1.
There seemed to be general confusion
between the contents of the Framework and its implementation. It does not make any difference if the
Framework says ,’Para 93…Planning plays a key role in helping shape places to secure
radical reductions in greenhouse gas emission… ‘ if this is ignored by LPAs,
inspectors (the inspector in an appeal
equating sustainable development to 'consuming its own smoke' is an
honourable exception). The SoS is notably guilty of ignoring the ‘sustainable’ part
of the presumption. It is doubtful
whether any of the developments permitted since March 2012 come near to
consuming their own smoke, which then become a burden on future generations.
2.
There was a startling contrast
between the reaction of the invitees and that of Clive Betts to the claim from
one delegate at the end of the session that she felt like a lone voice on the
role planning plays in failing to mitigate GHG emissions. The Chairman seemed to suggest that this
would be a matter of planning and energy on which there were few
representations apparently unaware of the injunction at para 93 cited
above. My original paper points to a
number of areas where planning of housing could and should mitigate GHG emissions.
3.
Much was said about the absence of
either or both a local plan or demonstrable 5 year housing land supply. This has been made into a problem by those
involved in planning decisions by their
failure to grapple with the very serious implications of meeting the Carbon
Budgets and other aspects of sustainable development. Weight should be given to
an emerging local/neighbourhood plan
where it is consistent with the Framework (see para 216) . The unsustainable
nature of the developments permitted since March 2012 suggests that these
emerging plans are being ignored or policies necessary to contribute to the
achievement of sustainable development are absent.
4.
Clive Betts seemed to be concerned
about the impression that the Framework was seen as so helpful to large scale
developers or landbankers and not to smaller builders. While it would not be
possible to have one framework for the large and another for the small, there
are forms of development which are more likely to involve smaller
developers. Para 50 has proved to be
inadequate to meet the demand for self-building (and the emerging demand for
custom-building and co-housing). This
should be strengthened to require LPAs to include local plan policies and
determine applications to ensure that a proportion of all substantial sites are
‘reserved’ (for a time) for self/custom-building and co-housing. Registers of interest in these sectors should
be kept by all LPAs and they should also be included in the definition of
affordable housing in the Glossary.
5.
Clive Betts seemed to be of the view
that the need for new housing was in the order of 250,000 new units regardless
of claims being made by delegates that the assessment of need should include
under-occupancy, empty homes (including the growing trends of build-to-leave by
foreign investors) and second homes. The
analysis of Prof Danny Dorling (found in
All that is Solid 2014 Penguin) seems to have no impact. The Framework should deal with the likelihood
that about half the assumed need might possibly be met by new build and deal
with the most important issue of the more efficient use of the housing stock
(especially co-housing and downsizing – often the same thing).