Housing delivery test: what it means for Kent

Last week’s announcement of results from the 2019 Housing Delivery Test looks at first like very dry reading, but for some Kent districts the consequences could be far-reaching.

The Test was introduced when the National Planning Policy Framework was revised in 2018. The NPPF sets high targets for the number of homes for which each area must plan, and the Test measures how well each district is doing at delivering those homes.

There is no doubt we need to build more homes, but the method for calculating the number required in each district is a blunt tool and one that takes little account of local housing needs or constraints.

The targets are based on statistical growth projections that are then adjusted to take into account the local affordability of houses.

Put simply, in Kent, where property prices are high and local full-time salaries tend to be relatively low, it means housing targets calculated in this way exceed the projected household growth and far outstrip the rates at which the building industry delivers housing.

Housebuilders only complete houses at the rate they know the local market will absorb them; there is simply no incentive for them to build any faster just to address local need.

What do the housing test results mean in practice? Across Kent, only four districts (Dartford, Maidstone, Shepway and Tonbridge & Malling) can demonstrate they are meeting these targets.

All the rest are to have sanctions applied that mean they must either demonstrate an action plan demonstrating the steps they will take to meet those targets (Ashford, Canterbury, Dover and Tunbridge Wells), or they must take steps to allocate yet more sites to build 20 per cent more homes over and above the existing targets (Gravesham, Medway, Sevenoaks and Swale).

Thanet, meanwhile, is one of eight local authorities across the country that fails the delivery test to such a spectacular degree that it is now officially required to adopt a presumption in favour of all housing development. This means that speculative planning applications which would normally never be accepted as sustainable or desirable must be, in large part, given a green light.

The irony, of course, is that local authorities are being penalised by having to allocate sites not in their Local Plan, and which are sequentially less and less sustainable, when the rate of delivery and release of homes is entirely within the hands of the development industry and beyond the control of local authorities.

It is iniquitous that local authorities – and more importantly local communities –must suffer from ever-more green spaces being allocated against targets which remain unreasonable.

This is the very opposite of good town planning.

Monday, February 17, 2020

Move quickly if you want to respond to housing consultation

Housing yes, but the right type, the right places… and the right numbers (photo by Hastoe)

Time is almost up if you want to respond to the government’s consultation on future housing provision.

The Department for Communities and Local Government document Planning For The Right Homes In The Right Places has sparked alarm across much of the South East.

Its proposed new methodology on determining housebuilding levels could leave some counties facing colossal hikes in the number of homes they are required by central government to build.

However, the burden is not being shared equally and, extraordinarily, some counties, even in the pressurised South East, could be asked to build fewer houses than previously scheduled.

Conversely, Kent is being targeted for a disproportionately large increase in the number of homes its must build.

If you think that is unfair – or indeed have any views on what the government could be about to unleash on us – you have until 11.45pm tomorrow (Thursday, November 9) to add them to the consultation.

CPRE has already responded and is encouraging others to do the same, even at this late stage.

You can do so here

For more on the consultation, see here

To read how Kent could be targeted disproportionately heavily, see here

Wednesday, November 8, 2017

CPRE Kent welcomes Medway Council attack on proposed housing hike

CPRE Kent today applauds Medway Council’s Cabinet for its withering rejection of proposed government policy that would see it face an “unrealistic and totally unacceptable increase in the levels of housing” to be built in the district.
Further, we support the council’s call for Kent and Medway MPs, as well as other local authorities in the county, to join it in expressing to central government the concerns that an increasing number of people and organisations have about the burden of housing development Kent would be expected to take.
It is telling that a Conservative-led council should offer such trenchant criticisms of the DCLG’s own policies.
After yesterday’s Cabinet meeting (Wednesday, October 25), the council released a fierce statement blasting the DCLG’s demands:
“At yesterday’s meeting of Medway Council’s Conservative Cabinet, members strongly rejected proposals from the Department for Communities and Local Government which would see an unrealistic and totally unacceptable increase in the levels of housing required within Medway,” it said.
“Independent consultants have previously determined Medway’s Objectively Assessed Need (OAN) for housing as 1,281 dwellings/year.
“This figure has been used as a core component of Medway Council’s Local Plan to assess the housing needed over the period covered by the plan (2012-2035).
“This work has already produced the ambitious figure of 29,463 homes required by 2035, [for] which the council has been tirelessly working to identify the land and infrastructure necessary to facilitate delivery.
“However, the flawed proposed government methodology would see a 29% uplift in the level of housing to be allocated to Medway, calling instead for 38,295 houses in the same period.
“The government may state that its approach represents a 5% increase across England, but there is significant variation in this figure.
“Within the South East, the average rise is an appalling 35%, yet the Conservative Group is disgusted to find that there are other local authorities who have in fact seen a fall in their level of housing need.
“Such authorities are largely in the north of England, reflecting the disjointed and disproportionate nature of this policy compared to the efforts the government has already been making to rebalance the economy and deliver the infrastructure in the north that would be able to support these homes.”
Responding to the statement, CPRE Kent vice chairman Richard Knox-Johnston said: “We welcome Medway Council’s statement as a first realistic reaction to the increased housing demand it has been allocated and the problems it will cause.
“CPRE has been saying for some time that the infrastructure is simply not sufficient to deal with the proposed new figures, while the DCLG approach does not address the real needs of young people and young families.”
Stressing further the views of his council, leader Alan Jarrett said: “Medway, like most of the South East, is an area already straining at the seams to accommodate the originally proposed level of growth, and therefore any increase to this figure will absolutely not be tolerated by Medway Conservatives.
“Whilst the Cabinet recognises the need for housing, and is already leading by example through the establishment of its own housing company, the sustainability of the government’s plan must be seriously questioned.
“Medway simply does not have the physical or social infrastructure to cope with any increased housing target. It is extremely unrealistic of DCLG to propose a change of target in the face of developers’ reluctance to build homes and a current lack of skilled workers to deliver these homes.
“Myself and my Conservative colleagues implore the three Medway MPs, and other Kent authorities and MPs, to follow suit in conveying to DCLG the severity of the concerns we have here in Kent and Medway.
“If the government were to ignore comments from this council, not only would this jeopardise the reams of work that have already gone into the production of Medway Council’s Local Plan but we face a scenario in which existing housing delivery targets will not be able to be met.
“On behalf of Medway residents, the Conservative Group will not stand idly by whilst our green spaces and our housing market are decimated.”

Thursday, October 26, 2017

Kent targeted to take huge housing hit

If government proposals are accepted, Kent will have to find room for more than 12,000 new homes a year

Kent faces taking the brunt of the government’s massive proposed hike in housebuilding levels for the South East.

This month’s beginning of a national consultation into changing the planning system in a bid to boost the amount of homes being built details a total of 3,400 extra dwellings a year – a rise of 8 per cent – on current targets across the region.

Staggeringly, two-thirds of these are earmarked for Kent, a county already having to accommodate some of the highest levels of housebuilding in the country.

If the proposals are accepted, Kent’s local authorities will need to identify enough land for 2,313 more homes a year, a 24 per cent increase on plans already in place.

The government’s proposed change in methodology is laid out in the Department for Communities and Local Government document Planning For The Right Homes In The Right Places: Consultation Proposals.

It would see a 15 per cent hike in housebuilding across the country, with London seeing the greatest increase at 79 per cent, or an extra 31,994 new homes on the capital’s current figure.

Not everywhere is expected to take more housing, however. It is suggested that the North West’s housing target is cut by 23 per cent, Yorkshire and Humberside’s by 22 per cent and the West Midlands’ by 8 per cent.

It is difficult to see how this tallies with the government’s concept of a Northern Powerhouse or indeed with the idea of reducing the focus of development on what is widely accepted to be an overheated South East, but there are further baffling aspects to the proposals even within the region.

After Kent, West Sussex is earmarked for the biggest increase, with an extra 1,290 dwellings a year, followed by Hampshire, with 1,211. Two counties, however, can breathe a sigh of relief, at least for the time being, as their proposed targets are being cut.

Oxfordshire has had its figure slashed by 1,590 a year, or 32 per cent, while East Sussex sees a cut of 1,095, or 28 per cent.

Quite why Oxfordshire, for example, facing similar development and population pressures to Kent, should see such a drastic proposed reduction in its figure while Kent, if the proposals come to pass, will be expected to build more than 12,000 houses a year, is anyone’s guess, but there is surely a suspicion that our county is being offered as a sacrificial lamb while other, arguably more fashionable, parts of the region are spared the full scale of the onslaught.

CPRE Kent Director Hilary Newport said: “The existing targets were already too high, so this latest development makes for some sorry reading.

“We absolutely accept the need for more housing, but we need to have the right types of homes in the right places. However, the higher levels proposed here will merely allow housebuilders to target sites in the countryside that will not provide the affordable housing that is so desperately needed.”

The views of delighted South Oxfordshire MP John Howell, meanwhile, are illuminating: “The new methodology…  ends the tyranny of the current strategic housing market assessment. Some areas will not see a reduction [in housebuilding targets] but, to be honest, my only interest is in the Henley area and Oxfordshire.”

Here’s hoping Kent’s MPs will be similarly focused on looking after the interests of the places and people they represent.

27 September 2017

Tunbridge Wells housing numbers too high

We have responded to the latest consultation on Tunbridge Wells local plan challenging the huge housing numbers planned which would cause severe environmental damage, loss of countryside, green space and ancient woodland.

CPRE Kent’s Tunbridge Wells committee has raised many concerns in its comments on the Issues and Options consultation.

We dispute the need to provide 650 to 700 houses per year. Given that employment growth in the borough in the 21 years from 1991 to 2013 was zero, the jobs forecasts which project an ever-rising volume of employment seem unduly optimistic and if the increase in jobs is not forthcoming, this volume of housing development could turn the borough into a dormitory for businesses elsewhere. The population and household formation forecasts on which the housing need assessment is based may also be too high.

View from Horsmonden Church by James Stringer

Committee chairman Elizabeth Aikenhead said: “Most importantly, housing development on this scale together with its infrastructure clearly cannot be accommodated in a borough with so many environmental constraints without causing serious damage to the environment.”

It is also contrary to the requirements of the National Planning Policy Framework. CPRE Kent does accept that there will have to be new development within the borough but this should continue to be at no more than the rate previously required under the Core Strategy. Even that amount of development will be very difficult to provide without serious environmental damage.

Lamberhurst in Spring by Jonathan Buckwell

Taking the proposed Strategic Options one by one, Continue reading

2017 Housing White Paper

CPRE Kent has welcomed the renewed commitment to protect the Green Belt made in today’s Housing White Paper.

We support the following initiatives:

  • Make more land available for homes in the right places by maximising the contribution from brownfield and surplus public land and regenerating estates.
  • Maintain existing strong protections for the Green Belt and clarify that Green Belt boundaries should be amended only in exceptional circumstances when local authorities can demonstrate that they have fully examined all other reasonable options for meeting their identified housing requirements.
  • Give communities a stronger voice in the design of new housing to drive up the quality and character of new development, building on the success of neighbourhood planning.


Building site 'Cox' restoration 018

Bluebells Street Scene

Bluebells Street Scene

Director Hilary Newport said: “We need this commitment to the Green Belt and other protected areas, particularly in Kent where so much of our beautiful countryside is Green Belt or in Areas of Outstanding Natural Beauty.

“We have long campaigned for a brownfield first policy and pleased to see a national commitment to this.”

Pentland Builders

Pentland Builders

Shaun Spiers, chief executive of CPRE nationally said: “We welcome the White Paper’s promise to address failings of the housing market, rather than just meddle with the planning system. Builders must build, not just sit on land. We look forward to seeing the Government’s plans to turn unused planning permissions into homes, and brownfield sites regenerated to bring new life to towns and cities.

“If the focus is on genuine need, achievable targets and good quality design that fits with the local environment, we can build the homes the country needs without losing further precious countryside.”

housing image for NPPF

The White Paper promises a further consultation on how local authorities should calculate housing need. For those concerned about our countryside, the outcome of this consultation is the acid test. Until local authorities are able to set realistic and deliverable housing targets, with an emphasis on meeting genuine need rather than aspirational demand, the countryside and Green Belt will continue to be threatened by poor quality and speculative development.

Shaun Spiers concluded:

“The Government has made a good start in this White Paper and Ministers should be congratulated for listening. It is vital that we build more homes, but it is also essential to do so in ways that have popular support. The focus on brownfield development and other measures in the White Paper will help with that agenda. We now look forward to measures to ensure that housing targets are reasonable, deliverable and focussed on affordability.”

To read the White Paper click here.

February 7th 2017.

Our fears over 4,000 homes approved for south Canterbury

The biggest housing development ever proposed in Canterbury has been approved. Canterbury City council has given outline planning permission for the 4,000-home Mountfield Park ‘garden city’ in south Canterbury. It stretches from Canterbury’s southern edge as far as the village of Bridge and includes shops, office space, sports pitches, two primary schools and a potential new site for Kent and Canterbury Hospital.


Photos: Vicky Ellis









We fear that Mountfield Park will have a severe negative impact on Canterbury. It is not an appropriate site because it will damage the visual setting of the world heritage cathedral.

Canterbury Committee chairman Dr Alan Holmes said: “The development will be on some of our best and most versatile farmland – it is vital to preserve this because we already import over 60% of our food and food security is an important issue. There are other low grade sites or we advocate prioritising development on brownfield sites.

“We also fear there will be a considerable worsening of traffic congestion, particularly on the Dover Roads, and this will in turn worsen air pollution. The Royal College of Physicians has raised concerns over deteriorating air quality as the result of traffic emissions and the serious impact this has on public health.”

To read our submissions on Mountfield Park click here and here.

November 14th 2016

Landowners can help solve the rural housing crisis

Report suggests ways to help landowners provide affordable housing for local communities

A new paper released by the Campaign to Protect Rural England (CPRE) argues that rural landowners can play a crucial role in solving England’s rural housing crisis, and sets out ways to better enable them to do so [1].

Photo: hastoe

Photo: Hastoe

Under current policy, rural landowners can provide sites at below-market prices to build housing for local people in need – but recent legal and financial changes have made this increasingly difficult. On Solid Ground shows how we could make it easier for landowners to offer their land for affordable housing, including through changes to tax legislation and to councils’ waiting list systems for social housing.

Rural communities are particularly hard-hit by dwindling affordable housing stock: 8% of rural housing is classed as affordable compared to 20% in urban areas [2]. This has seen the average age in rural communities rise as young people are priced out, and services like post offices, pubs and shops have closed as workers and potential customers are forced to move elsewhere [3]. Continue reading

Affordable home building at a 24 year low

Building of affordable homes is at a 24 year low: http://www.bbc.co.uk/news/education-38015368

In rural areas the situation is even more difficult –  housing associations are under more pressure than ever before with cuts in grants and rents and growing demand, particularly in rural areas where wages are low and few affordable homes are available. Susannah Richter talked to two rural housing associations about the challenges they face.



English Rural Housing Association tenants enjoying their homes

Hastoe and English Rural Housing Association (ERHA) are leading campaigners in rural housing. They are passionate about providing more affordable homes in villages to keep communities alive and vibrant. Both lobbied intensively to make the right to buy voluntary for housing associations (HAs) and have vowed never to sell off their village homes.

This is because it is so difficult to replace those homes and demand is growing. Only 8% of rural homes are considered affordable and incomes are far lower (average £19,700 compared with £26,900 urban). Open market house prices are 22% higher in villages than towns.

It’s a lengthy and expensive process to get rural homes built. Often the developments are small and they are almost solely on exception sites (areas outside village parameters which would not normally be granted planning permission and are therefore much cheaper than development land). The HAs work closely with parish councils, local authorities, rural housing enablers and communities to ensure the housing mix is right for the village.

Hastoe lobbied successfully on the Housing and Planning Bill to ensure starter homes would be exempted from exception sites so they remain a way for HAs to get rented homes built. “Usually there is a real sense of pride from the landowner that they are able to help and leave a legacy for their communities,” said Hastoe’s Chief Executive Sue Chalkley.

HAs used to receive a grant of up to £60,000 for every affordable rented home built. Last year that was cut to around £12,000 and this year to £0 for rented homes. Meanwhile, the Government has dictated rent cuts of 1% per year for the next five years. Both HAs have had to reduce their building programme. At its peak (2012) Hastoe was building 550 homes a year, now just 50-100. ERHA was building 70 a year and that has been cut to 30. Yet the demand in Kent is 200+ per year.


Photos: Hastoe



“This makes me really sad. So many people are working hard but on a low wage and desperately need homes for rent. They cannot aspire to buy a home but they want and need to live in their communities,” said Sue Chalkley.

Alison Thompson, Senior Regional Housing Manager at ERHA, explained that they now have to include some open market properties in developments to cross subsidise the costs. “It’s not all doom and gloom though and has in fact presented opportunities,” she said. “We are meeting a new need and have built small bungalows for older people wanting to downsize but stay in their village. Plus, we are being innovative – we are offering some self-build plots which reduces the risk to us and again meets a need and we prioritise selling them to local people.”

Affordable homes are vital for communities to thrive. Without them, families will move to cheaper properties in towns and then the lack of demand within the village can lead to the closure of schools, village shops, pubs. As it is, the number of people aged 30-44 fell 9% over the last decade, many moving to towns after being priced out of their communities.

Sue Chalkley: “I can’t see how villages will survive. Local employers won’t be able to find employees, the facilities will have gone and there will just be affluent older people driving out of the village.”

One example of the need for younger people was in Charing where the fire station was under threat of closure as there was a shortage of retained firefighters. When ERHA built a development, one of the first tenants was a young man who became a retained firefighter, demonstrating just how much impact affordable homes can have.

“We need a mixed community to keep our villages alive,” said Alison Thompson. “Our homes really are a lifeline. Some people have been living in cramped conditions, with parents or in mobile homes, and are desperate for their own home in the area they grew up in or work. One new tenant said she felt like she’d won the lottery the day we handed her the keys.”

To be eligible for a HA home, people need to have a strong connection to the village and be on a relatively low income (in most cases less than £30,000 a year). They then get an affordable rent (80% of market value) and, vitally, security of tenure.

Despite initiatives like the right to buy, shared ownership and starter homes, many people will never be able to afford their homes. Here in Kent our housing associations are safeguarding their stock to ensure it is available for future generations. This will allow people, particularly young families, to live and thrive in their village communities and, we hope, maintain vibrant, active and working villages with a mixture of age groups and income earners.

November 18th 2016

Safe under us?

Safe under us report coverA report, published today, shows how government housing and planning policies have led to an unprecedented scale of threat to London’s Green Belt

The London Green Belt Council and CPRE London have published a joint report “‘Safe Under Us?’ An investigation into widespread threats from housebuilding in the London Metropolitan Green Belt”

The report shows that government policies and sanctions appear to be forcing councils to release Green Belt land for development.

Drawing on local evidence provided by CPRE branches in Bedfordshire, Berkshire, Buckinghamshire, Essex, Hertfordshire, Kent, London and Surrey, the report demonstrates that the London Green Belt is likely to be under greater threat than ever. There are now plans for 203 sites within the London Green Belt including proposals for 123,528 homes.  Within the 42 local planning authorities that were surveyed covering nearly 84% of all London Green Belt land, the majority of the proposed homes (94%) are on sites allocated by councils in their Local Plan documents. The London Green Belt is also under pressure from infrastructure such as schools and roads.


Lullingstone Park, photo by Susan Pittman

Lullingstone Park, photo by Susan Pittman

The report finds that there is national pressure being applied to Local Planning Authorities to deliver inflated housing targets. These targets are being inflated by unrealistic economic growth forecasts, forcing councils to give up Green Belt land.

Continue reading

We need affordable rural homes

This week is #RuralHousingWeek and we have been considering some of the issues and challenges rural communities face when it comes to housing.

Photo, Hastoe

Photo, Hastoe

We firmly believe that genuinely affordable housing is the bedrock of a thriving, living countryside,
but we are troubled by the fact that house prices are seven times average earnings in rural areas,
compared with 5.9 times in urban areas.
Rural vs Urban
In fact in Sevenoaks average house prices are 10.5 times average salary and in Tunbridge Wells 10.3 times.
Agricultural and other rural workers’ annual earnings are far lower (average £19,700 compared with £26,900 urban) which makes it even more difficult for people to live in the villages where they grew up or where they work.
CPRE is calling for:
  • Local communities should be empowered through neighbourhood planning while housing policy should be “rural proofed” to deliver what the countryside needs: high-quality, affordable housing.
  • The government must ensure rural areas, including areas of natural beauty and national parks, are exempt from the forced sale of council homes.
  • Empower small and medium-sized enterprise builders with local knowledge to provide affordable homes in rural areas.
  • The Government must focus on the delivery of the right housing in the right places.

Shepway’s Otterpool Park – huge intrusion on landscape and villages

Shepway District Council (SDC) has announced plans for a “Garden Town” which would engulf Westenhanger, Newingreen, most of Lympne and some of Sellindge, together with up to 700 hectares (1730 acres) of countryside, bordering on the Kent Downs Area of Outstanding Natural Beauty.

Somehow, the council expects local residents to support this while the leader, Cllr David Monk, answers his critics with words like “It is not green space. Most of the time it’s brown, it’s mud, brown mud. It’s cockalooloo land. It is agricultural fields. You can’t say we can’t build on fields. It hardly affects anyone.” (quoted in Folkestone Herald 12/5/16).

Sheep in fields at Otterpool

Everything in this view, as far as the windmill (white tower), would be urbanised, photo by Graham Horner

CPRE fought hard to halt the urbanisation of this area through the examination of Shepway District’s Local Plan and the inspector agreed with us, throwing out proposals for just 400 houses on the Folkestone Racecourse site.  Now up to 12,000 houses are contemplated in the same area.  Shepway seem intent on filling up all land which is not AONB or on the Marsh with housing or allowing it to be concreted over for lorry parks.

Hilary Newport said “The garden city/village principles have merit, but CPRE believes that housing delivery should focus on putting effort into the regeneration of those brownfield sites that blight urban areas and communities. This site, by contrast, is in open countryside, near villages that are already struggling under the pressure of overdevelopment, and would be a huge intrusion on the landscape – indeed the Kent Downs Area of Outstanding Natural Beauty (a nationally important designation, equivalent in importance to a National Park) surrounds this area on three sides: walkers and riders on the North Downs Way national trail to the north would have their views across open landscape blighted.”

Otterpool Park 4 Otterpool Park 2


Photos by Graham Horner

May 16th 2016.

The housing crisis – a builder’s view

The following article by Susannah Richter appears in the latest edition of Kent Voice. We would be interested in your feedback.

Unrealistic housing targets are putting more pressure on the housebuilding industry than ever before. In Kent, the total 20-year figure is 158,500 new homes, with recent objectively assessed housing need of 18,560 in Maidstone, 15,600 in Thanet, 16,000 in Canterbury and 29,500 in Medway. The industry is dominated by the big companies, so what are the barriers faced by small and medium sized builders and can they provide solutions to the housing crisis?
Pentland Homes was set up by landowning farmers in the 1970s and now builds around 100 homes a year, up from just 30 during the recession five years ago. Most of its development sites are brownfield (79%) – including empty schools, a disused factory, a former pub and MoD land.
But Managing Director Martin Hart says brownfield sites are complicated: “Firstly, they are bought at risk because we don’t know what problems we may find. We are currently building on the site of an old potato packing plant at New Romney which was entirely concreted over – we didn’t know what to expect when we removed the concrete. If something untoward was found, a small company could go bankrupt on just one unlucky brownfield buy.

Martin Hart

Martin Hart

Pentland Builders

Pentland Builders

“Secondly, if a site has been brownfield for a long time it often has greater ecological value than greenfield land which has been ploughed and treated. We have to get ecologists involved and it can be costly if we need to move or provide for species or could even prevent planning permission. Either way it will cause delay – again something many small building companies cannot afford.”
This is exactly what happened at Lodge Hill, a former army camp in Medway identified for 5,000 homes. Over the last 20 years it has become home to 1.3% of the national nightingale population as well as bats, great crested newts, toads, lizards, slow worms, grass snakes and adders. This will be the subject of an interesting planning inquiry. Continue reading

Important meeting on Maidstone Local Plan

Great public meeting last night (11th February) on the Maidstone Local Plan

Lots to hear about gridlock, urban sprawl, sustainability and loss of greenfield and farmland from 18,560 new homes. We think unrealistic housing targets based on flawed numbers threaten our countryside: see the CPRE report Set up to Fail by clicking here.

set up to fail
Chaired by BBC Radio Kent’s John Warnett, over 200 concerned people turned out to hear MPs Helen Grant and Helen Whately and councillors as well as CPRE Kent.


Concern over planning reforms

The Government this week (Monday 7th December) published a consultation proposing a raft of new changes to the National Planning Policy Framework (NPPF).

We welcome the presumption in favour of brownfield housing development  which would make it clear that development proposals for housing on brownfield sites should be supported, unless overriding conflicts with the local plan or the National Planning Policy Framework can be demonstrated and cannot be mitigated.

However we are very concerned about some of the other proposals.

In particular, a new ‘housing delivery test’ (paras 27-33) will likely lead to more green fields being released for development as councils either plan for more development in advance or have to find new sites to develop when existing targets are not met. We believe that the ‘delivery test’ in its proposed form will allow developers to cherry pick greenfield sites instead, letting the brownfield sites go to waste.

Lullingstone, photo by Susan Pittman

Lullingstone, photo by Susan Pittman

The proposal to encourage new settlements (para 19/20) is also concerning – the area required for entirely new settlements is far greater than that required for just the housing. Councils are already encouraged in the current NPPF to bring forward new settlements. The proposed new policies could serve to force local people to accept large speculative schemes in unsuitable places that had been previously rejected in recent local consultations.

The idea of more quickly bringing forward development on brownfield sites in the Green Belt was trailed in the Spending Review. We believe each case must be considered carefully as brownfield in the Green Belt often contains valuable open land and open parkland that should not be developed. Paragraph 49, meanwhile, suggests that councils will be able to designate parts of the Green Belt for small developments of ‘starter homes’, entertaining the possibility of urban sprawl and drawing focus away from brownfield sites that have connections to existing infrastructure and amenities.

CPRE will be submitting a response to the consultation, the submission date for which is the 25 January 2016.

Paul Miner, planning campaign manager at the Campaign to Protect Rural England, said:

“This consultation is really concerning. Instead of addressing the current difficulties in bringing forward the right sites for the right homes, it proposes to release yet more land for development, often in the countryside and possibly in the Green Belt.

“The current policy isn’t working, but these proposals will make things worse. Releasing unlimited amounts of greenfield land will not deliver the Government’s welcome pledges to regenerate brownfield sites.”

December 9th 2015

Continue reading