CPRE Misleading on Why Some Local Plans undershoot OAN – would doom Plans to be unsound


Quoted below

There are four reasons why a local plan undershoots OAN

  1. It is underbounded or embedded with the heart of a large city – leaving no room to expand
  2. It has binding environmental constraints (not policy constraints) such as SPA/AONB etc.
  3. It is a site allocations plan carrying forward allocations from RSS numbers or numbers set in a higher level joint plan
  4. The council makes a policy choice to build less – like Castelpoint citing Green Belt for example  – a strategy doomed to fail.

The research doesn’t make this distinction.  Of the list Brighton and Hove, Watford, Ipswich  Crawley Derby etc. are victims of underbounding.

South Normaptonshire is an odd inclusion as its allocations plan only covers the rural area and does not include strategic allocations on theEdge of towns in the joint West Northants core strategy.

Wealden has tough SPA constraints, much more restrictive than AONB constraints alone, Lewes has AONB and National Park surrounding most of its major towns – indeed its major town in now in the South Downs National Park.  Chichester abuts the National Park.

Hertsmere only has a recent allocations document, its core strategy from 2013 is based on old RSS numbers and is very out of date.

To my mind these fully explain the variations.

The report is dangerous in that it gives the impression that undershooting where suitable land is available is a policy choice.  It isn’t the Bole doctrine was abolished with the Housing White Paper – now you have to review local plans every five years.  Similarly though local plans have a choice to treat Green Belt as an NPPF constraint as Castelpoint shows if they do so they will need agreement from elsewhere to meet the shortfall of fail the DTC legal and soundness tests.  If Windsor and Maidenhead followed Paul Miners advice they would have an unsound plan.


The Campaign to Protect Rural England (CPRE) today shows that councils are failing to apply planning guidance that is designed to protect precious countryside.

Councils are expected by Government to establish and have a plan to meet an ‘Objectively Assessed Need’ (OAN) for housing in their area, which takes into account issues such as projected population growth and future employment opportunities. Yet planning rules also state that this number should take into account constraints such as protected countryside.

CPRE research today shows that, since 2012, 24 councils out of the 62 local authorities for which there is clear data have heeded national policy and established housing targets in approved local plans lower than their OAN, with the majority reducing their targets due to environmental or countryside constraints. These include Chichester, Lewes and Wealden. Chichester reduced its target by 23% and Lewes by 30%. Other local authorities, such as Brighton, Watford, Hastings and Crawley, have reduced their targets by 50% or more (see Fig 1 below).

Other councils, however, have pursued the full OAN despite a high proportion of their land being protected countryside. In East Devon, the planning inspector accepted the local authority’s contention that OAN of 17,100 houses should be met in full because of high expected levels of job creation in the district. In Christchurch and East Dorset, where the local plan meets the objectively assessed need for 8,490 houses over 15 years in full, 84% of the area of the plan is covered by Green Belt, AONB and nature conservation land.

CPRE finds that this approach is continuing elsewhere (see Fig 2 below). For example, the Royal Borough of Windsor and Maidenhead, part of which is covered by the Prime Minister’s constituency, is pursuing their full OAN target of 14,000 houses over 20 years despite 84% of the land being Green Belt. In Mid Sussex, the planning inspector has been reported as forcing the council to accept a number even higher than their OAN of 876 houses per year to help Crawley meet their ‘unmet need’. Mid Sussex has significant areas of precious countryside, particularly the High Weald AONB. Neighbouring authorities, particularly Wealden which has a similar proportion of protected land, have been able to reduce their housing targets. Campaigners and local MPs have long fought a consortium of developers who have argued for a still higher housing target.

CPRE’s planning campaign manager Paul Miner comments:

“Government planning rules state that councils should reduce their numbers if faced with significant constraints. A number of councils around the country have done just this. One has to ask, therefore, why the Government is allowing councils to ignore national guidance in places such as Maidenhead.

“We need to build more genuinely affordable homes. But current rules promote urban sprawl and cause the unnecessary loss of countryside. A more transparent and less damaging method of planning for housing is urgently needed.”

Government ministers recently pledged to create a new method for councils to calculate their Objectively Assessed Need. The proposals were expected in early summer, but the General Election is believed to have delayed their release. CPRE is calling for a method that better reflects local need, protected countryside and current building rates.

CPRE’s new research follows previous work by consultants Lichfields, who in 2016 found a further seven councils that reduced OAN due to constraints or adverse impacts (p. 15: link). Added to CPRE’s work, this would total more than 30 councils that have reduced their housing targets, most often on environmental grounds.

Figure 1: The top 15 local authorities who have set lower housing targets in adopted plans

Figure 1

Figure 2: 10 Local Authorities who have not reduced their housing targets in adopted and proposed plans despite high proportions of protected countryside.

Figure 2


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