Inspector rules that food is a planning matter

Much as I would like to share my comments on the Housing and Planning Bill I am afraid that the ideology of the Government has come up against the rather deeper knowledge in intelligence of the Lords and it is impossible to know what the outcome will be (ie when the Commons vote on the amendments).  

So this blog goes back to the subject of food and rejoices in the fact that the Inspector charged with examining the VALE OF WHITE HORSE DISTRICT COUNCIL LOCAL PLAN PART 1 has issued a number invitations for further comment.

INSPECTOR’S REQUESTS FOR INFORMATION FROM THE COUNCIL

"Has the Local Plan 2031 Part 1 adequately addressed the needs of the food production industry as per paragraph 161 of the NPPF?"

To make this intelligible the relevant extracts from the National Planning Policy Framework are included in this blog: 

"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 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

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;

●the role and function of town centres and the relationship between them, including any trends in the performance of centres;

●the capacity of existing centres to accommodate new town centre development;

●locations of deprivation which may benefit from planned remedial action; and

●the needs of the food production industry and any barriers to investment that planning can resolve."

My comments to the Inspector are as follows:

"1.      This policy cannot have been complied with without also demonstrating compliance with para 160 that refers to LEPs and changes to business needs.  In fact the OxLEP is aware of the need for ‘starter farms’ [1]but this does not seem to have been conveyed to the LPA.  The LPA response to the inspector’s question relies on the CE/SQW Report that does not address changes to the local food systems or the barriers to change that, as implied by this question, a ‘sound ‘ local plan would need to address.  The ‘robust evidence base’ required by para 160 and which should deal with the role that food and agriculture plays in housing, soils, biodiversity, as well as employment and business is entirely missing.

2.      The ‘barriers to investment’ that the draft plan has failed to identify or address let alone ‘resolve’ include the affordable land for new farm enterprises, the associated and affordable housing, and the components of a low carbon food system in terms of production, processing and distribution.  The LPA response is not and could not be that para 161 is irrelevant but, despite have received representations throughout the plan preparation period, changes to local food systems were simply not investigated.  The ‘business as usual’ approach to food systems is not only contrary to the NPPF requirement to consider changing needs, but contribute to locking-in the existing systems and make change much more difficult.  Sound planning is expected and required to avoid  this trap and positively plan for the future.

3.      The consequence of this omission (not only causing the plan to be unsound) will be that the changes necessary to reduce the carbon emissions from agriculture will be made much more difficult if not impossible to achieve. The plan must be able to show how it would contribute to the achievement of sustainable development and mitigate carbon emissions.[2]  Given the significant scale of carbon emissions from agriculture (and subsequent processing and distribution) the 60% reductions to carbon emissions required by 2030 will not be possible if the plan does not deal positively with this issue.

4.      The necessary changes anticipated by paras 160 and 161 are likely to involve an increase in new farms and farmers who without modifications being made to the plan will not find it possible to access suitable and affordable land or associated housing." 

I hope that my blog conveys the idea that the main problem with the planning system is that it puts people off and despite the reduction of reading load represented by the NPPF, few people actually read it and use the good bits in advocating the necessary changes to bring about sustainable development.  In this case the Inspector is asking how the draft local plan meets existing Government policy.

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[1] Creating the environment for growth OxLEP 2-15  p63

[2] ss 39(2) and 19 of the Planning and Compulsory Purchase Act 2004 (as amended)