We’re looking for people to join us as assistant planning volunteers… can you help?

CPRE Kent is expanding the team

Do you want to help protect the Kent countryside from ever-increasing development pressure?

CPRE Kent, the countryside charity, is strengthening its efforts to keep the county beautiful and expanding its team across the county. It is looking to take on assistant planning volunteers to help act as our eyes and ears across Kent and Medway.

Dr Hilary Newport, CPRE Kent director, said: “The rural environment of Kent is under siege as never before. We campaign hard for both the protection of our countryside and the appropriate levels and types of housing that local people need.

“At the moment, sadly, we are seeing eye-watering levels of housing that respect neither our countryside nor our residents, many of whom are still finding it impossible to get a foot on the housing ladder.

“Anyone in the county who would like to join us in our fight for all that is good about the Kent countryside is very welcome to get in touch.”

If you are interested in any of the above roles or simply in the work of CPRE Kent, you can email info@cprekent.org.uk, phone 01233 714540 or visit the website www.cprekent.org.uk/about us. You can also find the charity on Facebook and Twitter.

Monday, June 20, 2022

Planning and the countryside: FAQs

Featured

Tackling the planning system can sometimes appear a nightmarish proposition for even the best-informed. So our planning experts at CPRE Kent have got together to produce an FAQs (Frequently Asked Questions) guide to planning and wider countryside issues. You can read it here

Laying the building myth to rest

And the build goes on… but it’s not of much use to local people wanting a home

In this concerning piece, Richard Thompson, CPRE Kent planner, spears the ridiculous notion that simply building more houses will make them more affordable. He highlights that this concept underpins the standard methodology for calculating housing, which, if left unchallenged, will lead to yet more sacrifice of greenfield land to unaffordable market housing without the needed delivery of truly affordable housing.

An article published in the county’s media as winter drew to its close highlighted the absurdity of government thinking that private-sector housebuilding alone would solve the housing affordability crisis.

The fact is, while ever-more houses are being built, the gap between house prices and earnings is still increasing, while much-needed affordable housing is simply not being built.

A stark example of this national policy failure at the local level can be found by looking in detail at the provision of affordable housing in the Canterbury district over the last 10 years.

Within Canterbury district, the average cost of a new-build dwelling has increased from £160,476 in September 2011 to £317,381 in September 2021. That’s almost a doubling of prices in 10 years.

Unsurprisingly, this market price is not affordable for most Canterbury residents. In fact, Canterbury City Council itself considers an income of more than £75,000 would be required to buy a house at this price without assistance.

It believes this equates to only 2 per cent of the population of Canterbury. Or, put another way, 98 per cent of Canterbury residents cannot afford a new-build home on the open market in the district on their incomes alone. Assistance therefore comes via affordable home-ownership ‘products’ such as Help to Buy and shared-ownership schemes. These all fall within the formal planning definition of affordable housing as set out in the National Planning Policy Framework (NPPF). However, many of these affordable home-ownership products are still not actually affordable to most Canterbury residents.

The table below assesses each of the different affordable home-ownership products against the income required to afford them and then considers what percentage of the district would not be able to afford these products.

Affordable Home Ownership Options SchemeIncome RequiredHouseholds Unable to Afford (all households)Households Unable to Afford (private renters)
Help to Buy: Equity Loan (20%)£67,01895%98%
Help to Buy: Shared Ownership (50%)£60,41993%97%
First Homes (30% discount)£52,56790%94%
Help to Buy: Shared Ownership (25%)£50,79090%93%
Rent to Buy (80% of median rent)£23,32332%46%

Yes, you have read correctly – it is the council’s own assessment that 98 per cent of Canterbury residents who currently rent are considered unable to afford the government’s flagship Help to Buy: Equity Loan scheme. Across all the schemes, at best, only 54 per cent of current renters would be able to afford the ‘cheapest’ rent-to-buy route to home ownership.

For those left, the only option is to rent. However, paying open-market rents is deemed unaffordable for 45 per cent of households in Canterbury.  

For this group, there are two types of rental products that fall within the formal planning definition of ‘affordable housing’. The first is affordable rent, which in Canterbury is some 86-97 per cent of the cheapest market rents, ie not necessarily that affordable and subject to usual market price rises. The second is the social rent, which is set according to a complex formula but is typically between 50 per cent and 60 per cent of market rent. This is the cheapest route to accommodation and in Canterbury is about £435 a month.

It is unsurprising then that the council considers the most pressing affordable housing need for Canterbury is for the genuinely affordable social rent homes. It considers 231 social rent homes are now required a year. There is then a lesser need for affordable home-ownership products (156 required a year) and then affordable rent homes (77 required a year). In total that’s 464 affordable homes required a year in Canterbury.

However, Canterbury City Council, like most Kent councils, does not generally build houses. Rather, the current model is that a developer is expected to use a small proportion of the financial gain it gets from a grant of planning permission to provide a certain number of affordable houses alongside the market houses it sells. In Canterbury, the target is that 30 per cent of all homes built should meet the NPPF planning definition of affordable (though until 2017 was set at 35 per cent for the Canterbury Urban Area).    

So how many affordable homes have been provided in Canterbury under this model over the last 10 years? The next table sets out how many of each type of affordable house has been built over this period and quite clearly shows it to be nowhere near enough.

YearAffordable rentAffordable home ownershipSocial rentTotal
2011/12183393144
2012/13105358121
2013/1410105070
2014/15400040
2015/162030050
2016/173810048
2017/18936045
2018/191937056
2019/20405544139
2020/213522057
Total239286245770

That’s barely a current year’s requirement of social rent homes built in total over the last 10 years. Amazingly, in six out of 10 years not a single social rent home was built. With an overall total of 6,097 new homes having been built within the Canterbury district across this period, that equates to 12.6 per cent affordable homes built across all types against the target of 30-35 per cent.     

So why are the required affordable houses not being built by the development industry? For many, the main reason is that current government policies allow levels of affordable housing to be reduced if a development is not deemed ‘viable’.

In the simplest terms, a development is not deemed viable if it can be demonstrated a developer would make a profit of less than 15-20 per cent once all set costs are accounted for. Significantly, one such set cost is an agreed premium to buy the land by the developer that is usually 20 times the existing value of the land though can be as much as 40 times! Added to this, the greater the perceived need for housing, the lower the ability of the council to negotiate, particularly if the council is subject to the ‘tilted balance’ presumption in favour of granting planning permission.

While the intricacies of viability appraisals are a topic of concern in themselves, the fact is housebuilder profits are soaring all the while the current system is not delivering affordable homes on the ground.

In 2021, when not a single social rent home was built in Canterbury, the four biggest UK housebuilders – Persimmon, Berkeley, Taylor Wimpey and Barratt Homes – reported pre-tax profits of £784 million, £504 million, £492 million and £264 million respectively.

If we delve into this a little deeper, we can see it is developer profit margins alone that have soared over the last 10 years, with the costs of buying development land and cost associated with physically building houses broadly staying the same. This can clearly be seen in the below chart taken from housebuilder Persimmon’s 2021 financial results presentation dated March 2, 2022. The chart gives a total cost breakdown of an average Persimmon new-build home showing that the gross profit element has gone from accounting for £20,763 of the cost of a new-build house in 2010 to £74,481 per house in 2021. That’s more than a tripling of profit margins.            

Despite this, the development industry maintains the problem is simply that not enough homes are being given planning permission. The argument goes that if they were given more permissions to build more houses, then of course more affordable houses would be delivered and market housing would become more affordable.

While the above record in Canterbury suggests otherwise, this argument is flawed for other reasons.

For starters, it can be argued that there is already sufficient planning permission or land available to build on. In Canterbury, there is either an existing planning permission or an identified Local Plan land allocation for 12,334 new homes. Specifically with respect to affordable housing, as of March 2021, there were 1,757 social/affordable rental units with permission in the pipeline. This is more than double the number of affordable homes built in Canterbury over the last 10 years. Despite this, Canterbury has just failed the government’s Housing Delivery Test for not building enough houses, meaning the district is now subject to the presumption that planning permission will be given even if in conflict with the adopted Local Plan. As has been pointed out by CPRE Kent, this is absurd.

There is also the small matter that housebuilders are quite simply not going to build at a level that over-supplies a local housing market, forcing them to reduce prices and lower profits.

The absorption concept was most recently highlighted by Sir Oliver Letwin in his government-commissioned independent review of buildouts. Here he found the “fundamental driver of buildout rates once detailed planning permission is granted for large sites appears to be the ‘absorption rate’ – the rate at which newly-constructed homes can be sold into (or are believed by the housebuilder to be able to be sold successfully into) the local market without materially disturbing the market price”. Alongside this, there are practical constraints such as the current labour and materials shortages.

However, and perhaps most significantly, it is housing market demandrather than need that drives affordability. Currently this demand is being fed as much by monetary policy and financial markets as by physical shortages. Low interest rates and readily available mortgage credit, coupled with state assistance policies such as Help to Buy equity loans, are arguably allowing those already in the position to buy a house to offer ever more. They are often bidding against others in a similar position, pushing the market prices up in the process. Meanwhile, those not already in a position to buy get left even further behind.

So why does this matter?

At the superficial level, CPRE Kent and other similar organisations are often accused of denying local communities much-needed housing when we object to yet more greenfield land being lost to market housing. Taking the Canterbury example, however, the council itself is accepting the new-build market housing dominating the supply is simply not affordable to most existing residents in the district. For those existing residents, they are losing greenfield land important to them to satisfy a wider market demand rather than for their direct benefit.

At the far more important level, though, this matters because the government’s current standard method for calculating how many houses a district needs is linked directly to housing affordability within that district. That is, the bigger the gap between new-build house prices and median earnings in a district, the higher the housing number for that district is. And the government rationale for this is that by building more houses, the cost of housing will come down…

This problem is increasingly urgent. The government affordability data are released on an annual basis, with the 2022 data due on March 23, just before we went to print. On release of these data, housing targets for each council can change overnight. With it reasonable to assume that the gap between house prices and earnings is likely to have widened over the last year for much of Kent, the consequences for the county could be dire.   

The need to revisit the standard methodology for calculating housing is urgent. The need to rethink how we deliver truly affordable housing in a way that doesn’t sacrifice greenfield land to bolster developer profits is arguably even more urgent.  

‘Affordable housing’ schemes

The formal planning definition of affordable housing is set out in Annex 2 of National Planning Policy Framework (NPPF) and, at almost 500 words long, is rather complicated and hard to understand.

The below non-exhaustive list, however, sets out the most popular schemes that currently fall within this formal planning definition of affordable housing:

Type or tenureDescription
Social rent  These properties are provided by local authorities and some registered providers. The rent for these properties will be set at a level dictated by the national rent regime. Social rented properties are the most affordable and what people usually understand as being meant by ‘council housing’.  
Affordable rent  These properties are provided by local authorities and registered providers and are subject to a control that in theory requires the level to be no more than 80% of local market rent. In practice and, as demonstrated in Canterbury, this is not always the case.  
Shared ownership  Previously known as ‘part buy, part rent’, households buy a share of the property and the remaining share is rented. In time, future shares can be purchased and the property could be bought outright/subsequently sold at market rates (though some restrictions might apply in very limited circumstances).  
Shared equity  The applicant purchases a share in the property and no rent is paid on the remaining share, but the purchaser is able to buy further shares in the property until it is owned outright. The house can subsequently be sold at market rates.  
Help to Buy equity loan  The government provides households with an interest-free loan of 10% or 20% of the cost of a new home for a period of five years; purchasers require a mortgage and at least a 5% deposit. The house can subsequently be sold at market rates  
First HomesFirst Homes is a new scheme designed to help local first-time buyers and key workers on to the property ladder by offering homes at a discount of 30% compared with the market price. It is intended that the discounts will apply to the homes forever.  
Build to Rent and Rent to Buy  These properties are usually built as blocks of flats. The property is rented for a set period during which time the tenant saves enough for a deposit to purchase the property at the end of the rental term.  

References

[1] www.kentonline.co.uk/kent/news/32-per-inch-who-are-pricey-kent-new-builds-for-261858/

[2] UK House Price Index – HM Land Registry Open Data

[3] Canterbury City Council Housing Needs Assessment 2021 –https://drive.google.com/drive/u/0/folders/1BCdWC6ME7X_b6szgA1E5knDlsta1ooTY

[4] again taken from the September 2021 Canterbury Housing Needs Assessment

[5] See – https://lichfields.uk/media/6509/fine-margins_viability-assessments-in-planning-and-plan-making.pdf

[6] Canterbury Authority Monitoring Report 2020-2021

[7] Sir Oliver Letwin’s final report – www.gov.uk/government/publications/independent-review-of-build-out-final-report

Thursday, May 5, 2022

‘A powerful and memorable campaign’: CPRE wins award for response to planning proposals

CPRE, the countryside charity, was part of a broad coalition of 18 organisations that worked together to produce an alternative ‘Vision for Planning’ in response to the government’s Planning White Paper

CPRE has broken new ground and won an award for its campaign responding to the government’s proposed reform of the country’s planning system.
Our first award for campaigning and policy work in living memory was announced on Wednesday, November 24, and represents a striking triumph for the combined national and local approach of CPRE.
The annual PRCA Public Affairs Awards recognise the finest organisations and individuals operating in public affairs.
Clarifying why CPRE beat other big names such as Transport for London in our category, the judges said: “This was a powerful and memorable campaign, which received solid support and strong messaging and ultimately exposed the failings of the Planning White Paper – and certainly did get the government to think again.”
As ever, the efforts of people at every level of CPRE have been highlighted. We can’t do it without our supporters – if you’re one of them, thank you!

  • For more on this campaign, see here

Tuesday, November 30, 2021

‘A victory for common sense’: CPRE responds to reported rethink of planning reform

Tom Fyans: ‘The devil is in the detail’

It has been reported in The Times this morning (Saturday, September 11) that the government is planning to abandon substantial parts of its planning proposals, including the zonal planning system.
If correct, this will be a huge win for the CPRE planning campaign, so fingers crossed!
Commenting on the reported rethink of the planning proposals, Tom Fyans, deputy chief executive of CPRE, the countryside charity, said:  “The devil will be in the detail, but it looks as though some of the most damaging proposals of what was a top-down developers’ charter have been rightly binned. However, the government must not shy away from overhauling a tired planning system to make it fit for the multiple challenges of the 21st century.
“Local communities need a stronger right to be heard in local decisions; brownfield sites must automatically be developed first to help protect local green spaces and our Green Belts in the fight against climate change; and young people and key workers desperately need more funding for rural affordable homes.
“Positive changes to the planning system are long overdue – in future it is vital local communities are empowered to protect their precious green spaces while delivering the affordable homes they desperately need and, at the same time, responding to the climate emergency by regenerating the countryside.
“This decision by ministers is a victory for common sense and local campaigners all across the country who just wanted a proper say on the needs of their communities and how their area should be developed.
“We look forward to working with the government on creating a planning system that puts the needs of local communities ahead of developers’ profits.”

Saturday, September 11, 2021

Coming your way: more development but not more doctors or school and nursery places

‘The new developer asked MBC whether it would require a new planning application. Amazingly, it was told it did not.’

CPRE Kent is dismayed to learn of a decision by Maidstone Borough Council officers, outside the scrutiny of elected councillors, that results in a loss of £469,000 necessary infrastructure funding promised to a local community. 
The story began when MBC approved the building of 53 houses on the non-allocated greenfield site of Loder Close, Lenham, back in 2019. Concerns were raised at the time by the county council and residents that this development would place unfunded pressures on local infrastructure.
These concerns were dismissed, with elected councillors being promised within the cabinet report that the development “will provide reasonable and appropriate contribution to other infrastructure by CIL payments”.
Except it turns out this advice was wrong.
Fast-forward to March 2021 and, after a change of developer, the plan had now changed, with more affordable housing being provided. The new developer asked MBC whether it would require a new planning application. Amazingly, it was told it did not.
This is amazing is because it exempts the developer from making any infrastructure payments. This includes £159,00 the county council said was required for additional primary-school places and £197,000 it has identified as necessary for new secondary-school places, as well as contributions towards community learning, youth services, the library and social services. This included up to £50,000 that would have otherwise come to the local parish to spend on a much-needed and now-delayed pre-school.
While CPRE Kent clearly supports the need for genuine affordable housing, we ask ‘Won’t those future occupiers also require doctors, school places and other community facilities?’.
With the rights and the wrongs of this decision remaining open to debate, CPRE Kent is heartened to see Lenham Parish Council continuing to challenge MBC on this. There is, however, a much wider picture to be addressed.  
That is development being forced on communities without the necessary community infrastructure being secured or provided. That is plans being changed that clearly impact on communities, though without further democratic input being sought from that community. That is the fact that current rules allow for any type of residential development being approved without having to make a fair contribution towards already overstretched community facilities.
Overall, Loder Close represents a clear example of why communities do not trust developers or councils when they promise future infrastructure impacts will be “mitigated”.      

Tuesday, August 10, 2021

Canterbury: the council cornering itself into a position where 20th-century solutions are being applied to 21st-century issues

Much of the still-beautiful environment of Canterbury and its countryside will be lost if the city council follows its ‘preferred option’

The deadline for comments on Canterbury City Council’s public consultation on its preferred option for its new Local Plan closes at 9am on Monday, August 9. The deadline has been extended by a week in response to glitches with the council’s online consultation portal.
CPRE Kent has submitted comments on behalf of its members objecting to the council’s preferred option of building 14,000-17,000 homes – which is 8,000 more than required under the government’s standard methodology for calculating housing numbers, for the period to 2040.
We have advised the council that a careful balance needs to be struck between taking economic advantage of Canterbury’s heritage and undermining it with too much and with inappropriately sited development.
Unfortunately, like many of the residents in the Canterbury area, we have had difficulty interpreting the full implications of the council’s development proposals.
The written summary details for the preferred option makes no reference to the provision of the proposed two new roads/bypasses – to the north-west and south-east of the city – referring obliquely to “upgrade of the A28 to allow traffic to bypass the city centre” instead.
CPRE Kent has questioned whether addressing congestion and pollution on the ring road by building a pair of bypasses will be effective – bearing in mind that it would appear that a high proportion of this traffic is generated by local people travelling into Canterbury for work, leisure, shopping and education.
Building up to 8,000 more dwellings than required to fund a roadbuilding programme to bypass the city centre will, CPRE Kent believes, place undue burden on local communities, the countryside setting of Canterbury, the Area of Outstanding Natural Beauty and surrounding Areas of High Landscape Value.
We have pointed out to the council that development to this degree would have an adverse impact on dark skies, tranquillity and best and most versatile agricultural land – which has a vital role to play in absorbing carbon and preserving biodiversity, including the biodiversity in soils. Once it is built over, soil biodiversity is lost. 
Sadly, the council seems to have cornered itself into a position whereby 20th-century solutions are being applied to 21st-century issues.

  • To learn more and contribute to Canterbury City Council’s consultation on the Local Plan, click here
  • To read more about development pressure and planning in Canterbury, click here

Tuesday, August 3, 2021

The revised NPPF is out! Not bedtime reading maybe, but it’s going to play a big part in planning policy

This year’s NPPF consultation focused largely on design codes and ‘building beautiful’

A revised version of the National Planning Policy Framework has been published this month (July) – see here.
The new incarnation follows this year’s consultation, which focused primarily on incorporating design codes and building-beautiful recommendations.
The full government consultation response can be found here, while the original comments made by CPRE to the consultation are here
The changes are largely incremental and as anticipated though are to be formally applied from the date of publication (Tuesday, July 20) for both Local Plans not yet at examination and planning decisions.
For immediate practical purposes, all paragraph numbers from paragraph 53 onwards have now changed – here is a tracked version illustrating the differences between the February 2019 version of the NPPF and this latest edition.

  • For more on the NPPF, see here

Thursday, July 29, 2021

Thanet council proposals to charge public in planning process: we question lawfulness, lack of democracy and equity

Thanet council plans to charge a fee to process public comments it deems long and complex

A consultation on Thanet District Council’s Statement of Community Involvement closed last week – and CPRE Kent is less than impressed.
A Statement of Community Involvement sets out how a council intends to engage the local community and others in planning matters. It is an important document that should help ensure that planning process is fair, open and accessible to all.
Or not, in the case of Thanet.
While CPRE Kent made several comments on the detail of the document, it is TDC’s intention to charge a fee to process public comments that it deems long and complex that has caused us most concern.  
Not only do we question the lawfulness of this, but we also point out that it is undemocratic and potentially discriminatory.
We have called for this proposal to be removed from the document. If it is to remain, as a minimum we have asked for the basis on which the charge is deemed lawful to be reported back to members.   
The outcome of the consultation, along with any resulting changes, will shortly be reported back to Thanet council members before formal adoption.
We will be watching the response very closely.

  • For more on Thanet planning issues, click here

Monday, April 12, 2021

Decisions, decisions: how does planning work during the pandemic?

Planning by remote in the 2020s…

The Covid-19 crisis has curtailed public involvement in almost all aspects of life, so it is important for us all to see that fairness and the democratic process do not suffer as a result, as a CPRE planner explains

Are you still getting your say at planning committee?
Since Saturday, April 4, 2020, councils have been able to hold public meetings virtually – using video or telephone conferencing technology – hence removing the requirement for physical attendance at meetings.
The decision was announced by Robert Jenrick, Secretary of State for Housing, Communities and Local Government, to in a bid to ensure effective local decision-making and transparency during the coronavirus pandemic.
Did you know that not all planning (and other) applications must go before councillors at a committee meeting? 
Under the 1972 Local Government Act, local planning authorities can discharge some decision-making to an officer – in the case of planning applications this is what is commonly known as a delegated decision.
Planning permission can still be granted (or refused) for individual schemes. The only difference is that, compared with a committee decision, the process is faster because there is no need to wait until the next planning committee comes round.
As it is up to individual councils to draw up their own delegation scheme, decisions that can be delegated in one authority may not in another.
Unless a local planning authority has changed its delegated scheme, all planning decisions that would normally have gone to a planning committee continue to do so.
While the decision-making format will not have changed, it is possible that meetings may have been cancelled in the early days while councils made the necessary arrangements to move committee meetings online.
It might not be the same for all councils, but I know one Kent authority minutes at the beginning of each session that meetings are being conducted in accordance with the Local Authorities and Police and Crime Panel (Coronavirus) Flexibility of Local Authority Police and Crime Panel Meetings (England and Wales) Regulations 2020 No. 392.
And that in welcoming councillors and members of the public the chairman states which council officers are in attendance.
The procedure for my local council is that members of the public are advised in the normal way of the committee date for schemes in which they are interested.  As usual, the procedure for speaking at committee is explained. In accordance with the regulations, interested parties are invited to dial in to the meeting and, where pre-arranged, get to speak for their allotted time.
In addition, participants are asked to provide a written copy of the statement they wish to make so that in the event of technical difficulties their views can be read out.
At this specific council, members of the public can not actually see what is going on at the meeting (they dial in by phone). Any papers that are likely to be viewed by councillors at the meeting are added to the council’s website in advance.
Audio recordings of the meetings held are posted on the council’s website within 10 days of the meeting.

Tuesday, February 24, 2021

Swale says it’s a listening council. Now it has the chance to prove it

CPRE Kent and others have raised deep concerns regarding the lack of consultation undertaken by Swale Borough Council on its Local Plan. 
We therefore welcome the recommendation to councillors to extend the current consultation until Friday, April 30. This is to be considered by all council members tomorrow evening (Wednesday, February 24).
However, as it stands, there is no formal requirement for the outcome of the consultation to be reported to councillors prior to the Plan being submitted for independent examination.
This is why we have today written to Swale councillors urging they consider the consultation responses before making a final decision that the Plan is ready for formal submission.
In the report to members accompanying tomorrow evening’s recommendation, Swale describes itself as a listening council.
This simple positive step is the least that they can do to demonstrate this.

  • For more on the Swale Local Plan, see here

Tuesday, February 23, 2021

Surprise, surprise! Kent’s environment suffers the failings of flawed government planning policy

The diggers and cement-mixers could be coming your way… but only if it suits the developers

Richard Thompson, CPRE Kent planner, shows how developers benefit from their own failure to build houses while our communities lose ever more green space

While the Housing Delivery Test might seem a dull and dry topic, often buried in the darkest, deepest recesses of a council’s website, its consequences should not be ignored. 
When CPRE Kent reported on the 2019 Housing Delivery Test results, it was a bleak picture. Well, last month the 2020 Housing Delivery Test results were published. And the situation for Kent has worsened yet further.
The test works by comparing how many homes have been built in each council district against how many homes the district is deemed to have needed over a three-year period (though reduced this year for a month to allow for the impact of the Covid-19 pandemic). 
These homes-needed figures will either come from a council’s Local Plan if it was adopted within the last five years or, more commonly for Kent, be based on the government’s ‘top-down’ standard method formula for calculating housing numbers.
If at least 95 per cent of the homes deemed needed have been built within a council’s district over that period, the council is regarded as having passed the test.
More than 85 per cent though less than 95 per cent, the council is put on the naughty step and has to write an ‘action plan’ in which it promises to try harder.
If less than 85 per cent though more than 75 per cent, the consequences become serious as an extra 20 per cent is added to the number of homes that will need to be built in that district. This makes it increasingly hard for councils to demonstrate they have a five-year supply of houses – and where a council cannot demonstrate a five-year supply it becomes subject to the “presumption in favour of sustainable development.
If fewer than 75 per cent of homes deemed needed have been built, that council area automatically becomes subject to the “presumption in favour of sustainable development. This means that if a site can be considered to deliver ‘sustainable development’, then planning permission should be granted, even if there is no support from the council for housing in that location or the site sits outside the Local Plan.
As set out in the table below, the combination of the 2020 Housing Delivery Test results and accepted lack of five-year supply by councils now means the majority of Kent is subject to the presumption.
Further, Canterbury, Dover and Folkestone and Hythe are all in precarious positions should developers seek to challenge the five-year supply position (note that both Canterbury and Tunbridge Wells only just avoided falling into the 20 per cent buffer requirement because of the Covid adjustment).

What does this mean in practice? Only that the majority of Kent is now at increased risk of speculative planning applications for developer-led interpretations of ‘sustainable development’.
CPRE Kent has long campaigned that the standard method for calculating the number of homes is a blunt instrument that fails to recognise local constraints and actual housing needs. Yet the revision made to the standard method in December 2020 is likely to further increase pressure on Kent to take some of London’s deemed increase in housing need.
It is also our view that the Housing Delivery Test and five-year supply requirements are fundamentally flawed.
The reality is that the supply of homes is all but controlled by the housebuilders, who clearly will only build what the local market will absorb. Yet if this building rate falls below these unreasonable targets, often the only response a local authority can have is to grant yet more planning permissions or allocate yet more land for increasingly unsustainable development.  
And so the cycle continues.  
Or, put another way, while the development industry is rewarded for failure to build houses with an increasing suite of sites where ever-greater profits may be made, communities suffer the real-world consequences of yet more precious green spaces being allocated for development.   

Friday, February 12, 2021

‘A depressingly stark example of how strategic planning should not be done’: Canterbury councillors back ‘deeply flawed’ housing plans

Life in Sturry and Broad Oak is going to be very different

Almost 1,100 homes will be built on the outskirts of Canterbury after councillors made a U-turn from their previous decision.
The city council’s planning committee had in November refused a scheme for 650 new homes in Sturry, a decision that sparked the withdrawal of a linked application, for 456 properties at neighbouring Broad Oak.
Last night (Tuesday, February 9), however, both schemes, which comprise one strategic site, came back to the committee, which at its ‘virtual’ meeting approved them by seven votes to five.
The Sturry plan had been marginally revised, the number of properties being cut by 20 homes to 630. A new primary school and – perhaps critically – funding towards a Sturry relief road were part of the wider package.
Planning officers said earlier reasons for refusal, including concerns over traffic, issues with environmental impact, absence of affordable housing, excessive density and poor design, had all been tackled.
CPRE Kent had objected to both proposals, along with many others, including Sturry and Broad Oak Action Group, the Woodland Trust and Sturry Parish Council.
The Sturry development won outline permission only, while the Broad Oak element’s 456 properties were given full permission. More than 800 square metres of commercial space at Broad Oak won outline permission.
CPRE Kent has been working on the proposals with Sturry and Broad Oak Action Group, which gave the following reaction to the Canterbury City Council verdict:
“We are deeply disappointed by the decision of the planning committee to push through this deeply flawed application for hundreds of houses on the edge of the city.
“The committee’s justified concerns over traffic, issues with environmental impact, absence of affordable housing, excessive density and poor design all cited in November’s decision to refuse the application are still just as relevant.
“Issues with planning law have not been addressed, while the developer’s slight reduction in the number of properties does not change the fact that the Environ Design (Sturry) scheme remains wholly unacceptable.
“We believe it has been accepted because of council fears that SELEP [South East Local Enterprise Partnership] funding for a related Sturry relief road would be lost if it were not approved by SELEP’s mid-February deadline.
“The new road is not even about relieving traffic at the Sturry level crossing – rather it is about opening up potential housing sites for miles to the east of the city. The resultant urban sprawl does not bear thinking about.
“Additionally, the new road, which will run through the middle of the estate, will do little more than shift traffic congestion a mile or two down the A28 towards Canterbury.
“We are concerned for the residents living in the new estate who will have to endure an extremely busy road effectively on their doorsteps – traffic will have to include the transfer of sewage from the tank built to deal with its waste.
“Such issues alone could make the new properties close to unsaleable anyway, while potential new residents might also notice the lack of any playing fields and the fact that the suggested tiny community hall sits on a roundabout, making it effectively inaccessible.
“There are serious concerns for neighbouring Den Grove Wood, where the council has not heeded or acted on Natural England’s standing advice for ancient woodland.
“We have never denied the need for new housing in our city, but we should be pressing for the highest of standards – not the lowest, which is what this scheme represents.
“The level of mitigation work necessary to address the damage caused by it will blight the area for years. Its acceptance is a depressingly stark example of how strategic planning should not be done.”

  • For more on this story, click here

Wednesday, February 10, 2021

CPRE joins coalition in call for a better planning vision

The government should rethink substantial elements of its controversial planning proposals and work with stakeholders to deliver a planning system that puts people, climate and nature at its heart.
The call comes from CPRE, the countryside charity, as part of a broad coalition of 18 environmental, housing, planning, transport, heritage and public-health organisations that have worked together to forge their own alternative ‘Vision for Planning’ in response to the government’s Planning White Paper, published in August last year.
The government is expected to make a further announcement in March about whether and how it will take forward the proposals in the White Paper.
The joint Vision for Planning was launched yesterday (Friday, January 15) at a virtual debate, with speakers including Chris Pincher, Minister of State for Housing.
Commenting on the new joint ‘Vision for planning’, Tom Fyans, deputy chief executive of CPRE, the countryside charity, said: “We are calling on the government to plan back better and work with us to develop a planning system that puts people, and tackling the climate and ecological emergencies, at its heart.
“We all deserve a home we can genuinely afford to live in, and to have a say in shaping the communities around us. And for over 70 years, a toolbox has been in place to make sure that can happen: the planning system. But as things stand, under the government’s current proposals, the opportunity to influence what happens and where in our communities would be halved.
“Before Christmas, the government announced a welcome revision of its housing numbers ‘algorithm’. However, this was only one small part of a range of potentially damaging proposals put forward by the government last year. That’s why we’re calling on ministers to take an equally pragmatic approach to improving policies relating to community voice, affordable homes and access to green spaces. Together, we can develop a planning system fit for the 21st century.”
Julie Hirigoyen, UK Green Building Council chief executive, added: “The government’s proposed planning reforms do not adequately reflect the important role of the planning system as a key strategic vehicle for decarbonising the economy, enhancing climate resilience and reversing biodiversity decline.
“If we are to deliver new development that does not compromise our progress towards net zero, the planning system – as outlined in this vision paper – must ensure all new buildings are net-zero by 2030 at the latest, with new homes to be net-zero as soon as possible.”
Emma Marsh, director of RSPB England, concurred: “Nature is in freefall decline and we have a climate in crisis. Our wildlife is declining at an alarming rate, with much-loved species at risk of extinction if things continue.
“A good planning system is critical not just for providing us with homes with access to nature-rich greenspace and the other services that we need but also for ensuring that our amazing nature is protected and given the space that it needs to recover and thrive again.”
The message was echoed by Shaun Spiers, chief executive of Green Alliance: “For a resilient society, we need environmental and climate priorities to be right at the heart of our planning system, so we hope the government takes careful note of this coalition’s recommendations.
“To cut pollution and climate impacts, reforms to the planning system must ensure that every home has easy access, via public transport, walking and cycling, to amenities, green spaces and local workplaces. Good spatial planning will be integral to the UK meeting its net-zero carbon goal by 2050.”

  • To learn more about the joint Vision for Planning, click here
  • For more on the government’s proposed changes to the planning system and our response to them, see here, here, here and here

Friday, January 15, 2021

Councillors revolt over government plans to dismantle planning system

We need new homes… we also need some say in how and where they are delivered

CPRE, the countryside charity, and Friends of the Earth are joining more than 2,000 local councillors to call on the government to rethink its planning proposals and work with locally-elected representatives to create the places and homes communities so desperately needed.
A total of 2,062 local councillors have called on the government to abandon the most damaging elements of its changes to the planning system in an open letter to Robert Jenrick, Secretary of State for Housing, Communities and Local Government.
More than 350 of the councillors, or one in six of those who signed the letter, are Conservatives, which shows the breadth of opposition to the damaging changes within the Conservative Party itself.
In the letter, councillors warn that the proposed changes to planning will undermine the trust the public has in the planning system and “could radically reduce protections for nature, local green spaces and fail to tackle climate change”.
Local democracy is a major concern for the signatories, with the proposals as they stand leading to “an unacceptable loss of local democracy, scrutiny and accountability and worse outcomes for communities”.
The letter goes on to highlight the need for a strong local planning system to support sustainable development, community cohesion and a healthy environment but highlights that the government’s proposals as currently set out “will not achieve these goals”.
Crispin Truman, chief executive of CPRE, said: “The message from MPs, communities and now more than 2,000 councillors is clear, but it is not too late for the government to rethink its controversial upheaval of the planning system.
“Planning done well can create the affordable and well-designed homes that communities are crying out for. We can create low-carbon and nature-friendly homes, with an abundance of green space on their doorsteps, all connected by low-carbon public transport.
“Investing in a locally-led democratic planning system that empowers local councils to create these places should be the government’s top priority.
“We stand with these councillors in urging ministers to work with us to develop and deliver a better set of planning reforms that can actually deliver our country’s environmental, economic and social objectives.”
The government’s proposed changes to the planning system would be the biggest change to the planning system since the Town and Country Planning Act in 1947. But the proposals put forward by ministers have already faced fierce opposition from local councillors, communities, MPs, former cabinet ministers and even the former Prime Minister, Theresa May.
A recent poll off Conservative backbench MPs, conducted by Savanta Comres, also found that more than half of Conservative MPs (55 per cent) on the backbenches are considering opposing the government’s upheaval of the planning system as set out in the Planning White Paper.
Notably, more than three-quarters (78 per cent) of MPs surveyed think it is important that local councils should choose and prioritise the most suitable development sites, which is something the proposed zonal planning system would exclude.
Naomi Luhde-Thompson, senior planner at Friends of the Earth, said: “It’s clear to so many MPs, councillors and local communities that the Prime Minister’s vision for decision-making on development in England is not one that guarantees local control and centres local voices.
“The privatisation of the planning system so far, where so many decisions are no longer made in principle by councils but by developers, like the conversion of offices into homes, tells us what this government thinks of local control.
“The proposals in the White Paper will drown out community voices, stifle local democratic responsibility and weaken legal protections for the environment.”
The letter from local councillors concludes: “The right development in the right place has the potential to deliver social equity and sustainable economic growth, as well as meeting our environmental ambitions.
“The government’s proposals as they stand will not achieve these goals. With this is mind, we urge you [Mr Jenrick] to rethink the proposals you have set out and work with elected representatives in developing a positive vision for planning.”
With the 2021 local government elections just around the corner in May, CPRE and Friends of the Earth are joining local councillors to call on the government to rethink the planning proposals they have set out, trust in local expertise and work with elected representatives in creating the places and homes communities need, especially in rural areas.

Thursday, December 10, 2020