So we have the first full scale- as opposed to endlessly adhoc (often through ‘guidance ‘ without consultation which the courts naturally took a dim view of) nothing do do with evidence of what is or is not working bit rather driven by the productivity plan and Housing Bill.
Much of the document seems back to PPG3, housing around transport hubs, more promotion of bropwnfield, more proactive on new settlements.
The introduction of a large number of changes due to starter homes is here as well as relaxing policy on previously developed brownfield sites.
One section, flagged up before the election, seems not thought through at all, the new policy on small sites. Page 12
Most Local Plans include clear policies supporting small windfall sites, but there continue to be concerns about the challenges and uncertainty associated with identifying small sites. We propose to apply the approach described above for brownfield land to other small sites, provided they are within existing settlement boundaries and well-designed to promote or reinforce local distinctiveness. In doing so we will retain protection against unwanted development of back gardens.
Ok lets think about this. If the site is brownfield there would already be with the changes a ‘double presumption’, if commercial a triple presumption, if for a starter home a qudruple presumption in favour. If the site is a garden, not just a back garden, then the NPPF protects it.
So when exactly does this policy apply? The only thing left for this policy to apply to is open spaces within settlements. Within villages most of these are not defined in development plans, its a big job, they are rather often protected by criteria based or prohibitive policies. Hence local green space designations have been poorly taken up.
When exactly is this policy expected to apply? Either it is not intended to apply to green spaces within villages or not? Many of these spaces in villages are small and verge like and may or may not be protected as village greens, others may be paddocks and small areas of agricultural land and so would not qualify either as village greens or as public open space.
If it is not intended to apply to such areas the NPPF should say so, if this is the case however the DCLG should explain when if ever the policy would apply as it seems never.
Even more mixed up is the policy on settlement edges.
We also intend to make clear that proposals for development on small sites immediately adjacent to settlement boundaries should be carefully considered and supported if they are sustainable.
As the while definition of ‘sustainable’ is the NPPF the policy is effectively otiose it adds nothing to the NPPF. You can see why the policy could not be a presumption in favour of settlement edge expansion, as ministers may have wanted. The day a local plan is adopted – which may have resolved a dispute about limits, you could add another 10, then another, then another. If it did then there would be no policy which the starter homes policy would be an exception too, you would never get starter homes or affordable housing (They are different things – you cannot by political decree refine cats as dogs which the government is proposing).
There is a real issue here which the NPPF doesn’t resolve. Settlement boundaries for settlements of all sizes can be too small and out of date. The answer is to review them. If the review is unlikely to resolve swiftly LPAS should adopt a criteria based approach towards the impact of development on settlement character and consider proactively the poential for small sensitively designed schemes especially for local needs. The NPPF should state this.
Similarly their should be more certainty towards single plots. The government is confusing plots and sites. The reason other nations such as France and Germany build at twice the rate we do is that municipalities buy land at existing use prices, zone and subdivide it under a zoning and subdivision system and use the proceeds of land sales to pay for the roads, drainage and infrastructure. If the housing bill really wanted to properly introduce a push towards zoning and subdivision this is what it should have done, including I propose a rural agency providing support for parish plans to CPO sites for such zoning and subdivision in neighbourhood plans where owners are obstructive.