Developers Scupper Housing Plans
Amber Valley Borough Council has withdrawn its Core Strategy from the public examination that was due to resume next week. This follows considerable public consultation and heated debate for many years about potential housing development sites. The Council were at the final stage before formally adopting the Core Strategy.
The reason for the withdrawal is that, following discussions with relevant housing developers in the last two weeks, the Council can no longer be confident that the developers will deliver the previously predicted number of houses within the next five years on the sites proposed by the Council. Government policy requires the Council to show that enough homes will be built in the next five years to meet objectively assessed housing need.
Cllr Alan Cox, Leader of the Council, said:
I am deeply dismayed that such a decision had to be made at the eleventh hour, after so much effort and expenditure on the process by so many. Regrettably, however, despite the fact that there are many sites within the Borough that have been given planning approval by the Council, the Council has no powers to force developers to start building the houses, or influence the timeframe over which a site is developed.
He added: “The Council remains fully committed to establishing an up-to-date Local Plan for Amber Valley, which will provide a robust set of policies and proposals to support housing and economic growth in the Borough, whilst at the same time safeguarding and enhancing the environment. It will not, however, be practical to achieve a demonstrable five year supply, through the identification of further sites for housing development, without re-visiting the overall strategy for housing growth. The process of reviewing the growth strategy and reaching a conclusion as to an alternative approach, including appropriate public consultation and engagement, will take at least 12 months.”
In addressing concerns about the implications of making decisions without an up-to-date Local Plan, particularly where the Council cannot show a five year land supply, Cllr Cox said:
“This does not mean that any development, whatever the impacts, will be acceptable. Neither does it mean that there would be no point in refusing a housing scheme because we wouldn’t stand a chance on appeal. National planning policy, and the objective of pursuing sustainable development, is a material consideration in planning decisions irrespective of the status of an area’s development plan and will enable the Council to continue to protect the Green Belt and other areas of environmental importance for heritage, landscape and other reasons.”
He added:
“Levels of planning appeals upheld against an authority’s original determination remain constant at only one per cent of all planning decisions in England. There are several recent cases where development has been refused permission, even in the absence of an up-to-date Local Plan or five-year land supply, because it would conflict with national policy objectives.”
One can only infer that housing developers have scuppered the prospect of building enough houses over the next five years to make the plan viable. Did they demand more greenfield sites? Whilst public opinion favours building on brownfield land first this is more costly for developers. While there is a perceived demand for large numbers of new houses to be built the laws of supply and demand dictate that houses will be marketable at higher prices if fewer are available. And, if the Core Strategy is adopted the sites that are available to build on become more limited thus restricting developer’s options.
Many in Belper will be dismayed at this news and wondering whether the fight to protect Bullsmoor, Pottery Farm and Cherry House Farm will need to start all over again. Campaigners should take heart from Cllr Cox’s determination to protect Green Belt “and other areas of environmental importance for heritage, landscape and other reasons,” as well as the implacable opposition of English Heritage to any development at these sites and the previous planning appeal to build nearby that was thrown out.
CPRE – “housing targets based on ambition rather than actual need “
Meanwhile, the Campaign to Protect Rural England is today calling for an overhaul of the way local authorities set housing targets in order to stop countryside being lost unnecessarily.
Extensive research commissioned by CPRE has shown that local authorities are in effect being asked to base their plans on aspiration rather than need, which is resulting in ever higher housing targets and the consequent, unnecessary release of countryside for development – without resulting in an increase in overall housebuilding.
Among a large number of problems with how the targets are calculated, the research found a lack of clear guidance in the process, a lack of objectivity in the calculations, and a lack of concern for land availability and environmental impacts.
The research demonstrates that the unrealistic targets are putting undue pressure on the countryside. Setting targets far higher than what can be realistically built just means that developers have more sites to choose from: as static building rates show, higher targets do not mean faster delivery. The disastrous consequence is that when these unrealistic targets are not met, councils have to identify even more sites for housing, and ever more countryside is released for more lucrative development while brownfield sites go unused.
Matt Thomson, head of planning at the Campaign to Protect Rural England (CPRE), said:
It is vital that we build more homes, but this will not be achieved through ever higher housing targets based on ambition rather than actual need. The current process is not only highly damaging to our countryside and the environment in general; it is also damaging to community well-being and extraordinarily frustrating for local people.
Through its planning inspectors and the threat of expensive appeals, the Government is taking a top-down approach to impose and enforce housing targets – despite ministers calling for more localism. Instead, we need to see a more accurate definition of community need at the heart of all local plans, and more consideration for environmental concerns and land availability. Councils should not be penalised for failing to meet implausible ambitions for growth over and above actual housing need.
To illustrate the unrealistic nature of the housing targets, CPRE has analysed the local plans passed in the past two years that have contained a new housing target. In those 54 local plans, the average housing requirement is 30% above the Government’s household projections, and 50% above the average build rate. Only seven of the 54 targets take environmental factors into account.
To ensure that we build the homes we actually need in the right places, CPRE is calling for community surveys to play a far greater role in determining true need; for available brownfield land to play a leading role in developing targets; and for planning guidance to include a clear definition of housing need that is designed to support those who lack housing, and to ensure local plans specify what kind of homes will meet this need.
By David George
Nothing in Councillor Cox’s statement gives any grounds for optimism. The Tories at AVBC have utterly failed to carry out their responsibililities in regard to housing, just like the Tories at Westminster.
A well written article David ……………….
It led me to a very tedious evening reading the CPRE report ………… I have to say that I am not convinced. I quote this from the summary as an example:
“Counterbalancing ‘predict and provide’: there is a need to develop
counterbalances to top down ‘predict and provide’ approaches.
These could be most effectively achieved by ensuring that all
Assessments take account of housing needs derived from
meaningful sub-areas, including rural areas, and needs derived
from local assessment for example, from parish surveys and
Neighbourhood Plans. This would have cost implications for
commissioning SHMAs.”
It sounds good, democratising decision making to a local level but the onus on, what are essentially amateurs to get it right is very naive and divisive. I am not knocking Neighbourhood plans, well how could I when I am the vice-chairman of the Neighbourhood Plan for Belper and I have great respect for all who are involved with this project but we rely on information from a range of sources, principally those who live, work and study in Belper but also the agencies of local and national government. I do accept that SHMAs can be something of a blunt instrument and that is why I would favour a more step by step process that ensures that a base level of provision happens on say, brownfield sites and that only emergent peak demands would trigger development on hitherto virgin sites. That approach requires a more expansive approach that cannot solely rely on locally sourced solutions. On the surface the CPRE report seems to be in line with that but a more detailed reading, in the body of the text, is less clear. I do not agree that at 14 years a plan is too far seeing as I would advocate a plan that is even longer, a minimum of 20 years, more generational. Short term localism will be just as bad as long term regionalism and I contend could be even more detrimental to the green environment.
I know that I am not alone in my mistrust of the CPRE although I do recognise that some of their campaigning has been effective. On the down side I find their response to fracking is woeful:
“Based on current information, we do not oppose exploration for shale gas in principle, provided it meets certain conditions. Our Policy Guidance Note sets out those conditions and how we are trying to secure them. We will oppose proposals which fail to meet these conditions”.
Back to the core strategy …………… what is needed is a forensic analysis of housing need, today, next year, next decade ………………. We have a whole raft of information from the Office of National Statistics which does not just rely on the 10 year census but publishes regular key updates to assist infrastructure planning. This data provides a solid base for forecasting the changes that we can expect, to population size and demographic, and the services, infrastructure and housing that will therefore be required. Local input has a part to play in this process but cannot be relied upon to be the sole arbiter.
However, the real problem is that whilst our democratically elected representatives become ever more accountable to the electorate they have been stripped of any meaningful decision making power. The AVBC failure to secure an adequate 5 year build is inevitable given that developers want to build houses that they can sell at an enhanced profit level so they look to build in attractive places. The only way to counter this is for local authorities to commission the houses and that means that urban and rural councils should be empowered to borrow to build, a reinstatement of what was taken away from them in the eighties. It cannot be right that private developers are allowed to dictate housing strategy and this is the basic problem. Oh and whilst we effect that change we could also have a crack at land reform ………….. a related argument but one that should be left for another day.
I’m far from being an advocate for either Cllr Cox or CPRE but we now have his commitment to protecting our heritage on record. CPRE were pointing out the absurdity of a situation that allows self interested developers to plot to build on green fields whilst brownfield sites become eyesores. And for their plotting to override local democracy.
Housing need is normally assessed at Housing Market Area – HMA – by highly qualified consultants who have the ability and tools available to them to drill that down to much smaller sub areas. This is especially useful in rural areas but can also help balance need, affordable housing need, employment and infrastructure development.
Determining need is one thing but meeting it is another and this is where the process is, in my opinion, deeply flawed. Perhaps Local Authorities should have a duty to meet assessed and agreed need in their sub areas without having to buy in to a strategy that ties them up. Do we really need a Core Strategy?