DCLG Framework Review

The Communities Parliamentary Select Committee are reviewing the working of the National Planning Policy Framework and I attended a workshop on 1 September 2014. Although delegates had already submitted written comments we were invited to make representations arising from these further discussions.  Some of the points in the following note were included in the original but I thought needed emphasising:

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).