Still no need to get personal in Amber Valley #NPPF

I have a number of responses to the last post with replies basically saying its ok to get personal against the staff of amber Valley because they havnt considered brownfield sites.

Well they have have a look at this report. It shows there are a number  brownfield sites in Amber Valley considered suitable and available which are taken into consideration in their recent consultation totalling over 1,000 dwellings.    This means that several thousand dwellings will still be needed on Greenfield sites whatever happens as this equates to only two years supply and they have to plan for 15.  Greenfield sites for over 36,000 dwellings are being consulted on by only a fraction of those will be designated to make the expected 550 a year target.  There is nothing dodgy or unusual about this consultation.  Many authorities have to do the same.  There is no need to get personal.

If hypothetically the authority did go with a 100% brownfield plan the opening day of the inquiry would see the inspector say a) that isn t nowhere near enough and b) where are these mysterious deliverable and developable sites then because I see no evidence.  And without a sound plan they would be at risk of losing appeals and costs at many appeals as Leeds have suffered.  Amber Valley councillors and officers are just doing their job within the constraints of national planning policy and the attacks on them should cease.  They are ill mannered and counter-productive.

The intractability of calculating the social costs and benefits of developing and not developing land #NPPF

Henry Overman at the LSE Spatial Economics Blog comments on the recent Inexpensive Progress report.

I am all for a planning system which compares the broad social value of preserving undeveloped land to the broad social value of building on that land and makes decisions accordingly. On the balance of the evidence that we have available that would lead to lots more development on low social value agricultural land at the fringes of our cities. It would also preserve lots of beautiful English countryside that has high social value.

My issue is not over the balance or otherwise of the benefits and costs within the overall framework as suggested by Vivid but whether this is tractable at all.

Firstly the whole point of assessing costs and benefits is to aid decisions, which requires assessment of alternatives.  If you are looking at the marginal costs and benefits of developing an individual parcel you need to make assumptions about where (for housing) people will commute to, send their kids to school etc. and then you can calculate the costs of travel.  For just one parcel you have to assume continuation of trend as there is no alternative development scenario to consider.  The only alternative you can assess against is the ‘no development’ alternative.   So individual parcel assessment is simply comparing no development to trend, a non-decision scenario.  But this is not planning at all.  In these circumstances it would not be surprising if an assessment of continued sprawl versus no development came out in favour of sprawl but this comparison leaves the act of spatial planning out of the equation.

To put back planning you have to assess not individual parcels but realistic alternative spatial strategies, and then it is only possible to compare the costs and benefits of one strategy against the costs and benefits of other strategies, not one parcel against another.

Fore example a site might be proposed for housing but might be the only realistic site for a reservoir or a new school making a wider strategy happen.  You cant compare the costs and benefits of a parcel against the costs and benefits of a strategy as that is comparing apples and oranges.  Moreover if a site is the only realistic one for infrastructure needed in all realistic strategies then there is no loss of benefit from not building that house – as there are no conceivable circumstances where that one house would ever get planning permission.

A naive approach would say that these costs and benefits are intrinsically intractable as they are an infinite number of arrangements of land parcels.

In reality there are only a limited number of realistic strategies if you set out certain policy parameters in advance.  For example if you set a target of 800 homes per annum then you narrow geometrically the number of options.  But if you have set this policy target then the minimum costs in all strategies to accommodate that number should not be evaluated as they are the costs as a society we have decided to pay for this housing – a decision already made.  Similarly it would be wrong to assess the benefits of building 800 houses per-se as this assessment will have been factored into the decision to build to that target.  To assess them again would be double counting.  The only things that should be assessed are the site and strategy specific costs and benefits. A good example being the insistence of adding a ‘cost’ when examining the business case for rail the loss of tax revenue from car fuel duty, when the better way to assess this is the minimum cost for energy of the lowest cost alternative – what Basitat would have considered a dead weight ‘broken window’ cost to society – and then using that in the assessment of costs and benefits of investing a certain sum in transport; and then once that decision is made to assess the greatest benefits from investing that sum to gain the maximum accessibility and mobility from it. Indeed a former chief planning inspector at a commission in the 1990s on updating the DoTs approach to CBA correctly said that the wrong question was being asked – it should be do we need to get from a to be, and then what is the most cost effective and least environmentally damaging way of doing so.

Therefore it is meaningless to talk of the costs to society of not building on a field, rather the issue is too fold, what are the costs and benefits to society of certain building rates and then what are the best places to accommodate those rates.  I would call this the fallacy of parcel level cost benefit assessment.

Whose costs and benefits? You can assess them in term of immediate costs and benefits to current residents.  But this is not planning which looks to the future.  You need to look at the costs and benefits to those who move into an area and who are prevented from moving into an area.  But it is impossible to predict who will move, and how much they will earn in the future, it is only possible to forecast and this is beset with radical uncertainty.  How long will they live for, what discount rate to apply?  It is particularly difficult to measure willingness to pay issues over future costs and benefits which have not yet merged.  For example a town might gain a reputation for the arts which means it is a desirable place to live, but might now be run down and cheap.  Do we assume underlying growth in the future – and if we do are we not under-counting the benefits of the individual infrastructure and housing investments that will provide that growth?

Cost Benefit Analysis calculates the benefits and costs aggregately, so that it does not matter who bear the costs and who enjoy the benefit. But politics is inevitably about the distributional effects of who benefits and who loses.

Lets say that an assessment found that the benefits of developing 400 homes in Oundle was £31 million and £32 million in Raunds.  This is going to make very little difference in choosing between the two given that Raunds has three thousand more people able to write letters and lobby their greater number of councillors and to the people of Raunds who being smaller will with some vigour proclaim they should get proprtionately less.

In 1994 John Adams made a famous critique of CBA

The failure of CBA has three main causes:
• it attempts the impossible
• it is biassed
• it entrenches conflict

CBA cannot forge agreement between the Bosnian Serbs and Muslims, or the Tutsis and Hutus of Rwanda, or between those in Britain who believe more traffic is a benefit and those who believe it a cost, or between those who like ski resorts and those who prefer undisturbed nature, or between those who like loud rap music and those who prefer peace and quiet. CBA, which assumes that a society has a single objective function that all citizens will salute, cannot be reconciled with pluralistic democracy. Vilfredo Pareto, who articulated the criterion on which CBA rests, was hailed by Mussolini as `the founder of fascist theory,’ but the method that he inspired appeals to central planners of all political colours…

wherever people can be found arguing from different premises progress toward agreement can only be made if they can be persuaded to examine the foundations of their
disagreement. The skills in shortest supply for this task are not economic, but scientific and diplomatic.

Given all of these problems and uncertainties the advantages of a multicriteria decision making approach, where costs and benefits are only presented where they effect actual revenue streams and are easily quantified, become apparent.  But in this scenario the spatial economics approach of hedonic calculation has nothing to bring to the table.  Indeed the more complicated and less based in ‘hard cash’ the assessment is the more it is likley to be ripped apart and criticised by those opposed to the decision outcomes it recommends. Planners are wise to avoid them.




Alex Morton – more Contradictory Nonsense from the Policy Exchange #NPPF

Policy Exchange again a rant about the planning system – spot the contradiction – why does anyone take them seriously?

We have created a system where once developers have paid for land and made a payment to the council to obtain planning permission (entitled Section 106) they are probably out of pocket to the tune of £50-£100,000. On top of that, people are so desperate for a home you can put up almost anything and make a profit.

Terry Farrell to pay for application to demolish side walls of Battersea Power Station


Terry Farrell and Partners is to make a listed building application to allow parts of Battersea Power Station to be demolished, claiming it is the only way to save the structure.

The practice is assembling a team of specialists including engineer and conservationist Alan Baxter to work up an application at its own cost. It could be submitted within a month.

It would preserve the most important parts of the grade II* listed power station, including the front and back walls, the chimneys and the art deco control rooms, but allow other parts to be demolished.

This would reduce the cost of repairing the building from £90 milion to £25 million, said Terry Farrell.

His practice published a speculative vision when the site went into administration in December. This proposed replacing the side walls with a colonnade and creating a park in the central void.

In an interview in today’s Evening Standard he said: “Giles Gilbert Scott is one of the greatest architects of the 20th century and to bring this monumental temple alive again would be incredibly exciting. I believe that submitting a listed building application is the only way forward now, in order to preserve the iconic parts of the power station and unblock the ‘bigness’ that has thwarted all previous attempts to redevelop it.

“The most important thing is the relationship of the mass overall to the great void inside, and I find all attempts to fill it up and to make money – whether shopping, leisure, conferencing or a football stadium – deeply upsetting.

“The glorious sculptural remains of Fountains Abbey or the Parthenon in Athens have a retained sense of their spatial order. Our proposal for a colonnade and park retains the sense of the great void inside as well as the external view of the silhouette.”

No Need to Get Personal – Amber Valley Protesters Call for Chief Planning Officer to be Sacked over Housing Plans #NPPF

My inbox keeps being bombarded with messages and photos from protest groups in Amber Valley concerned about proposals to build around 5,000 houses in the core strategy (though the number hasn’t yet been finalised).

A group called Amber Valley SOS has been formed and protests at every Council meeting.

Rather disturbingly there are placards calling for the heads of the council leader, the CE and the Head of Planning David Stafford.

There is no need to get personal, they are just doing there jobs and are victims of the a combination of circumstances.

Here is Mr Stafford talking to This Is Derbyshire

 “We need to build about 510 homes each year in Amber Valley. The reason we need that many is due to a number of factors.

“First is the growth in population. More people are being born than are dying and people are living longer.

“The second is migration. Amber Valley is a popular area for people to move into, perhaps later in life, moving here from a city centre. It is still a relatively cheap place to live and it is rural and attractive.

“The actual figure will be set later this year and it could be higher or lower than 510. But that is what we have at the moment.”

He said that by 2028, about 5,000 more homes needed to be built in Amber Valley – but, crucially, that figure was reached after subtracting all current sites with planning permission granted to them.

In reality, it will mean the total number of new houses people will see popping up in the borough will be higher than this.

Mr Stafford said: “There are many sites around the borough which we have given planning permission for but on which building work is yet to be started.

“And, unfortunately, we can’t force developers to start building.”

With the recession biting into the economy across the country, building rates have slowed. Developers are taking fewer chances on new projects and numbers of houses being built has dropped.

Despite the goal of 510 new houses per year in Amber Valley, between March 2010 and March 2011, only 258 properties were built, with a similar number predicted for this year.

Every year the council falls behind its target, the higher the total number still required rises.

Mr Stafford said: “We are losing ground each year.

“Only a few years ago, we were meeting the target quite easily, with 531 homes built in 2006 to 2007 and 548 the year afterwards.

“Then the recession took hold.”

He said that unmet housing targets would have effects throughout the borough.

“More people in our population would not be able to find a house and they move out of the borough.

“Housing prices will rise because of the difficulty in finding a home and people will live at home for longer.

“It would make things very difficult for young people who want to start families.”

So the homes are necessary. But, as Mr Stamp and many other residents have pointed out, why cannot they be built on brownfield sites? And what about those homes standing empty?

Mr Stafford said: “Even if we built houses on all our existing brownfield sites, we could only create about 600 homes before we ran out of space. And that’s not taking into account the amount of brownfield land we have to apportion for employment development. It’s just not enough.”

Council leader Stuart Bradford said that, in the past year, about 100 empty homes had been brought back into use but that the total figure stood at over 1,000.

Mr Stafford explained: “We have an empty-property officer at the council who is dedicated to trying to find new uses for these houses.

“But many times, a landlord has just disappeared and you can’t just stick somebody new in if this is the case.”

The inevitable, if unpalatable, conclusion is that to keep up with housing need in Amber Valley, greenfield land has to be built on. But where? And how much?

Mr Stafford said: “We have admitted before that we feel we will have to build on greenfield land but it is not something we take lightly.”

As a result, the council is in the early stages of looking at which sites could be built on to meet the requirement of 5,000 homes by 2028.

The authority has singled out 16 spots around the region and will work with the public, via consultation, to whittle those down to the ones it needs.

Mr Stafford said: “The first thing is to say these are very early plans. The second is that we do not need to build on all sites – that would give us about 25,000 homes, far more than we need.

“We have chosen this many sites – about five times more than we’ll need – to provide a choice. And we will be working with residents at each step of the way to include their views.”

But it is the revelation of these early plans – and the areas highlighted – which has prompted such reaction among locals. One of the most contentious areas is Swanwick.

People there have formed an action group to oppose the possibility of building near the village.

Swanwick parish councillor Peter Statham outlined the issues.

He said: “A housing development of hundreds of homes would lead to increased traffic and the current amenities are not enough. There is no doctor’s surgery in Swanwick, no opticians and very few shops. There would also be a loss of green fields.

“We have faced three developments in the past, had three public inquiries and won all three times but now the goalposts have moved.”

The issue of whether existing villages and towns could take a large influx of new housing has led the council to develop an alternative to go alongside the multi-site approach.

This is to create one large settlement, complete with shops, schools and services, taking care of a large chunk of the houses in one go.

Only a few days ago, the Derby Telegraph reported that an approach had been made by a developer to build such a settlement on land at Cinderhill, near Kilburn.

If a plan was formally submitted for the development, it would be the first application for the site since a controversial plan was quashed in 2008 due to a legal flaw.

Cinderhill Opposition Group was set up to battle the Banks Group plans by local residents, who said nearby toxic tar pits had contaminated the land too much for it to be developed.

But Mr Stafford said any new plan would have to address this issue fully.

He said: “Cinderhill is a mixture of brown and greenfield land. Any plans would be thoroughly examined by the council and subject to all planning requirements. But we think it is worth consideration.

“Like all options for Amber Valley, though, we are looking to engage the community in every stage.”

Indeed consultation on the Cinderhall site at Denby has just commenced.

The truth is that Amber Valley illustrates how local authorities with what you might term intermediate housing demand are disproportionately affected by current and proposed (in the NPPF) planning policy).  High demand areas are less threatened because housing compl;etions often remain high giving them 5 years supplies, and they are more likley to have Green Belt, AONB protection etc. and lower housing targets anyway as a result.

But in authorities under less pressure the non-implementation of consents mean that although they easily met housing targets in the good years before the recession now they technically have a shortfall in the 5 year supply.  This is exploited by developers who see a chance to build up there landbanks on second rate long-shot sites on which they acquired cheap options.   These developers need not even have any great intention to build, merely add to the book value of their holdings to set against the sites they bought for too much money which weigh down their balance sheets which they cant build out because it would show up as a loss.   It enables them to say to their bankers – look we now have all these assets to secure against future lending.  However given the large number of consents banked around some towns if all of these came on the market at once the price would drop like a stone.  Such areas are victims of the curious accounting practices and business models of UK housebuilders so tellingly criticised in a recent report by the IPPR.

Ironically this policy situation doesn’t bite hardest on those authorities with the greatest shortage of housing sites and permissions but those with a healthy stock of permissions where developers are likely to be conspiring in drip feeding sites to the market, areas of intermediate demand.  In these areas appeals can see more and more consents being granted and more and more statements from developers that they wont be implementing those consents because of issues of viability.

National Policy on the 5 year supply should be reformed so deliverability is judged over a business cycle and over the forthcoming 5 years to avoid such perverse outcomes.

Advice to the SoS group, you may seem overwhelmed with applications and options but they cant all go ahead, its a question of positively engaging with which and where, which will do the least harm and have the most benefits.  It is likely that the final NPPF will give some breathing space to argue ‘prematurity’ whilst these discussions go on.