Lies, damn lies and statistics (qv Disraeli)
There are a lot of very interesting facts and figures in the NPPF Impact Assessment, which explains the reasons behind the Government's new policies in the NPPF (a bit like a bonus DVD with footage taken behind the scenes!).
For example did you know that appeals by Public Inquiry cost the Planning Inspectorate £11,500 each (on average) while written representation only cost £1,000 and councils only spend £3,200 on each Inquiry, while appellants spend £10,500?
No wonder PINS is so keen to ensure that as many appeals as possible are dealt with by written representations.
Commercial to Residential Encouraged
In 2010, the Government published a consultation paper, which mooted relaxing the Use Class Order to allow change of use from commercial uses (B classes) to residential (C3) without the need for planning permission. The NPPF states that here is a "shortage of housing land nationally", but the Government has decided to succumb to pressure from local authorities (who would have lost much need income from application fees and s106 contributions, as well as affordable housing) and make the policy more amenable to such changes of use.
About 1,000 such change of use applications are submitted each year and this is now expected to increase due to more welcoming planning policies. Any owner of an underused commercial building should certainly be looking at submitting a planning application for change of use to residential as a means of adding value to the property - and helping to tackle the housing shortage.
5 Year Housing Land Supply - Fact or Fiction?
All councils have to maintain a 5 year supply of housing land. This is imperative if we are to deliver enough homes for future generations.
Most councils claim that they have got a 5 year housing land supply, In April 2009, 86% of councils, which responded to a Government survey, said that they had a robust 5 year housing land supply. However, a study by the Planning Inspectorate (PINS), in March 2010, found that only 61% of councils sampled actually had a verifiable 5 year housing land supply.
PINS stated that there were a number of reasons why land allocated for development was not coming forward for development, including:
- Time taken for multiple owners to work together and agree a deal
- Infrastructure requirements
- Land allocated in less commercially attractive locations
- Landowner expectations
- Local market situation
In order to try to fill this gap between allocation and actual delivery, the NPPF now requires councils to add a 5% buffer to their housing figures, rising to 20% for persistently under-delivering councils.
Paragraph 49 of the NPPF states that if councils do not have a genuine 5 year housing land supply their housing policies will be considered out of date and the presumption in favour of sustainable development will apply. It appears that the Government is placing a great deal of emphasis on ensuring that councils have a robust 5 year housing land supply in place. Any councils that do not, will find themselves, inevitably, facing more appeals, which, as we know, are expensive!
Brownfield Sites in the Green Belt
In a previous Blog I referred to paragraph 89 of the NPPF which encourages redevelopment of previously-developed sites in the Green Belt. It's interesting to note the Government's thinking behind this policy change. The Impact
Assessment states that:
"The rationale for allowing the consideration of development on previously-developed sites is that the sites, by definition, have already been developed and the impact on the openness and purposes of the Green Belt has already been established. By allowing development which does not create a greater impact than the existing development, there could be additional economic, social and environmental benefits, including housing, transport, commercial, employment and decontaminating land without damaging the principles or protection of the Green Belt."
The Government estimates that around 29% or 47,000 dwellings are built on greenfield land. If 1% (470 dwellings) were now built on brownfield sites in the Green Belt, then this would save 17 hectares of greenfield land per year.
It is a shame that the Government hasn't taken this policy one step further, because, although the redevelopment of brownfield sites in the Green Belt is now encouraged, it isn't in the rest of the countryside. The Government needs to encourage the redevelopment of all brownfield sites, both inside and outside of the Green Belt. This would save hundreds more hectares of greenfield land in the years ahead.
Jim Bailey - Director, Guildford