CPRE Kent has commented on the consultation on changes to the National Planning Policy Framework which covers the following broad areas:
- Broadening the definition of affordable housing. We believe the inclusion of starter homes within the definition of affordable housing raises significant concerns about the availability of properly affordable homes for rent or intermediate ownership in our rural areas. This impact will be even more pronounced if ‘right to buy’ is extended, and the new starter homes are not retained in perpetuity for people with a local connection.
- Increasing the density of development around commuter hubs. We agree with the principle of higher density around commuter hubs, but a lot more work needs to be done to define what a commuter hub is, and to ensure that the location has access to a range of services.
- Supporting sustainable new settlements, development on brownfield land and small sites, and delivery of housing agreed in Local Plans. Due to the settlement pattern in Kent, and the reductions in staff and resources in local authorities, new settlements are unlikely to be appropriate. We do support, however, a strengthening of policy to encourage development of brownfield sites in sustainable locations and where they are not of high environmental value. Unintended consequences of changes to policy are, however, an issue and we are very concerned about the proposals to strengthen the policy on small greenfield sites for housing. A presumption in favour of small urban edge sites, for example, will be harmful to the setting of our settlements and the delivery of exception sites for affordable homes.
- Supporting delivery of starter homes. We believe there are a host of potential unintended consequences by setting an unrealistic time limit on the retention of land for employment uses. The uptake of employment land can be very cyclical and councils need to be able to plan for the future. Balance is key and although some employment sites might be suitable for delivery of starter homes, Council’s need to be able to protect land, if necessary, from higher value uses. It is essential that brownfield land in the Green Belt can be classed as ‘inappropriate’ if development would damage openness or land of high environmental value.
You can read our full response by clicking here.
February 22nd 2016.