We have received an email from CPRE (Campaign for the Protection of Rural England). They have commented in response to the current NPPF (National Planning Policy Framework) consultation which concludes on September 24th, 2024.
We believe that some Wreningham parishioners would be interested in the consultation and the comments made by CPRE. Hence we publish the email text here:
These comments have been organised with reference to the relevant consultation questions, using the same numbering as in the consultation documentation.
The government intends to revise the NPPF. This revision will, in our opinion, weaken the planning system and lead to an increase in housing targets and an erosion of local democracy – especially in regard to the rights of local people to have a meaningful say in the decision making process for onshore renewable proposals (wind and solar).
If you share the concerns of CPRE Norfolk please submit your comments to:
PlanningPolicyConsultation@communities.gov.uk and feel free to use any of the points CPRE Norfolk has made in your response.
This link gives access to all the consultation questions and you can see that we have only responded to a limited number of these.
Yours faithfully, David Hook, Trustee, Chair; Vision for Norfolk Committee
Proposed reforms to the National Planning Policy Framework and other changes to the planning system
The CPRE Norfolk Responses
Chapter 3. Planning for the homes we need
Question 7: Do you agree that all local planning authorities should be required to continually demonstrate 5 years of specific, deliverable sites for decision making purposes, regardless of plan status?
We have major concerns regarding this proposal. In our view they will serve overall to actively frustrate, rather than deliver, the government’s stated manifesto objective of delivering the‘biggest increase in social and affordable housing in a generation’, an objective which in principle we support. The restoration of the five year housing land supply rule and 5% buffer will only benefit large builders, leading to speculative proposals for development in what would normally be seen as unsuitable locations.
Question 9: Do you agree that all local planning authorities should be required to add a 5% buffer to their 5-year housing land supply calculations?
We have major concerns regarding this proposal. In our view they will serve overall to actively frustrate, rather than deliver, the government’s stated manifesto objective of delivering the‘biggest increase in social and affordable housing in a generation’, an objective which in principle we support. The restoration of the five year housing land supply rule and 5% buffer will only benefit large builders, leading to speculative proposals for development in what would normally be seen as unsuitable locations.
Question 14: Do you have any other suggestions relating to the proposals in this chapter?
It would be far better if the builders were required to develop their land banked sites. According to the Competition and Markets Authority (November 2023) the 11 largest housebuilders own or control an estimated 1.17 million land plots across more than 5,800 sites in Britain that have not been built out. The government should insist that these land banked sites are built out before any new sites are allocated. CPRE Norfolk has argued consistently for the phasing of housing whereby existing allocations have to be developed first (161 parish and town councils in Norfolk support us on this). Phasing of sites in this way should be included in a reformed NPPF.
The NPPF should more effectively encourage the regeneration of inner cities (and protect countryside from development) by encouraging the conversion of redundant office and retail space into residential usage.
Chapter 4. A new standard method for assessing local housing needs
Question 19: Do you have any additional comments on the proposed method for assessing housing needs?
We particularly disagree with the elements of the proposed new method which simplistically equate increasing the affordability of housing with increasing planned levels of supply in a given area. Given the dominance of the big six housebuilders and their control over the rate at which suitable housing land is developed, this assumption is fundamentally flawed and has been patently ineffective in the ten years or so since it has been established in planning policy.
The government should drop its plan to reintroduce compulsory targets – this is not a sensible or effective policy: it did not work in the past and it will not work now. It is a policy based on the mistaken belief that requiring local authorities to allocate even more sites for new housing will speed up the rate at which new houses are built, whereas in reality it merely increases the size of the developers’ land banks. For example, in Norfolk, compulsory housing targets led to the local planning authorities setting unnecessarily high targets and making an excessive number of site allocations (mostly greenfield) to accommodate those targets. As developers only build what they can sell they cherry pick the most desirable sites (often in rural areas) and land bank the rest. As a result, previous mandatory targets have not been met – in the Greater Norwich area alone sites for 30,000 houses were not built out during the term of the Joint Core Strategy plan and have been “rolled over” in to the new plan (the recently adopted GNLP). The planners had done their job: it was the builders who were blocking the development of sites in order to maximise profits by building only what they were able to sell at the highest possible price. Compulsory targets merely lead to the penalisation of local authorities and they are not the guilty party.
Chapter 5. Brownfield, grey belt and the Green Belt
Question 20: Do you agree that we should make the proposed change set out in paragraph 124c, as a first step towards brownfield passports?
CPRE Norfolk is pleased to see the proposed move towards a ‘brownfield first’ approach, prioritising the development of previously land. New housing developments should be directed to brownfield sites first, with research from CPRE demonstrating there is sufficient brownfield capacity to deliver 1.2 million homes. (CPRE State of Brownfield Report, December 2022, using brownfield register data from 344 local authorities in England)
Nevertheless, regard must still be given to heritage, ecological and biodiversity constraints as well as transport, flood risk etc. When determining applications for new homes on brownfield sites. The requirement for technical evidence to support new development should not be weakened.
Chapter 6. Delivering affordable, well-designed homes and places
Question 47: Do you agree with setting the expectation that local planning authorities should consider the particular needs of those who require Social Rent when undertaking needs assessments and setting policies on affordable housing requirements?
We support the recognition and introduction of the need for new social rented homes in policy. This aligns with our recent research around the need for greater numbers of rural affordable housing, in particular, social rented homes. (CPRE Norfolk, Affordable Housing in Norfolk: how far are aims and needs being met? December 2023.) However, it is difficult to see, without minimum targets, how the aspiration to deliver greater numbers of social rented homes will be met.
Question 54: What measures should we consider to better support and increase rural affordable housing?
The NPPF should better facilitate the creation of small-scale rural exception sites (RES) for social rented housing in villages as the best way to provide social rented housing in villages. At present in Norfolk, insufficient RESs are coming forward, resulting in a failure to deliver much-needed rural social rented affordable housing. This appears to be partly as Local Plans are increasingly allowing some market-housing to be built adjacent to settlement boundaries, likely leading to landowners holding on to land for such market housing, rather than for RESs at less profit. Also, there are indications that registered providers of affordable housing are struggling to provide new affordable units at the necessary and needed rates, due to a number of factors, not least the costs in maintaining existing properties. This leads us to believe that more needs to be done to enable LPAs to deliver social rented affordable housing.
Likewise, the provision of social rented housing needs to be prioritised further, because the linking of affordable housing provision to the building of market housing has failed to provide (particularly rural) communities in Norfolk with genuinely affordable homes.
A further factor which has an indirect effect on the number of affordable dwellings being available and constructed is likely to be the number of properties which are either second homes or holiday homes. This is due in part to the likely profit for these types of ownership when compared to releasing these properties as affordables, and also due to the knock-on effects on the property market in general when the supply of market houses is limited. In the three Norfolk LPAs most affected by this issue, King’s Lynn and West Norfolk, Great Yarmouth and North Norfolk, the percentages of second homes are 2.9%, 4.5% and 5.8% respectively (2021 census data, Office for National Statistics.) The number of vacant dwellings is also an issue, particularly in King’s Lynn and West Norfolk and North Norfolk, with figures of 6.9% and 8.9% respectively (2021 census data, Office for National Statistics.) These figures are supported by further information released by North Norfolk District Council, with 7,169 second and holiday homes as of 1 April, 2022, second homes representing 8% (4,508) of council tax paying homes, and holiday homes representing 4.5% (2,661) of all homes (council tax homes plus holiday homes liable for business rates) (the possible impacts of second and holiday homes in North Norfolk, NNDC, 20 July 2022.)
Question 61: Do you have any other suggestions relating to the proposals in this chapter?
We would like to stress the following:
- National Policy should redefine what is meant by ‘affordable housing’, so that discounted market housing and starter homes are removed from the definition, unless these categories are clearly linked to average local incomes and not just property prices.
- Clear, unambiguous and binding targets should be set for affordable housing, particularly for social rented dwellings.
- Greater government support is required to deliver affordable housing on rural exception sites, which would enable small scale affordable housing schemes to be built on the edge of rural settlements. This should include policy changes at national (and local level) to make it easier for such sites to come forward and to make it harder for other types of development in these locations to take place, in addition to the greater provision of grant funding for rural exception sites.
- Restrictions on the resale of affordable housing stock across rural parishes should be extended and enforced, so that these properties continue to be occupied by local residents, and not as second or holiday homes.
Chapter 8. Delivering community needs
Question 71: Do you have any other suggestions relating to the proposals in this chapter?
We would like to see emphasis placed within the NPPF on the need for providing disabled (or less-abled) friendly public transport, which should be mandated for all new housing developments. This would probably be best inserted into current NPPF para. 108 (new para. 106) alongside the need to identify and pursue public transport.
When considering a hierarchy of sustainable transport, electric/renewable-powered water transport should come high in any such list.
Chapter 9. Supporting green energy and the environment
Question 86: Do you have any other suggestions relating to the proposals in this chapter?
Climate change poses a great threat and CPRE Norfolk supports de-carbonising energy production through increasing the supply of renewable energy. However, this should not be achieved at the expense of the countryside. With good planning and sensible decision making it is possible to deliver a mix of renewable energy solutions of the “right” scale and in the “right” locations. We strongly suggest the following actions:
- Promote the inclusion in the NPPF of the national CPRE campaign objective to prioritise roof top solar energy production – there really is no need to sacrifice countryside for solar farms.
- Promote via the NPPF the use of small scale and community owned onshore wind schemes involving new micro wind harvesting technologies to avoid the negative impact of large-scale turbines on the landscape. The best way forward for onshore wind would be to decouple its production from the national grid and for it to involve numerous small scale local schemes owned and operated by the community. Each village could, for example, have a small turbine (e.g. less than 40metres high) and use it to power a community facility (e.g. a village hall). Coupled with the widespread employment of new micro generation wind harvesting machines to help power houses and businesses the cumulative impact of such schemes on onshore wind production would be considerable. This approach would have a minimal impact on the landscape and is preferable to the widespread employment of large-scale turbines which would cause unsightly visual intrusion over large areas of countryside (the average height of current offshore turbines exceeds 200 metres to blade tip). Proposals for large turbines in Norfolk (and elsewhere) have in the recent past caused much distress and opposition. The best way to secure community support for onshore wind is for it to be done at the right scale in the right places and to not return to a situation where huge turbines are placed in farmers’ fields.
- The re-instatement in the NPPF of a requirement for community support before onshore wind proposals can proceed. The removal of the 2 footnotes (NPPF footnotes 57 and 58) that provided local communities with a meaningful voice in on-shore wind decisions is regrettable. The NPPF should require (or at least recommend) the use of Parish Polls to democratically ascertain if an onshore wind proposal is supported by a majority of the local population most directly affected. If the proposal does not receive majority support it should not be permitted.
- The NPPF should require that the long-distance transmission of energy is facilitated by offshore grid connections or by the burying of cables. and not via pylon routes.
- The NPPF should specifically preclude the use of financial inducements as a means by which developers proposing an onshore wind scheme or other significant development attempt to overcome the opposition of those most affected by the proposals. The planning system must operate according to sound planning principles and policies and not be influenced by the use of “bribes”.
- The NPPF should require all new buildings to be carbon neutral and provide for substantially greater funding to be made available for schemes to increase the energy efficiency of existing buildings.
Chapter 12. The future of planning policy and plan making
105: Do you have any other suggestions relating to the proposals in this chapter?
The creation of the planning system is one of the major achievements of post war Britain. It was designed to prevent urban sprawl and is still very much needed in this regard. Unfortunately, planners are often unfairly criticised by some politicians.
In Norfolk we know that the blocking of housing development has not been caused by the planners. It is the builders who are the blockers, for example having failed to develop allocated sites for 30,000 houses in the Greater Norwich area. It is not a good idea to weaken the planning system, or to reduce the role of local communities in decision making.
- Proposals in recent years to create growth areas where planning rules would not apply must be resisted.
- The NPPF should re-introduce regional planning. This could enable the special features of an area to be recognised as important considerations in the plan making process. The relatively few remaining parts of lowland England which are still mainly rural in character, e.g. Norfolk, that act as the “green lungs” of the nation deserve better protection. Not everywhere has to be equally suburbanised – that is not good planning. Please support: reforming and strengthening the planning system to ensure that our countryside, landscape and environment are properly protected
- The NPPF should support a strengthening of community involvement in all planning decisions – local democracy is a key element in the planning process and must be respected.
