Dame Fiona ‘dont use the current eurozone crisis as a smokescreen for deregulation, which could cause lasting damage to town and countryside for generations to come.” #NPPF

Dame Fiona Reyonolds to BBC News on the Environmental Audit Committee’s Report

“Radical changes are needed throughout the draft planning changes if its fundamental flaws are to be addressed and the prime minister’s assurance on the role and purpose of planning are to be upheld.

“It’s vital that a short-term response to the economic situation doesn’t overtake the need for a strong planning system which delivers benefits to communities and the environment as well as the economy.

“The government must resist any temptation to use the current eurozone crisis as a smokescreen for deregulation, which could cause lasting damage to town and countryside for generations to come.”

#NPPF the Environment Audit Committee’s Report

Link 

MPs on the Environmental Audit Committee have written to the Prime Minister to express concerns about the ‘unsatisfactory’ wording of the Government’s new national planning policy framework (NPPF) – and to call for a clearer definition of sustainable development.

In its current form, the planning framework

“presents different messages to different audiences about what the presumption in favour of sustainable development actually means in practice.”

The Government’s vision must be articulated more clearly, the MPs point out,

“because it will be used as a material consideration in planning decisions and might have to be tested in the courts.”

Chair of the Committee, Joan Walley MP, said:

“As it currently stands the new planning policy framework appears contradictory and confusing.

It pays lip service to sustainable development without providing a clear definition, potentially leaving future planning decisions open to legal challenges.”
The NPPF must include an up-to-date definition that makes it clear that a ‘sustainable development’ should not breach environmental limits (on water use or waste disposal, for instance), according to the committee.

Joan Walley MP added:

“There are environmental limits to how much development any one area can sustain and the Government should acknowledge this in the final draft of the NPPF.

If the new planning framework protects our greenbelt and countryside, as the Government claims, then there should be no problem in defining sustainable development more clearly to avoid misinterpretation.”

MPs also highlight a number of other concerns raised in evidence submitted to their inquiry. The NPPF:

  • replaces the target for 60 % of development to be on brownfield sites with an ambiguous new requirement for development to be on sites with least environmental value regardless of previous use.
  • weakens the protection of the green belt, according to legal advice obtained by the CPRE
  • weakens the town centre first policy that was supposed to create viable town centres, according to the Town and Country Planning Association
  • could lead to urban sprawl and more car journeys according to the National Trust and the Campaign for Better Transport

CPRE #NPPF ‘Building in a small island’ report – previously developed land not running out

Building in a Small Island

The area of brownfield land is growing faster than it is being used. Yet Government proposals risk neglecting large areas in our towns and cities which need regeneration and place the countryside at risk.

A new report published by the Campaign to Protect Rural England (CPRE)  Building in a Small Island, challenges claims that there is a shortage of brownfield land suitable for housing development. The findings bring into question the Government’s proposed national planning policies that would no longer require developers to use previously developed land for any new development before greenfield sites are considered.

The report by Green Balance finds

There appears to be an underlying misconception that [brownfield land] will not be replenished sufficiently at the same time as it is being built on, whereas the evidence demonstrates that there is an ongoing supply of PDL as part of the process of urban land recycling in a dynamic market. Indeed, across England as a whole replenishment has exceeded reuse since 2001. Detailed reasons to support the change of policy inadequately understand the land and housing markets, and at times give misleading impressions. None of the arguments put forward is found to be convincing…Indeed, across England as a whole replenishment has exceeded reuse since 2001. (page 3)
The proposed changes to national planning policy could lead, under scenarios projected by the Government, to the amount of greenfield land being used for housing more than doubling (a 158% increase).

The report convincingly shows the fallacy in the governments argument.  An analogy I like to use is that The DCLG conceives of the stock of brownfield as like a well in a land that never rains, of course it does, a flow replenishes the stock, and this is where the report is strong. However we also need to cover the rate at wish we need to draw water (build houses) and that now garden housing is no longer classified as ‘brownfield’ it will rain much less often.

The report goes on to argue, rather unconvincingly in my view, that the price of housing is inelastic to land supply- a horizontal supply curve ! which may be partially true in the short term with a marginal change but is not true over a long period analysis, as the size of the stock of houses which arent new (90%) rises.  All of the arguments and research about land availability and house prices have been long period analysis.  The report also (page 9) seems to assume a perfectly competitive housing market – with only 5 main suppliers no – it leads to hobbit homes not innovation to cut build prices, there has been no rise in productivity or fall in build costs in this sector which is what would happen if this were true.

A strong part of the report is the analysis of the land take of abandoning the ‘brownfield first’ approach.  The impact assessment erroneously assumed that the ‘swap’ from brownfield to greenfield would be at brownfield densities.  The report of course makes the assumption that they would be at least at typical greenfield densities and the lot size would grow in a less land constrained scenario.  On that basis they estimate the land loss to greenfield would be 158% more than current, on the basis of the impact assessments assumption of the reduction in the brownfield building rate.

The impression from the data on ‘stocks’ of PDL that in a handful of authorities supplies are running out is seriously misleading when examined against the ‘flows’ of PDL: windfall sites have demonstrated a striking ability to sustain output in many authorities in the region. Only in the most constrained locations, where greenfield development would involve breaching major policy constraints such as the Green Belt, is housing supply apparently tied to the rate at which new PDL becomes available. (para 3.29)

What impact will deletion of garden land from PDL have.  The 2010 Kingston University study survey for DCLG found that it  contributed close to 30% of all new dwellings in the South East, whereas in other regions no figure significantly exceeded 10%.   However definitive statistics will only be collected from 2011 onwards.  The report does not try to model the impact of the change on future brownfield development rates, however with the need to build significantly more and the reduction in the categories of sites it would be very hard to see the % of brownfield sites remaining close to 70%, and without a shift to much higher densities and more compact forms of development the reduction in the rate could be substantial.

MPS say #NPPF ‘contradictory and confusing’, ‘lip service to sustainable development’ Telegraph, Independent

Telegraph

A Commons committee said controversial plans to introduce a “presumption in favour of sustainable development” to planning rules were “unsatisfactory” and open to legal challenge.

Unusually the MPs on the Environmental Audit Committee have written directly to the Prime Minister with their report, urging him to make changes.

The intervention from the committee is a significant boost for campaigners, including the National Trust, which are battling against the reforms. The Daily Telegraph is also calling for the changes to be rethought.

Ministers have stressed that they will take into account the findings of the committee before they finalise the changes in the next few months.

Mr Cameron and Chancellor George Osborne are desperate to reform planning rules to provide a boost to the economy.

They claim that current planning rules are holding back firms from expanding, and restricting house-building, keeping prices artificially high.

The draft National Planning Policy Framework (NPPF) distils 1,300 pages of planning guidance into as few as 52 and writes into planning rules a new “presumption in favour of sustainable development”.

However Joan Walley MP, who chairs the committee, said the current draft “appears contradictory and confusing”.

She said: “It pays lip service to sustainable development without providing a clear definition, potentially leaving future planning decisions open to legal challenges.”

The committee called for this presumption to be defined more clearly so it balanced “economic, social and environmental aspects” of development.

Planners in local authorities needed “an NPPF which does not push them to regard the economic dimension as predominant”, she said.

In her letter to Mr Cameron, Mrs Walley said the Government should write into the rules a definition of what is meant by sustainable development.

Mrs Walley also told the Prime Minister that the rules had to include stronger environmental protections.

She said: “The committee considers that the final version will have to make it clearer that the drive for economic growth does not trump other sustainability requirements.”

The framework says developments should be given the green light in communities where local plans are “absent, silent or indeterminate”, leading to fears that they will be sitting ducks for developers’ bulldozers.

Mrs Walley pressed Mr Cameron to delay the introduction of the framework to give people time to draw up local plans which set out where development can take place.

The committee’s report also called for the Government to emphasise that building should take place on brownfield sites before greenfield areas.

Fiona Reynolds, director-general of the National Trust, said the report was a “welcome and important intervention from MPs”.

She said: “If agreed, their recommendations would go some way to helping address some of the key concerns contained within the planning changes.

“It’s vital that a short-term response to the economic situation doesn’t overtake the need for a strong planning system which delivers benefits to communities and the environment as well as the economy.

“The Government must resist any temptation to use the current eurozone crisis as a smokescreen for deregulation, which could cause lasting damage to town and countryside for generations to come.”

A Department for Communities and Local Government spokesman said: “The planning system has always enshrined the principle that the economic, environmental and social dimensions of sustainable development should be considered in a balanced way – and it will continue to do so.

“The framework also aims to strengthen local decision-making and reinforce the importance of local plans. It was always our intention to ensure that appropriate transitional arrangements are in place before the new framework comes into force.”

Independent

The new planning regulations are contradictory and confusing, and would lead to the loss of green-belt land and development being prioritised over the environment, MPs have warned today.

In a highly critical report, members of the House of Commons Environmental Audit Committee backed concerns by the National Trust and the Campaign to Protect Rural England (CPRE) that the changes could prompt a rash of unsustainable building across the country.

More than 200,000 people have signed a petition by the National Trust opposing the reforms in the National Planning Policy Framework, and there is unease among Conservative backbenchers over the extent of opposition to the plans from their constituents.

The committee has now written to David Cameron urging him to reconsider the “unsatisfactory” wording of the framework and provide a clear definition of what “sustainable” development is to local authorities.

“It just seems to us that, as it’s written at the moment, the planning framework will create a free-for-all,” said Joan Walley, chair of the committee. “It’s a bit like playing football without having the rules of the FA.”

The committee’s report is a setback for ministers, who have been subject to sustained criticism from environmental groups over their proposed changes to planning regulations.

Today’s report comes as a study by the CPRE suggested that there was sufficient brownfield land to build 1.5 million new homes – equivalent to about six years’ supply of housing – without the need to use green sites.

But ministers reject this and argue that simplifying planning rules will encourage growth and reduce bureaucracy, while still ensuring important safeguards against unsustainable development.

Today’s report from a Conservative-dominated committee, including Zac Goldsmith and Caroline Nokes, warns that unless more is done to safeguard the natural environment local authorities will be able to override local opposition with the presumption in favour of development.

In particular, it suggests that it could lead to urban sprawl as towns increase in size, less protection for green-belt land and the loss of previous rules designed to strengthen town centres.

“As it currently stands, the new planning policy framework appears contradictory and confusing,” said Ms Walley. “It pays lip-service to sustainable development without providing a clear definition, potentially leaving future planning decisions open to legal challenges.

“If it protects our greenbelt and countryside, as the Government claims, then there should be no problem in defining sustainable development more clearly to avoid misinterpretation.”

Fiona Reynolds, director-general of the National Trust, welcomed the MPs’ intervention. “Radical changes are needed throughout the draft planning changes if its fundamental flaws are to be addressed,” she said. “It’s vital that a short-term response to the economic situation doesn’t overtake the need for a strong planning system, which delivers benefits to communities, the environment and the economy.”