Planning
(as in town and country planning) for a revolution in local agriculture
Notes
from a presentation to the Real Farming Conference
held
in Oxford on 6 and 7 January 3014
This is an argument that we should be working
collectively to make the planning system deliver what we (at the RFC) know to
be important changes to farming that are dependent on the use and development
of land – ie the job of the planning system.
The revolution does not depend on any change to the
law but changes to policy and practice. There was a change in 2011 with the
passing of the Localism Act that extended plan-making powers to parish councils
and neighbourhood forums. This means
that there are more organisations that might be receptive to new ideas and the
hundreds of very local councils with no ‘baggage’ might be more receptive than
the long established planning authorities.
The revolution should encompass the production, processing and
distribution of local food. The key to
the argument to plan makers and decision takers is the contribution that ‘local
food’ makes to sustainable development, the “golden thread" that,
according to the National Planning Policy Framework, must run through both plan
making and decision taking. The fact that the food supply chain is responsible
for between 30% and 50% of carbon emissions that must be reduced by 80% by 2050
should interest policy makers.
It is important to understand that the planning system
has inbuilt flexibility in that material considerations, those matters that
could and should be taken into account in deciding planning applications, is
not a closed list. Any matter that relates to the use of land (including
buildings) and is of public interest can (must) be taken into account. Until
the 1990s there was no such thing as “affordable housing" recognised by
the planning system. After a High Court judge supported a local planning
authority in the making of a distinction between a dwelling that could be
afforded by local people and general market housing that could not, the affordability
of housing was recognised as a material consideration and became a main theme
in policies adopted at national and local level. There would appear to be a
parallel for securing affordable land and associated residential accommodation
for agriculture or horticulture. In a plan led system, if a public interest
case can be made out, it would be logical for these objectives to be pursued
through development plans produced at parish, neighbourhood or district level.
This would represent a more ordered and effective harnessing of the power of
the planning system than through relying on decisions on test cases, having
applications refused and considered by the High Court.
Whilst there is no legal reason why planning
authorities should not start to be proactive in respect of issues relating to
food from ‘plough to plate’ (the neglected country part of town and country
planning), planners lack the necessary knowledge and expertise in this area and
will be very slow to change without receiving substantial assistance in their
understanding of the related needs in terms of access to land, housing,
buildings the impacts on local transport and the potential to create jobs. I am looking to the CRF, the Soil Assoc, the
Permaculutre Assoc, the Landworkers Alliance and the ELC to do the educating of
Government, local government and the planning and surveying professionals.
The potential for incorporating issues relating to
food applies to both existing planning authorities and parish councils or
neighbourhood forums embarking on the preparation of neighbourhood development
plans. However, it would be much more effective if the required policy
framework was set out in higher-level plans that cover large rural areas,
including those where there is no appetite or capacity for producing
neighbourhood plans. Innovating at the level of a planning authority has the
very great advantage that it not only produces plans but also makes decisions
on planning applications. It is easier to introduce new policy when a local
plan or core strategy is under review.
But it is also possible to adopt Supplementary Planning Documents
covering particular issues, so long as the policies are not inconsistent with
the adopted development plans. (I will
be attending to the drafting of policies suitable for development plans or SPD
on the DanthePlan blog where the issues are already being discussed.
It may be that change is more likely to be
instigated by one or more parish councils out of concern about the way in
which the land around their village is being used and how to realise its
potential to enhance local food production.
It is an important part of the localism agenda that, as neighbourhood
development plans must comply with policies at higher levels (district,
national and European), those responsible for planning at high levels can learn
from the results emerging from neighbourhood planning in their respective districts. In fact the planning system is a quite good
at disseminating information through formal (ie appeal decisions, professional
institutes) and more informal (conferences and trade magazines/journals) channels.
Given that ‘local food’ epitomises much of what is
said in the National Planning Policy Framework about sustainability, compliance
with the Framework (that is a basic
condition to be met by all neighbourhood plans) should not be a problem. This
path would be made easier by relying on some of the growing evidence relating
to the importance of local food. Perhaps the most important discussion to be
had is how proposals that support the production, processing and distribution
of food benefit from the “presumption in favour of sustainable development”.
The question was asked about what could or should be
the main thread that could bring together the many strands of the Conference. I think that the concept with the greatest
potential is “carbon”. With the food
supply chain responsible for between 30% and 50% carbon emissions it is
difficult to see how any development plan that is statutorily required to deal
with the use and development of land could possibly be contribution go the
achievement of sustainable development without a chapter on food and farming
and policies consistent with the (at least) the carbon emission reduction
target of 80% by 2050 and the interim Carbon Budgets.
Support for these new rural enterprises should also be
the subject of employment policies in the local plan or neighbourhood plan with
associated local job (and training) opportunities and the possibility of jobs in local food
processing and distribution. Enhancing
and maintaining biodiversity and reducing travel and transport are other
important elements to be explained in order to qualify for the
presumption in favour of sustainable development.
Planning for the revolution in local food is probably
predicated on the fact that new residential development in villages is likely
to be the most effective driver of change. The purpose of all planning policy
should be to increase the sustainability of the village (or town) and the new
local food policies would aim to increase the availability of local food
supplies (the most common reason given by people surveyed by the Soil
Association in respect of Community Supported Agriculture), allow more people to live and work locally,
reduce transport and, in the case of CSA, increase community involvement.
The prospect for planning for a revolution in local
food based on new policy frameworks will not mean that applications will not
continue for setting up new agricultural/horticultural enterprises; ie the
buildings and dwellings. However, for the
scale of change to become a meaningful (particularly on the fringes of towns
and villages) it is fair to assume that the necessary land and housing will
have to be leveraged and enabled by the profits from new housing. Section 106
has been one of the most contentious parts of the planning system, many leading
court cases the result of litigation led by Tesco. Fitting ‘local food’ into planning
obligations might not be easy but planning develops by trial and error. S106 of the Town and Country Planning Act can
be seen as the mechanism for securing community benefits (not normally or
willingly proposed by developers). As
well as the commonplace enhancements to village halls, playgrounds and
allotments (which can, by law, be up to 2 acres), there is no reason why
smallholdings should not be included in this list. However, it will be very
difficult to secure these benefits unless these are listed and
explained/justified in the development plans (local and/or neighbourhood plan),
to which the profits from new residential development should be required to
contribute in order to make both the new housing itself and the village location
more sustainable. It will also be
important to explain why such benefits relate to the development (e.g.
compensation for the taking of greenfield/agricultural land for housing
development and in terms of higher productivity of smallholdings compared with
agriculture or horsiculture) as well as increasing the sustainability of the
location for new housing/population).
Just as the affordability of housing has become a
mainstream part of planning decisions and policy, there appears to be a
relevant precedent for requiring
contributions towards the provision of land for smallholdings. In Surrey a
number of councils collect s106 contributions to green infrastructure (Suitable
Alternative Natural GreenSpace –SANG) to meet the increased recreational needs
associated with new housing developments. The contributions are set between
£2500 and £3000 per dwelling. Once the
‘need’ for local food is established, financial contributions, £1000 per house
could purchase the equivalent of the tenth of an acre to produce most fruit,
vegetable and eggs/chicken meat.
Alternatively land for horticultural purposes could be made available by the developer.
Another housing policy could require one dwelling or
more of those being proposed, to be made subject to an agricultural occupancy
condition. In itself, the “ag tag" would limit the price of such a dwelling
and could reasonably be accepted as part of the affordable housing requirement
(often about 40% of the total). In many cases a development of a scale
appropriate to the village (say 20 houses) will occupy only part of the land
owned by the applicant. It should, therefore, be possible to require some or
all of the residual or remaining land to be sold or leased with the tied
dwelling(s). To counter any argument that S106 is not designed to control the
sale or lease of land, the residential smallholding might have to be proposed
as an integral part of the application for residential development. Conditions
and/or obligations can then control the establishment of the smallholding and
also the future use of that land. It might be necessary for the terms of a lease
to secure these benefits (possibly
enforced through the PC or ELC).
It might serve to reinforce the effectiveness of this
policy if the development plan explained that, by using the area around the
settlement for small-scale agricultural enterprises there should be less need
for these to be established in isolated locations in the open countryside. Food
enterprises on the edge of villages would enable those involved and their
families to be part of a village. It will also enable village residents
to be involved in the agricultural enterprise.
Government reacted to failings in the use of s106 by
introducing the Community Infrastructure Levy (CIL) that will gradually
supersede the arrangements currently available under section 106. On-site benefits might still be secured
through s106 but the payment of CIL might reduce what a developer would be
willing or able to contribute in terms of land. Although local authorities
(county councils) have powers to acquire
land for smallholding, this can involve
compulsory purchase which is not seen as a popular way of managing land
use. In an area where CIL is introduced it would be necessary to include ‘local
food’ as part of the schedules of “infrastructure" to which CIL receipts
could be put. (see the reference to Green Infrastructure and SANG land above).
In the village where I live, 200 out of 1900 adults
responding to the village survey said that they, “…would be interested in
growing food locally on a small holding (i.e. land larger than an allotment)”. Assuming that there is the same level of
demand of about 10% of the population in other towns and villages, there would
seem to be a compelling case for planners to become involved. So, engage with the planners (professionals
and politicians) at all levels and in both plan-making and
decision-taking. Inform them of the
public interest case in regenerating ‘local food’. Explain that affordable land and housing
epitomizes ‘sustainable development and that planning controls are real and
perceived barriers to people being able to realize these ambitions. Without
food and farming policies neighbourhood plans should net be found to satisfy
the basic condition of contributing to the achievement of sustainable
development and local plans should not meet the test of “soundness”.
These comments and more about using the planning
system for sustainable development particularly in housing provision (mostly
co-housing and self building) at DanthePlan.blogspot.com
Thanks, Dan, for this. I hope people read it. A huge help to grasp planning as an enabling practice rather than as repressive and forbidding, as it so often is felt to be.
ReplyDeleteVery pleased that reference to Surrey SANGS sparked off such an interesting line of thought. Isn't there a role for CLT's in this brave new world of CIL funds, ELC and co-housing. CLT's could draw social investors into this planning for local food milieu; CLT's adapted to secure the land assets for creating new populations of CSA smallholdings. Think Land Settlement Association estates. I visited the remains of one owned by SCC at Sutton on Sunday. The LA is selling off the houses and seeking to lease the holdings as land with light industrial use! I guess a lot of LA Planning Depts. are under pressure to get creative with the public estates in cash strapped unitary/district authorities. I'll email you re Coxbridge. Thanks again for all your counsel. Robert.
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