary.  The level of ignorance of planning in Government does not give much hope for the future unless those with an interest in these matters make concerted efforts to engage with the planning system at local and national levels. 

Although there has been a consultation on revising the NPPF no details have been published.

1.Could the existing framework of law and policy legitimately support local food systems? And, If not, what changes would be reasonably necessary?

  1. Since the 1947 Act, whatever public interest depends on the use and development of land and buildings can be delivered by the planning system.
  1. Example: There was no difference recognised by the planning system between a dwelling that was affordable to local people and one that was not until a High Court judge found that a refusal of planning permission by a local authority based on that contention was within the powers of the 1947 Act.   It would seem to follow that If it can be shown to be in the public interest to facilitate access to affordable land and associated housing to support the growth of local food systems ie production, processing and distribution, the planning system could and should deliver.
2.National Planning Policy Framework
The following extracts show that the NPPF is not hostile to and in many ways could be reasonably interpreted to support the development of local food systems.

Achieving sustainable development
The NPPF cites the UN definition about not disadvantaging future generations that has been interpreted by an appeal inspector (www.planningportal.gov.uk/planninginspectorate  Appeal Decision APP/N2345/A/12/2169598) as ‘consuming its own smoke’. A helpful judgement has found that, “the presumption cannot apply to un-sustainable development and that somewhere in the process must be an assessment of sustainability ..." Dartford BC v SSCLG [2014] EWHC 2636 (Admin.).


“Core Planning Principles   - 17…proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business communities;”

Whilst this might not have been drafted with small-scale agricultural enterprises in mind, if these are needed then the planning system should be delivering both suitable and affordable land and housing

“- take account of the different roles and character of different areas,
promoting the vitality of our main urban areas, protecting the Green Belts
around them, recognising the intrinsic character and beauty of the
countryside and supporting thriving rural communities within it;”

It would be reasonable to regard a thriving agricultural industry to be fundamental to thriving rural communities

“- take account of and support local strategies to improve health, social and cultural wellbeing for all, and deliver sufficient community and cultural facilities and services to meet local needs.”

Local food would appear to be suited to meet all these local needs.

Supporting a prosperous rural economy
“28. Planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable new development. To promote a strong rural economy, local and neighbourhood plans should:
● support the sustainable growth and expansion of all types of business and enterprise in rural areas, both through conversion of existing buildings and well designed new buildings;
● promote the development and diversification of agricultural and other land-based rural businesses;
● support sustainable rural tourism and leisure developments that benefit
businesses in rural areas, communities and visitors, and which respect the character of the countryside. This should include supporting the provision and expansion of tourist and visitor facilities in appropriate locations where identified needs are not met by existing facilities in rural service centres; and
● promote the retention and development of local services and community
facilities in villages, such as local shops, meeting places, ...”

No stretch of the imagination is required to read this advice as official/Government encouragement to the growing, processing and distribution of local food.

 Housing
“52. The supply of new homes can sometimes be best achieved through planning for larger scale development, such as new settlements or extensions to existing villages and towns that follow the principles of Garden Cities. (see later comment).

Working with the support of their communities, local planning authorities should consider whether such opportunities provide the best way of achieving sustainable development. In doing so, they should consider whether it is appropriate to establish Green Belt around or adjoining any such new development.”

There is a lively debate about the future of the Green Belt and small scale agriculture aimed at serving the enclosed urban area offers an attractive alternative to both camps; those who would like to see the GB kept free from development and those who would like to see it put to productive use –ie horticulture could be preferred to horsiculture that has become the predominant use, even if this implies a limited level of associated residential development.

Climate Change
“93 Planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions, minimising vulnerability and providing resilience to the impacts of climate change…”

There is a debate about the scale of greenhouse gases that can be attributed to agriculture (UNCTAD estimate of about 50% of global emissions down to about 13% estimate of the Committee on Climate Change from UK agriculture).  It is important to collect the evidence to show that local agricultural systems can contribute to the reduction in GHG emissions.

“95. To support the move to a low carbon future, local planning authorities
should:
● plan for new development in locations and ways which reduce greenhouse gas emissions;”

Opportunities for local food growing should be planned for all localities.

Conserving and enhancing the natural environment
“109 minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;”

The case can be made that (by definition) agro-ecology enriches bio-diversity both above and, importantly, below ground.  The NPPF could be seen to miss the connection between food growing and ‘natural environment’ which is currently seen simply about bio-diversity, geo-diversity and landscape.

Land quality
“112. Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land BMV). Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality.”

This is the vestige of the concern that had been expressed about preserving the food growing capacity of the UK.  Sometimes the protection of BMV is decisive in planning decisions and sometimes not. Generally the smaller the holding the greater reliance on land quality and, If the need for small scale agriculture can be demonstrated, then so would be the need for the planning system to protect and use the best land for this purpose.

Using proportionate evidence in plan-making in terms of ‘business’
“160. Local planning authorities should have a clear understanding of business needs within the economic markets operating in and across their area. To achieve this, they should:
● work together with county and neighbouring authorities and with Local
Enterprise Partnerships (LEPs) to prepare and maintain a robust evidence base to understand both existing business needs and likely changes in the market; and
● work closely with the business community to understand their changing
needs and identify and address barriers to investment, including a lack of
housing, infrastructure or viability.”

Notwithstanding the important benefits derived from urban food growing up to and including 10 pole allotments, the scale of change that may be required is very much at a business level and scale where LEPs should be interested.  However, planning authorities are likely to need help in assembling the evidence to support the radical policies which will be required to facilitate the shift to ‘real farming’.

“161. Local planning authorities should use this evidence base to assess:
● the needs for land or floorspace for economic development, including
both the quantitative and qualitative needs for all foreseeable types of
economic activity over the plan period, including for retail and leisure
development;
● the existing and future supply of land available for economic development and its sufficiency and suitability to meet the identified needs. Reviews of land available for economic development should be undertaken at the same time as, or combined with, Strategic Housing Land Availability Assessments and should include a reappraisal of the suitability of previously allocated land;”

Whilst this might have been intended to apply to the change of employment land to residential, it could equally apply to identifying the most suitable land for ‘real farming’ which could then be a constraint in the identification of land suitable for housing (ie the SHLAA).

● the needs of the food production industry and any barriers to investment that planning can resolve.(my emphasis)

3.Planning Practice Guidance
Support can be found in the NPPG at:
“Health and Wellbeing para 2  •opportunities for healthy lifestyles have been considered (e.g. planning for an environment that supports people of all ages in making healthy choices, helps to promote active travel and physical activity, and promotes access to healthier food, high quality open spaces and opportunities for play, sport and recreation);” and,
“Para 5 •Active healthy lifestyles that are made easy through the pattern of development, good urban design, good access to local services and facilities; green open space and safe places for active play and food growing, and is accessible by walking and cycling and public transport.”
This guidance can be cited in support of the above policy advice in the NPPF.
The only guidance on “agriculture” relates to the unhelpful relaxation to regulations allowing “changes of use of agricultural buildings (eg schools and dwellings)”

4.Local Plans
Back to the NPPF that says, “99. Local Plans should take account of climate change over the longer term, including factors such as flood risk, coastal change, water supply and changes to biodiversity and landscape. New development should be planned to avoid increased vulnerability to the range of impacts arising from climate change. When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure.”


“150. Local Plans are the key to delivering sustainable development that reflects the vision and aspirations of local communities.
151. Local Plans must be prepared with the objective of contributing to the
achievement of sustainable development. To this end, they should be
consistent with the principles and policies set out in this Framework,
including the presumption in favour of sustainable development.
152. Local planning authorities should seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development, and net gains across all three.”

There should be no need or excuse for trade-offs between the three limbs of sustainable development and agro-ecology epitomises how multiple  social, economic and environmental gains can be achieved.

      5.Neighbourhood   Development Plans
There is no reason why advice on local plans should not also apply to NDPs – and vice versa.

In my not very special village the NDP survey showed 200 out of 2000 adults (on 64% return) desired to be involved in smallholding ie more than an allotment.  The NDP followed advice from the district council not to translate this ‘public interest’ into development plan policy.   This is an example of a failure of localism and a demonstration of how much both planning authorities and neighbourhood forums/parish councils have to learn

6.Green Belts
Although agriculture and forestry are ‘appropriate uses’ it is not a main purpose of Green Pelt policy to actively support these uses. Models of village farms or market gardens encouraged by the planning system (ie providing affordable housing) could be an alternative to new inappropriate development. Such dwellings should be regarded as appropriate as being  ‘buildings for agriculture and forestry’.(NPPF amendment required).  Similarly the policies in National Parks and AONBs should acknowledge the contribution that could be made by ‘agro-ecology.  The regulations applying to National Parks include the advancement of social and economic objectives.

7.Garden Cities   
Whilst new garden cities might not be at a scale that will solve the housing or agricultural crises, they do seem to have cross party support and the door should be pushed open, especially because of the advice at para 52 of the NPPF.  There is a real opportunity for the campaign for real farming to capitalize on the inclusion of ‘market garden’ zones in Ebenezer Howard’s idealised diagram (the ‘homes for inebriates’ might be suitable for plannerd drowning their sorrows?).  Agro-ecology and community supported agriculture would also fit into Howard’s three magnets by providing, “Fields and farms of easy access, enterprise and low prices… [and]…Plenty to do. “

8.Infrastructure
Sustain (please Google and support) describe local food systems as ‘infrastructure’. Just as real farming should be regarded as an integral part of the agricultural industry and rural economy (Colin Tudge confirmed that the Real Farming conference now attracts more delegates than the Oxford Farming Conference) planners might find it easier to adjust to something falling within a familiar category.  If Community Infrastructure Levy (CIL) could be invested in local food systems this could be a game changer (but change to regulations and local CIL schedules required).

9.Proposals

The town and country planning system engaged in controlling the use and development of land and buildings in the public interest should be empowered to control the changes in agricultural practices where there can be seen to be significantly different impacts being caused in matters already seen to be material planning considerations:
-       Landscape impacts.
-       Bio-diversity
-       Soil health
-       Flooding
-       Employment
-       Transport
-       Sustainability (where not covered by any of the above)
-       Affordable and appropriately located housing for agricultural workers
-       Health and wellbeing of individuals and communities
-       Carbon emissions from food systems (eg transport and fertilisers)
-       Recreation (community supported agriculture)
-       Health and wellbeing

1.        NPPF – Support for ‘food production’ should be expanded beyond the business section of plan-making; given a chapter of its own, or added to landscape, green belt, bio-diversity and health and well-being sections.  However, this does not mean that the NPPF in its existing form is not already fit for the purpose of supporting the growth of real farming in both plan-making and decision-taking.  The definition of ‘affordable housing’ in the Glossary should include those dwellings approved with an ‘agricultural occupancy condition’, removing this as an obstacle for developers concerned about viability. The NPPF should also identify ‘affordable land’ as land made available for farming/growing through planning obligations/s106 only to be sold at values relating to its commercial potential in agro-ecological use.

2.         Local Plans  & Sustainability Appraisals – should have policies supporting agro-ecology in particular requiring the provision of affordable housing (with ag tags) and ‘affordable land’ (secured through s106 planning obligations). These should be reserved out of all new developments on the fringe of towns and villages.  Policies should indicate that the urban fringe is the appropriate location for such developments and could zone land where preference would be given to such uses.

3.         NDPs – market gardening zones and village farm allocations should be made if not already provided for in local plans under NPPF 160/161. There should be a campaign for legislative change to enable Community Right to Grow Orders as counterparts to Community Right to Build Orders.

4.         Green Belts (and Nat Parks/AONBs) – promote agriculture including horticulture – including provision of affordable housing associated with ‘affordable land’.

5.         Garden Cities (and large scale housing developments along the garden city model, should all include market garden zones and require engage with local examples of community supported agriculture.

6.         Community Infrastructure Levy  schedules should include elements of local food systems; eg food hubs for storage, distribution and processing.

7.         Regional food systems should be the focus of attention that would imply a ‘duty to cooperate’ between urban and rural planning authorities (as applied to housing land supply).  It would also be helpful to emphasise that the ‘real farming’ must be encouraged to make contributions to the economy at an industrial scale.

8.         Decisions must by law all refer to the ‘presumption in favour of sustainable development’.  There is sufficient other policy advice and guidance in the NPPF and NPPG to support proposals for agro-ecological developments.  There is a need for those with knowledge and experience of agro-ecology and real and/enlightened farming to support/propose policies at national and local level as well as backing individual decisions.  Given the discretion available to decision-makers; officers, committees, inspectors and the Sec of State (within the bounds of reasonableness), it is important to bring the considerations material to the promotion of agro-ecology to the fore.

Specific comments

Local Plan should recognize that the food supply chain is a major source of carbon emissions and have clear policies to support and enable low carbon local food supply (and remove barriers in accordance with NPPF para 161).  A fundamental ‘barrier’  that must be addressed by a sound plan is the cost/affordability of both land and associated housing for aspiring farmers/growers.

One readily available policy to enhance local food supply is to require one or two dwellings in all developments on the periphery of towns and villages to be made subject to agricultural occupancy conditions (accepted as part of the affordable housing quota) and the developer (landowner) would be required to include at least 1 ha of land as a smallholding  as well as land for allotments for the new housing.  The preference would be for this to be adjacent, but in any event it must be reasonably accessible, to the new housing. This would be the reasonable to response to the proposals for new agricultural dwellings in the open countryside which should supported if the Plan does not seek to meet the need in a more sustainable way.

For the very adventurous (possibly those persevering to the end of this blog) A much more pro-active approach could be taken by preparing and presenting a bio-regional plan to the planning authority covering all those matters in para 9 above.  This will be described in my next blog. 

Best of luck