Greg Clark the new SoS

Readers would have noted from previous blogs the influence of the Secretary of State for Communities and Local Government on planing decisions. As an example,  I  stuck out my neck in the blog on 'food and planning' to suggest that the NPPF need not change if only there was a change at Ministerial level. Lo' and behold from today we have Greg Clark as Sec of State.

Opening the NPPF issued in March 2012 we find the Ministerial Foreword from Greg Clark when previously Minister for Planning.  It starts "The purpose of planning is to help achieve sustainable development....Sustainable development means ensuring that better lives for ourselves don't mean worse lives for future generations."(emphasis added)

Mr Clark would or should have been horrified by the way his predecessor Mr Pickles has been corrupting the meaning and purpose of 'sustainable development' and the application of the 'presumption' in the NPPF.  The DCLG Parliamentary Select Committee reported just before the recent election and recommended that the definition of sustainable development be clarified.   No such clarification should be necessary just so long as the new Secretary of State reflects the above meaning included in the NPPF in all his future decisions.  We should all be congratulating Mr Clark and reminding him of his role in launching the NPPF.

Food and Planning

On 30 April the local branch of the Royal Town Planning Institute held a seminar on 'Food and Planning' and I gave a planner's response to the public interest case (presented by Colin Tudge and Richard Nunes). 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.  Mr Pickles with his very strange and conflicted views on localism and sustainable development may be replaced after the general election on 7 May - but the level of ignorance of planning in Government does not give much hope for the future.  Happy reading...

Food and Planning Seminar 30 May 2015

organised by Royal Town Planning Institute SE Branch

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.

2. 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.

I then considered various elements of the policy framework within which planning decisions are taken and that could be relied on by decision-makers.

3. 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 (see paper presented by Colin Tudge).  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 envisaged by Colin Tudge 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 developmentand 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)

Colin Tudge and Richard Nunes explained in different ways the need for and benefits deriving from local food systems and pointed to some of the barriers (eg affordable land and associated housing).  Unless I am wrong about the analogy of planning delivering affordable housing in the public interest and the  relevance of other parts of the NPPF that could be applied in support of local food processing and distribution, then the Framework should not be regarded as preventing the regeneration of local food systems.

4. 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)”

5. 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.”

Colin Tudge’s presentation identified the diversity and flexibility that could make ‘real’ or ‘enlightened’ farming  better suited to the green infrastructure reducing vulnerability to climate change.

“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.

8.   Neighbourhood   Development Plans

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

In my 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

9. 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.

10. 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. “

11.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.

12.Proposals

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.

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

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 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 local food systems.

7.         Regional food systems should be the focus of attention that would imply a ‘duty to cooperate’ between urban and rural planning authorities (as they are applies 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.

After the NDP referendum

Neighbourhood development plans, the referendum

and after

This blog discusses the issues raised from the

experience of drawing up a Neighbourhood Development

Plan and putting it to examination and referendum

‘material consideration’, and it would be reasonable

for a decision-maker to give substantial weight to

comments based on the substantial evidence base

represented by a draft NDP even if ‘the people’ had

not yet formally endorsed it.

A DCLG official has also agreed that it would be

reasonable in following section 38(6) for a decision maker

to give substantial weight to an NDP based on

substantial evidence, even if it failed its referendum.

Parish Council representations must be given

weight whether there is an NDP in preparation or

not. It would be perverse to give less and not more

weight to representations based on evidence

collected from the local population over a number of

years and through considerable expense in time and

money, just because of a failure to secure the

majority vote at a referendum. Such a failure could

be due to opposition to a single controversial

proposal or policy.

In these circumstances, asking, as the current

regulations require, whether the plan should be

‘used to help in making decisions’ is pointless, as

the plan must be taken into account whatever the

result of the referendum.

Given that the effect of an NDP receiving a simple

majority vote is that it becomes the ‘development

plan’ for the neighbourhood area for the purposes of

section 38(6), this should have been the question

put in the referendum. If this is too legalistic for the

voters to understand, then the question could relate

to another real effect of a ‘yes’ vote – whether more

weight should be given to the NDP than the Local

Plan covering the same area. However, in order to

cast a vote on this question, it would reasonably be

necessary for the electorate to know the contents

of the relevant Local Plan and be able to compare

its effect against the possible effect of the NDP (at

least one honest villager spoiled their voting paper,

being unable to make this comparison).

Over 1,000 NDPs are in preparation and over 50

have received support at referendum. It is not yet

known how many such plans have been tested at

committee or appeal in the determination of

applications by local planning authorities or the

Secretary of State. However, in the knowledge that

very few people would have been either able or

willing to read, understand and compare an NDP

with the relevant Local Plan, it might be reasonable

(in silent defiance of the regulations) in the exercise

of their judgement for a decision-maker to give little

or no more weight to a Neighbourhood Plan that got

its majority than to one that did not.

In my village about 30% of those entitled to vote

supported the NDP without, I would suggest,

carrying out the relevant comparison but as a show

of solidarity with those people who had put the

time and effort into the preparation of the plan. This

does not appear to be a good or sufficient reason to

raise a plan prepared by lay volunteers to the status

of the ‘development plan’ in substitution for a Local

Plan prepared by professionals. It will be very

interesting to see the feedback from professional

planners when they have had experience of giving

development plan status to NDP policies.

Without very close supervision over the

preparation of NDPs in a way that preserves the

spirit of ‘localism’, planning officers are likely to find

themselves trying to apply policies which are

insufficiently precise, prescriptive or proscriptive to

form a sound and reasonable basis for decision making

in accordance with section 38(6).

Notes

1 D. Lock: ‘CMK Business Neighbourhood Plan megaballots’.

Town & Country Planning, 2015, Vol. 84, Feb.,

58-60

2 Parliamentary Under-Secretary of State for

Communities and Local Government Penny Mordaunt,

reported in Hansard, 4 Mar. 2015, Column 360WH.

www.publications.parliament.uk/pa/cm201415/

cmhansrd/cm150304/halltext/150304h0002.htm#

15030472000340

3 Section 38(6) states: ‘If regard is to be had to the

development plan for the purpose of any determination

to be made under the planning Acts the determination

must be made in accordance with the plan unless

material considerations indicate otherwise.’

184 Town & Country Planning April 2015

Food and planning

I am in the process of helping to organise a  seminar on food and planning   for the local branch of   of the Royal Town Planning Institute.   One of the purposes of this seminar is to explore the extent to which food systems or hindered and could be helped by controls vested in the  1947 Town and Country Planning Act.

The  principal effect of the Act  was to nationalise control over the use and development of land and buildings. The extent to which these controls can legally be exercised by the Secretary of State and local planning authorities is strictly a matter for the courts.  Such judgements would rely on whether the decision was  made following section 38 (6) of the PCPA 2004;  ie taken in accordance with the development plan  (i.e. based on policies within it) unless material considerations indicate otherwise. There would not appear to be any statutory limits over what, judged by politicians to be in the public interest, would be the necessary material considerations to  achieve the desired outcome.

If, for example, it was decided that the  support and promotion of local food would be in the public interest (eg benefits in respect of employment, traceability, carbon reduction and food security) there should be nothing to prevent the inclusion of policies privileging local food producers, processors and distributors ( including retailers) from being included in development plans and reflected in planning decisions.  As discussed in previous blogs, this could include policies which sought to secure supply of land at affordable prices (for sale or rent) and associated affordable housing.

So the seminar (to be held on 30 April 2015 in Reading (Google RTPI south eastern branch)  will start by establishing the public interest in local food production, processing and distribution and then have presentations from those promoting these activities  at regional level, in the countryside,  within  urban areas  and in the urban fringe.   Hopefully, an outcome of these discussions will be the formulation of policies  in development plans that will facilitate a regeneration of local food systems.

The NDP Referendum

The Neighbourhood Development Plan for my village/parish has been cleared by the examiner and at the referendum, on a turnout of about 30%, 90% voted for and 10% against. These stages have raised some interesting issues not clearly covered in the legislation and guidance.

The examiner made some recommendations that were not intended to change the purpose of the plan; notably the drawing of a village envelope around the existing built-up area.  The version of the Plan that had been consulted on did not have this boundary defined and I had worked for the LPA in preparing a local plan where this exercise was regarded as too onerous (ie requiring a detailed survey of the perimeter of the village, looking at every garden and paddock) and the alternative of assessing the extent of the built up area  when applications were submitted has worked well for the last 40 years.  This was pointed out to the neighbourhood planners who, undeterred, agreed the line of the boundary during a ten minute period of the steering group sitting round a table in the village hall.  The question arose as to whether the neighbourhood planners had to follow what the examiner had said or the recommendation could have been ignored on the basis that the public could not be consulted ?

The National Planning Policy Guidance has recently been revised to confirm that any significant impacts arising from NDP policies or proposals must be assessed in the Sustainability Appraisal.  The Plan in question might be unusual in proposing a housing development that has been made the subject of an application before the Plan has been 'made'.  The impact of the development of part of the allocated site has been described both in the application and regarded by the Council Landscape Officer as 'significant'. The applicant claims that the significance is not sufficient to trigger an Environmental Impact Assessment but if this impact is not in the Sustainabilty Appraisal or an SEA,  the question will arise as to whether the LPA can still 'make' the Plan?

The question which must be posed at the NDP Referendum is, "Do you want the LPA to use the neighbourhood plan to help decide planning applications in the neighbourhood area?"  A planning minister has recently confirmed that, "...Neighbourhood plans have a legal weight prior to being adopted through a referendum. The fact that a plan is being written and is in place, subject to a referendum, gives it legal weight; it does not have that status only after a referendum."
(4 Mar 2015 : Column 358WH The Parliamentary Under-Secretary of State for Communities and Local Government - Penny Mordaunt). This is obviously the case under s38(6)* where any representation on a planning application is a 'material consideration' and it would be reasonable for a decison-maker to give substantial weight to comments based on a substantial evidence base even if the 'people' have not yet endorsed it.  However,  The DCLG has agreed that it would also be reasonable in following s38(6), for a decision-maker to give substantial weight to a plan based on substantial evidence even if it failed its referendum.  Asking, as the current regulations require, whether the plan should be 'used to help in making decisions' is pointless as the plan must be taken into account whatever the result of the referendum.

Given that the effect of a neighbourhood plan receiving a simple majority vote is that it becomes the 'development plan' for the neighbourhood area for the purposes of s38(6), this should have been the question put in the referendum.  However, in order to cast a vote on this question it would be reasonably necessary for the electorate to know the contents of the relevant local plan and be able to compare its effect against the possible effect of the neighbourhood plan. Given that very few people would be able or willing to read, understand and compare these two competing plans I would give little or no more weight to a neighbourhood plan that got its majority than to one that did not.

An application had been made between the deposit of the plan and its examination and referendum, that has now been considered by the planning sub-committee of the parish council.  The PC has not been trained on how to weigh evidence in the consideration of a planning application and expressed concern about the weight to be given to the NDP at its very final stages and the slightly conflicting views of neighbours that the PC would like to be seen to be taking into account.  Although it will not comprise the development plan until it is formally 'made', the PC would seem to be reluctant to relinquish its discretion to demote the weight given to the Plan despite the efforts of many of its members in its preparation.

It will be the LPA that has the ultimate responsibility for deciding what weight to give to the NDP and possibly to regret the lack of supervision provided in its preparation and the precise wording of its policies.

*The determination of the application must be made in accordance with the development plan unless material considerations indicate otherwise

Policies to privilege self-building and co-housing

I would not pretend to be an expert in the drafting of development plan policies but I have spent a career in applying policies and interpreting them as an expert planning witness  in the context of public inquiries.  The following was written in response to a request from a Neighbourhood Forum wanting to promote self-building and co-housing.  The former is receiving Government support and has many synergies with the latter and, incidentally,  with Community Land Trusts.

"Self/group-building and cohousing

The NDP recognises the important advantages that can arise from self/group-building and cohousing, particularly in terms of their sustainability; affordability, environmental  and social benefits. The 'golden thread' of sustainable development should run through the NDP, and co--housing and self/group building exemplify important elements of sustainability such that, in contrast to other forms of housing, either or a combination of the two would benefit from the ‘presumption’ in the Framework in favour of sustainable development. Experience shows that self/group building and cohousing are unlikely to occur within the Neighbourhood Plan Area without positive support and privileging.

1.         The Neighbourhood Forum will keep registers of those interested in self/group building and co-housing. Details in the register will include the nature of the household, the interest in renting or buying, the timescale of any prospective move, and the skills and time resources available to be applied to the project.

2.         On all sites suitable for 5 or more dwellings, 20% of the land shall be  reserved and made available to those wanting to self/group build.

3.         On all sites suitable for 20 or more dwellings, a suitable area of the site for  at least that number of units shall be reserved and made available to those wanting to  co-house.

4.         The area being used for co-housing and/or self/group building shall, subject to the resources being invested (see para xx below) be counted as part of the affordable housing quota required by the NDP/Local Plan.

For the application of the above policies reference to “suitable" shall mean that the site could, at 30 dwellings per hectare, accommodate the number of units indicated. Reference to “reserved and made available" shall mean that those wanting to self/group-build and/or co-house (whether or not on the Registers being kept by the Neighbourhood Forum), shall be given the opportunity to express and confirm their interest. The value of the relevant land and the nature of the interest shall, in cases of dispute, be subject to expert arbitration (e.g. RICS appointee). The period of the “reservation" will depend on the size of the site but, in no case will it be less than a period of 6 months  from the grant of outline or full permission, during which general purpose housing on that part of the site will not be allowed to commence.  In the case of a full permission there might well be a need for a further application (to be made at the expense of those wishing to self/group build and/or co-house).

In cases of self/group building the value of the work being provided by the builder/occupier or group will be assessed. If this amounts to more than (say) 50% these units shall qualify for part of the affordable housing quota required in accordance with the NDP/Local Plan."

I see that the original note made no mention of the unsustainable level of under-occupation (the subject of the previous post) that could be addressed through co-housing.

Under-occupation again

I don't think that the problem with the various forms of under-occupation can be over-stated.  While the talk is about the need to build 250,000 new dwellings per year (while carbon from housing has to be reduced by between 6% and 10% per year?!) there is very little said about the scale of under-occupation.  I would qualify that with the publicity being given to the empty/second home issue in London where a significant number of dwellings are owned by people who live in London for the weather! warmer for Russians in Winter and cooler for those from the Middle East in summer and for its culture and relative safety.  But is it true that shops and schools are closing for lack of custom due to the lack of permanent residents  - as is the case in other parts of the UK where second/holiday homes are vacant for large parts of the year.

"Notwithstanding estimates of over 700,000 empty homes ie about 3 years supply of new housing, the greatest potential is to balance the size of households and housing in the existing stock of about 26 million dwellings.  Provoked by a planning application for 70 houses on my doorstep where less than a third would be 2 bedroomed (and all for social rent or equity shared) the following letter was sent to the paper. There was no reaction in the following week's paper.

Should we be concerned that five of the applications for residential development reported in the Abingdon Herald (7 January) and Oxford Times (8 January) propose a preponderance of larger houses? Consultants for the Vale of White Horse District Council advised that 97% of new dwellings would need to be one or two bedroomed to rebalance the size of households and housing.  The average household size is around 2.3 people, and decreasing.  Over75% of dwellings in Oxfordshire have one, and more often two or more spare bedrooms.  And nationally, the spare capacity in the existing housing stock of about 26m dwellings is the equivalent of building 250,000 new 2 bedroomed homes for the next 80 years.

For many reasons, we are not all going to immediately “right-size” into a house to fit our family circumstances. However, these current planning applications show the intention of housebuilders to provide a majority (ie about 60%) of three and more often four bedroomed houses (and 3 parking spaces/dwelling!).  That the smaller dwellings are mostly for rent suggests that larger houses are being provided for reasons other than meeting ‘objectively assessed housing need’, as is intended by Government.   If, however, a large number of attractive smaller dwellings (some with generous gardens) were provided, a significant number of large dwellings vacated by downsizers would become available.

The recent Parliamentary Select Committee enquiry into the working of the National Planning Policy Framework  found that interpretations of ‘sustainable development’ had been inconsistent and  unsatisfactory.   Making efficient use of the housing stock will become more urgent as other sectors; power generation, industry, transport and agriculture, fail to meet statutory carbon reduction targets.  Planners must insist that new housing contributes to the achievement of sustainable development (inc 6% carbon reductions/annum) while residential development and employment in the County is planned to grow at 2.5%."