CPRE GLOUCESTERSHIRE BRANCH

 

Response to ODPM Consultation Paper on New Planning Policy Statement 3 (PPS3): Housing

 

1.      Introduction

 

We are writing to express our concerns on the consultation draft of PPS3 and its accompanying draft practice guidance on Housing Market Assessments and Housing Land Availability Assessments. Our concern is that as drafted the PPS puts an unbalanced emphasis on meeting market demand for housing. Unaltered it will undermine the considerable progress which has been made in Gloucestershire on focussing development in the most sustainable locations. It will also undermine the emerging South West Regional Spatial Strategy which has successfully plotted a strategy for housing the very large increase in population expected while respecting the conservation of the environment and in particular the fine countryside which underpins the region’s attraction as a place to visit and set up business.   

 

2.  Lack of a clear statement of environmental context

 

Gloucestershire is a very rural county within which sit two modest cities (Gloucester and Cheltenham). The county contains some of England’s finest countryside, a number of historic market towns and a host of small villages. Geographically however it is easily accessible from the major centres of Oxford to the east, Swindon and Bristol to the south east and south, and the West Midlands to the north. Improvements in the road system have made it relatively easy to commute from the rural areas into all these conurbations. Our experience is that when market forces are inadequately restrained by policy then housing development moves to the villages and country towns and commuting increases unsustainably.

 

A clear example of unsustainable commuting is the Cotswold District where the strategy for the local plan 1991- 2001 was to locate most of the new housing in the largest town (Cirencester), some in the next nine market towns, the largest of which has only 5000 inhabitants, and only exceptionally in the villages. In practice 20% of housing was built in Cirencester, 40% in the small towns and 40% in the villages. The result has been a rapid rise in car commuting across the Cotswolds mostly to the urban conurbations. About five years ago the A419 was converted to dual carriageway for most of the route from Swindon to Gloucester. The traffic levels have exceeded forecast by 80%, much of which is concentrated in the peak hours leading to long tail-backs and rat-running through villages. The root cause was that local plan policies concentrated on landscape and historic heritage protection; this meant that each application was judged on its own merits against criteria based on subjective judgements and where the cumulative effect on the character of the settlement or the cumulative environmental effects of traffic were not valid grounds for objection. It was only when central government policy put emphasis on urban regeneration and discouragement of commuting that local authorities were given the tools to increase the focus of development on Gloucester and Cheltenham and to refuse excessive development in the smaller towns and villages. This is now bearing fruit.

 

The conclusion we draw is that it is important for Government strategy to be clearly spelt out and backed by firm policy statements. We suggest therefore that the introduction to PPS3 contains a clear statement along the lines:

 

 “ It continues to be government policy that new market housing be concentrated in and around the major urban conurbations, that housing which would encourage commuting to these conurbations should be discouraged and that housing in country areas be limited to the local need required to maintain vibrant sustainable self-contained communities. Nothing which follows overrides this policy.” 

 

3.  The need to recognise restraint to market demand

 

PPS3 as drafted puts emphasis on meeting demand within Sub Regional Housing Market Areas. These are emerging as being defined as the commuting envelopes of the major conurbations. These will cut deep into rural areas of Gloucestershire (and other counties). Both the use of Sustainability Appraisals and reference to PPS1 are too weak to constrain and focus the demand for commuting homes which will be evident within these areas. This conclusion is reinforced by the fact that only areas of high demand and low demand are recognised in the draft policy. In the former land is to be made available to meet demand and if rising house prices indicate that there is unfulfilled demand then further land should be released. This is exactly the case in the attractive areas of the countryside. We urge that PPS3 recognises explicitly a third category of “Restraint” where market demand is not fully met for sustainability reasons. We suggest this be incorporated as an introductory paragraph to the section on Rural Housing along the lines:

 

“ To meet sustainability objectives, allocation of housing land in rural areas should be limited to that required to meet local need and allocation of land which would encourage commuting should be discouraged. In these circumstances it will be acceptable for there to be a policy of demand restraint both in the allocation of the numbers of dwellings and in the formulation of the policies covering the acceptable criteria for approving market housing planning applications. Such areas of restraint may cross district, regional and housing market area boundaries. To define the areas of restraint and common policies will require co-operative working of all the authorities concerned.”

 

4.  Affordable housing and design

 

We welcome the emphasis on providing affordable homes and that will be a key element in defining local need. We support the policy of provision of exception sites. We also welcome the emphasis on quality and sustainable design. In the latter case we would recommend that local planning authorities are required to adopt the building industry’s own best practice for energy and resource efficient standards as mandatory requirements for developers.

 

5.  Policy on release of land

 

Much progress has been made in Gloucestershire in directing development towards brownfield sites in particular in Gloucester and Cheltenham with 80% of all completions in the last three years being on brownfield sites. There is still a very significant availability of brownfield land particularly in Gloucester and Cheltenham with 91% and 71% of future developable land being identified as brownfield. It will need strong policy and local authority direction to ensure that this land is developed in preference to greenfield sites around these cities. We therefore welcome the clear statement in para 15 that priority will be given to the development of brownfield land. The provisions of para 16 however undermine the principle by forbidding phasing within the first five years period. This is recipe for greenfield sites being developed and then pressure being brought to bear on local authorities to release further greenfield land on the grounds that no brownfield site meets the criterion in para13 of being viable. We know that brownfield site development is more difficult and it is possible that meeting demand can be frustrated by local authority insistence that unviable brownfield sites be developed before greenfield sites can be brought forward. We suggest the solution is to allow local authorities to take a flexible approach to which brownfield sites are to be developed first – in effect to treat all brownfield sites as a single land bank from which they select by negotiation with developers sufficient sites for release to meet a 60% target over any five year period. Indeed the evidence above demonstrates that a target of 75% would be more appropriate and challenging.

 

6.  Windfall sites

 

Within Gloucestershire 31% of housing over the last 5 years has been met by windfalls on sites of less than 10 dwellings. We see no reason to suppose this will not continue to be so. We are therefore surprised to see that para 14 severely limits taking windfall sites into account to “when it is not possible to allocate sufficient land”. It is always possible to allocate sufficient land by allowing excessive urban extensions. We believe that the opening words of para 14 will result in an overprovision of greenfield land as market forces will ensure that windfalls continue to come forward. Of course it is important to make a realistic provision for brownfield windfalls which reflects the impact of policies, rather than rely purely on projections of past trends, but that is not an argument for making no provision at all. We suggest that the opening words of para 14 be deleted.

 

7.  Meeting market demand in advance of formulation of LDDs

 

It is clear that in many parts of the county house prices already indicate a pent up demand. The reasons for this are outlined in our Section 2 above. Para 41 as drafted appears to encourage bringing forward the implementation of the principles of PPS3,  overriding existing local plan policies and strategies. Apart from bypassing the consultation process, many of the local plan policies in the Districts in Gloucestershire are aimed at restraining commuter demand. Ignoring these policies will result in a reversion to development of unsustainable but desirable rural sites to meet commuter demand. By increasing competition for scarce sites, this will also make the provision of rural affordable housing more difficult. We suggest this paragraph be severely caveated to make clear that policies aimed at protecting the environment, landscape and historic heritage or discouraging commuting should be applied to any review of meeting market demand. The existence of para 41 reinforces the need for a clear contextural policy statement, as suggested above. 

 

 

8.  Recognising local need and sequential selection

 

Local need is the housing required to meet the needs of locally employed people and their families and to accommodate self-sufficient expansion of the local economy. Local need includes affordable housing as well as free market housing. Being clear that allocation of land should only be sufficient to meet local need limits the sprawl that would take place if market forces were allowed free rein limited solely within  landscape policies. An example is again Cirencester. The town has been remarkably successful in keeping a good balance between housing and employment with something approaching 70% of working people within the town and its surroundings travelling less than 21/2 miles to work. The town is under continuous pressure to expand to meet the commuter demand from Swindon connected by the A417 dual carriageway and just 30 minutes away. As part of the local plan review, Cotswold District Council commissioned a landscape study of the land surrounding the town to identify possible sites for urban extensions which could be developed without significant visual damage to the countryside or the views of the historic centre of the town. The study identified enough potential sites with capacity several multiples greater than the need for local housing. Because of the existence of brownfield sites and the clear policies at regional and county levels on limiting building to local need, the District Council was able to resist pressures for allocation in the recent plan review of most of the sites identified in the study. This example shows that more than simple statements of environmental protection are needed to ensure demand is channelled into areas which meet the government's sustainability agenda of concentrating development on the major urban centres, protecting our countryside and discouraging commuting particularly by car and not least building sustainable communities.

 

To us the key to all this is that "need" can and should only be defined at the local level whether it be major urban conurbations, minor urban centres, market towns or villages. Housing market area studies will need to build up from this. We suggest that it should be made clear that need it is assessed on a very local basis. This is consistent with PPS7.

 

It also reinforces the sense of having clear policies on the sequential selection of sites. This concept appears to be entirely missing from the consultation draft of PPS3.

 

9.  Housing Market Assessments

 

Finally, we note with concern that the Best Practice Guidance on Housing Market and Land Availability Assessments reinforces some of the weaknesses identified above namely:

 

 

 

 

 

 

 

 

CPRE Gloucestershire Branch

February 2006