More than a year and a half since the Government brought the National Planning Policy Framework (NPPF) into force, new research commissioned by the National Trust suggests that the Government’s planning policies could fail to deliver genuinely sustainable development.
The Local Government Information Unit (LGIU) carried out a survey of local authorities in summer 2013. The LGIU received responses from 147 senior officers and local politicians responsible for public parks, green spaces and planning.
Of those, 59 respondents had Green Belt in their local authority area and were asked the question “please rate the likelihood that your authority will allocate Green Belt land for development in the next 5 years”.
• 51% of respondents (31 of the 59 respondents) said their authority was likely or very likely to allocate Green Belt land for development in its Local Plan. In total there are 186 local authorities in England with Green Belt land in their area.
In the wider survey group of 147 senior officers and local councillors, which includes councils without Green Belt in their areas:
• 51% of respondents agreed or strongly agreed their authority has brownfield sites available that could help meet the 5 year housing land supply target, but they are not considered viable by developers.
New planning guidance to be issued by Government could make the situation worse unless it is amended. National Trust analysis of the proposed National Planning Practice Guidance (NPPG) suggests that:
• the revised guidance on assessing housing and economic development needs, land availability and viability will lead to more development on green spaces. The new guidance is also a missed opportunity to reinforce the Government’s ‘brownfield first’ policy.
The National Trust supports a plan-led system, and in some cases this will mean that previously undeveloped, ‘greenfield sites’ will be allocated for development in local plans, through a process that truly integrates economic, environmental and social concerns.
However, this new research leads us to conclude that the Green Belt and green space more widely is at risk from unnecessary development. This is due to the unrealistic rules on 5 year housing supply and the failure of the Government to ensure a brownfield first policy. This situation is likely to be made worse by the new ‘affordability test’ included in the NPPG.
In the summer of 2011 we launched our ‘Planning for People’ campaign in response to the draft National Planning Policy Framework (NPPF), which sits at the heart of the Government’s planning reforms. The National Trust was concerned that the NPPF would not steer development to the most appropriate places, and was weighted in the interests of economic development. We worked with the Government to make some significant improvements to the Framework, including a better definition of what constitutes sustainable development, and a clearer steer that brownfield sites should be developed first.
In response to our campaign, the Prime Minister wrote to the National Trust. He stated that “our beautiful British landscape is a national treasure“. David Cameron also said “we must ensure the appropriate protections for our magnificent countryside. This is why our reforms will maintain protections for the Green Belt…”. He also said that “sustainable development has environmental and social dimensions as well as an economic dimension, and we fully recognise the need for a balance between the three”.
However, in the months since the adoption of the NPPF we have become increasingly concerned that the Government’s planning rules are failing to give people a genuine say in shaping their communities, are not delivering a genuinely ‘brownfield first’ approach, and are placing additional pressure on councils to grant planning permission for unnecessary developments on Green Belt and green spaces in both urban and rural areas.
LGIU conducted research for the National Trust in the summer, surveying Local Authorities’ opinions on the level of protection given to Green Belt and green space in their area.
The National Trust also commissioned an expert analysis of the new National Planning Practice Guidance (NPPG) issued in draft by the Government in September and likely to be finalised by early next year, comparing this new guidance with the ‘asks’ of the Trust’s ‘Planning for People’ campaign.
These asks are that the planning system should:
• Be balanced, establishing a framework for integrating economic, environmental and social concerns.
• Safeguard public interest by recognising the value of and protecting the countryside, heritage and nature.
• Start from what people value about their place, and their aspirations for its future.
• Give people a genuine say, and not undermine localism by insisting on an automatic ‘yes’ as the response to development proposals.
• Work in practice, by using clear and consistent definitions so that everyone has the same understanding of the rules and planning by appeal doesn’t become the norm.
This expert analysis was received in October. It informed the National Trust’s comprehensive response to the Government’s request for feedback on the NPPG.
Our findings in more detail
• The Local Government Information Unit (LGIU) carried out a survey of local authorities in summer 2013. The LGIU received responses from 147 senior officers and local politicians responsible for public parks, green spaces and planning.
• Of those, 59 respondents had Green Belt in their local authority area and were asked the question “please rate the likelihood that your authority will allocate Green Belt land for development in the next 5 years”.
• More than half of respondents to LGIU (51%) said their authority was likely or very likely to allocate Green Belt land for development.
• 36% of respondents disagreed or strongly disagreed their authority has sufficient sites to meet the 5 year housing land supply target. However, 51% of respondents agreed or strongly agreed their authority has brownfield sites available that could help meet the 5 year housing land supply target, but they are not considered viable by developers.
National Trust analysis of new Planning Guidance
• Our analysis of the NPPG suggests that taken together, the revised guidance on assessing housing and economic development needs, land availability and viability will lead to more development on green spaces. The new guidance is also a missed opportunity to reinforce the Government’s ‘brownfield first’ policy.
• The NPPF encourages a short-term view of economic viability that risks unnecessary development of greenfield and Green Belt sites. Local Plans must identify a “deliverable” five year housing land supply. This means that development plans must be shown to be economically viable and achievable with a reasonable timeframe. The NPPG has added considerable new guidance on how to put the viability principles in the NPPF into effect. The new guidance will require planning authorities to pay distinctly more attention to viability issues than they have had to in the past.
• The NPPG introduces new detailed guidance on ‘housing market signals’ in the section on assessing housing needs. Our analysis is that the new guidance will not increase overall housing supply, or deliver more affordable homes. However, the superfluous additional land release (over and above that that is already required when councils assess housing need against housing projections) could allow building firms to cherry pick the sites attractive to their markets. These are much more likely to be rural greenfield sites than those to which the planning system should be encouraging builders to go first.
• The NPPG states ‘the more significant the affordability constraints (as reflected in rising prices and rents, and worsening affordability ration) and the stronger other indicators of high demand (e.g. the differential between land prices) the larger the improvement in affordability needed and, therefore, the larger the additional supply response will be’. Elsewhere the draft NPPG states ‘divergence under any of these circumstances will require upward adjustment to planned housing numbers’.
• The proposed NPPG guidance on windfall sites is a missed opportunity to focus development on deliverable brownfield sites of low environmental value.
• The Local Green Space designation was a new planning policy outlined in the NPPF, and more guidance on how it could be used it provided in the draft NPPG. It provides probably the best opportunity in the new guidance to promote practice which starts from what people value about their place, and to protect the countryside, heritage and nature. However the guidance seems not to grasp this opportunity fully at present.
• Evidence gathered by others supports this picture. CPRE research (June 2013) says that 500,000 houses are planned for greenfield sites. CPRE also estimates that, as a result of the Government’s planning policies, Local Authorities are allocating land for 150,000 houses in the Green Belt, double their estimate of a year ago .
Our request to Government
The National Trust believes the Government should take the following steps to ensure the NPPF delivers genuinely sustainable development:
• The Prime Minister and Secretary of State Eric Pickles should publicly re-affirm their commitment to protecting the Green Belt and promoting a brownfield first approach to send a strong signal to Local Authorities and the Planning Inspectorate
• The proposed National Planning Practice Guidance should be re-drafted to point development more effectively towards brownfield sites first. The damaging ’affordability test’ should be removed altogether.
• The House of Commons Communities and Local Government Committee is expected to carry out an inquiry into the implementation of the NPPF in the New Year. The Government should seek to implement the findings of this cross-party committee if it finds problems with the NPPF’s implementation on the ground.
• The Government’s Local Enterprise Partnerships have significant financial resources. Government should consider whether these bodies could be given a strategic focus on remediation of brownfield sites in urban areas, bringing these forward so that new housing and green space can be created in our towns and cities.