As we await the publication of the delayed Planning Bill, the direction of future planning policy is uncertain. The housing crisis itself is unquestionable, but the Government’s proposed means of achieving the 300,000 new homes per annum target has shown some inconsistency.
David Churchill, a planning partner in Carter Jonas’s London office has implemented some research which indicates the impact of recent political announcements on the development sector.
“brownfield sites throughout England have the capacity for
1.16 million homes”
“changes in housing trends as a result of the pandemic favour rural locations”
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At the time, my team was researching the extent to which local planning authorities (LPAs) were planning to under-provide housing in their emerging Local Plans, against the standard methodology target. Unsurprisingly, the majority of Councils which fall into this category have major constraints to development, such as areas at risk of flooding, unspoilt AONBs, tightly drawn boundaries around urban areas and other environmental designations. This list excludes the Green Belt as that is not considered reason enough to undershoot in planning terms. But then Johnson’s comment ricocheted around town halls up and down the country and suddenly Local Plans were halted. Several were widely reported in the planning press at the time but many more were evidenced in our monitoring. Furthermore we became aware of LPAs whose Local Plan progress was not at a definitive stage, but nevertheless was paused – for example those undertaking the second (or more) round of
Regulation 18 consultations.
While there was a sigh of relief when the Department distanced itself from the PM’s comments, the damage has been done and remains unresolved. With the Planning Bill, revisions to the NPPF and the Levelling Up White Paper all reportedly imminent, we look forward to finding out the true colours
of this Government.
“FINDING OUT THE TRUE COLOURS”
It’s time for the government to show its true colours
GREEN OR BROWN
The most significant announcement was Boris Johnson’s apparent commitment at the Conservative Party Conference that his party would not support greenfield development. Empathising with a captive audience of middle-class Tory voters, he referred to the ‘constant anxiety’ of those living in the Homes Counties over their ‘immemorial view of chalk downland’ being ‘desecrated by ugly new homes’.
Civil servants were quick to issue ‘clarifying statements’ stating that there was no change in policy. But prime ministerial announcements, however wayward, have an impact.
If local authorities are on the verge of committing to a large-scale garden village or urban extension, any hesitancy in progressing Plans can be understood. Similarly for those due to open up their Plans for public consultation, or submit them for Inspection, hesitation is understandable.
The potential impact on housing figures is more considerable than a few months’ stalemate while we await further clarity through policy, because the impact on a Local Plan being re-written, or an evidence base having become out of date and requiring updates potentially adds years to the Local
Plan process.
When a clear target – 300,000 homes per annum – exists but the main means for delivering it is taken away, that target can only be achieved if an alternative is put in its place.
The Government had been enthusiastic in its commitment to brownfield development but there are simply not enough urban sites to rule out all rural land development. In October the countryside charity CPRE released research which sought to demonstrate the substantial availability of brownfield land. It concluded that brownfield sites throughout England have the capacity for 1.16 million homes. And yet even these optimistic projections provide for little more than three years of housebuilding at 300,000 homes pa. Added to that, changes in housing trends as a result of the pandemic favour rural locations.
“brownfield sites throughout England have the capacity for
1.16 million homes”
“over 90% of undeveloped land the borough falls within the Green Belt and AONB.”
Brownfield development often brings with it significant constraints: sites are usually smaller than a typical greenfield site, the need for remediation is costly those positioned within an existing neighbourhood can be difficult to access. Housing on brownfield land can only be achieved through greater height and density – flats, rather than family homes. Private and shared open spaces are limited, and if parking standards are adhered to parking must sometimes be provided underground. The result is higher costs and lower profits – which then impacts planning gain, community infrastructure and, perhaps most significantly, on affordable housing.
Greenfield land, on the other hand, has the potential to deliver on the Government’s net zero aspirations and make considerable biodiversity net gains. Paragraph 11a of the 2021 NPPF requires that ‘all plans should promote a sustainable pattern of development that seeks to….improve the environment [and] mitigate climate change’. It is believed likely that a
2022 revision will re-enforce the sustainability goals.
Some LPAs’ inclination to build on greenfield land goes as far as calling for Green Belt reform. In Sevenoaks, for example, over 90% of undeveloped
land the borough falls within the Green Belt and AONB. Without Green
Belt release, the Council is unable to prevent unplanned
speculative development.
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