As a Government consultation on assessing housing need closes, we take a look at the implications of proposed changes on the National Trust and protected landscapes, such as Areas of Outstanding Natural Beauty.
Our consultation response agrees that a standard approach to assessing housing need would be helpful, but questions whether existing house prices should be used to make an adjustment to the formula, and asks Government to build constraints, such as protected landscapes, into its formula.
Last week a Government consultation closed on creating a standard method for calculating housing need in each Local Planning Authority area. The consultation is titled ‘Planning for the right homes in the right places’, but we are concerned the proposals could have quite a different outcome unless they are substantially altered.
Ministers first proposed a standard method in a Housing White Paper, published in February, and the idea behind it is a good one – to give more certainty to Planning Authorities about the number of new homes they need to provide through Local Plans, and to remove the ability for developers and others to challenge the figures Councils currently produce, and stymy the plan-making process.
The National Trust recognises that there is a shortage of new homes, and support plan-led, well-designed new housing in the most appropriate locations. We were encouraged by the Government’s White Paper, which seems to agree with this approach.
‘A blunt tool’
However, we have some significant concerns about the impact of the proposed formula. As it stands it is too blunt a tool, and could have a negative effect, particularly for councils containing Areas of Outstanding Natural Beauty (AONB), Green Belt and in some areas where there is lots of National Trust land.
The proposed formula uses Government projections for housing growth and applies a multiplier based on existing house prices – so where house prices are higher than average, the housing need figure is increased, and where they are lower, the number is reduced. Any increases will be capped at 40% of the existing housing need figure. The Government has published a table which you can use to check the impact in your area.
In addition, the formula currently takes no account of constraints or designations, such as Green Belt, AONB or Conservation Area. The biggest increases in numbers appear to be in urban areas and in peri-urban areas with lots of Green Belt or AONB. In urban areas the proposals could create a pressure for taller buildings and urban densification more generally, which could place additional pressure on historic buildings and conservation areas
We are concerned that, if left unchanged, the formula and associated policy proposals would require local plans to allocate significant additional land for housing in or adjacent to these heavily constrained areas, if they cannot reach agreement with neighbouring Planning Authorities to accommodate additional housing numbers.
The consultation makes it clear that that a housing need calculation should only be the start of the process, in which councils need to consider environmental constraints, and liaise with neighbouring authorities to see if they can accommodate any shortfall. However, the proposals also appear to state that If Planning Authorities do not have a plan in place by March 2018 “would not be able to factor land constraints into the baseline for establishing their five year land supply”. We are concerned that this would leave them subject to a blanket presumption in favour of a level of development that could be much too high for their area to accommodate, having to rely on core protections in national policy for designated areas rather than a local plan-led approach.
We are concerned that this combination of changes could have the effect of forcing councils to release unsustainable sites for development in some of our most important landscapes, or in the Green Belt, resulting in urban sprawl and the coalescence of settlements. It could also lead to Conservation Areas being challenged by proposals for inappropriately tall buildings.
Stroud – Case Study
A look at a map of Stroud District Council (above) helps to illustrate why we are concerned. The National Trust cares for 1,385 hectares of land in Stroud District, 52% of which is in the Cotswolds AONB or has other environmental designations.
National Trust ownership includes the Stroud Commons (comprising Rodborough and Minchinhampton Commons) above the settlements of Stroud, Rodborough, Nailsworth and Chalford. The Commons comprise one of the largest areas of unimproved species-rich limestone grassland in the Cotswolds, with SSSI and SAC designations, and they also have far-reaching views across to the Severn Vale and Wales.
Stroud Commons provide an opportunity for local residents and visitors to get outdoors and closer to nature, but the use of these sites also puts significant pressures on these places from car parking and the associated problems of erosion, degradation of grassland and potential damage to archaeological remains.
There are various ways through which the National Trust and its partners can seek to manage these pressures, and indeed the Trust, Stroud District Council, Natural England and others already have an agreed strategy aiming to avoid and mitigate the impacts of new housing development within 3km of Rodborough Common. Nonetheless, our concern is that with the current evidence of wear and tear on the Commons (see image below), significant additional housing development in the Stroud area is likely to lead to further pressure on the Commons and harm to their ecological interest and natural beauty.
What we’re asking for
Our consultation response agrees that a standard approach to assessing housing need, which is less open to challenge than the current situation, would be helpful. However we:
- question whether existing house prices should be used to make an adjustment to the formula; and
- ask the Government to build constraints into its formula.
We hope Ministers and their officials will reflect on our submission and makes some alterations to their proposals. Without these changes the new formula would in many cases put additional development pressure on sensitive and constrained areas, placing at risk the many places whose popularity is based on the high quality of the natural or built environment. On its own, it is also unlikely to deliver more affordable housing in these places.
Blog by Adam Royle, Head of Advocacy, National Trust.