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LIVING AND WORKING SUB COMMITTEE 6TH SEPTEMBER 2005 AGENDA ITEM 9 PLANNING FOR HOUSING PROVISION - CONSULTATION RESPONSE Summary: This report suggests a response to the Government’s consultation on new planning for housing policy. Author: Malcolm Watt, Planning Officer Recommendation: That the responses suggested in the report be forwarded to the Office of the Deputy Prime Minister. Background 1. The Office of the Deputy Prime Minister (ODPM) has issued a consultation paper “Planning for Housing Provision”. Reponses are requested by 9th September 2005. Subsequently the Government intends to publish a new draft Planning Policy Statement on Planning for Housing (PPS3) to supersede the existing Planning Policy Guidance note on Housing (PPG3). 2. A copy of the consultation paper is attached at Appendix ‘A’. 3 The Cotswolds AONB Management Plan includes two references to the provision of housing in the section “Living and working in the Cotswolds”. Key issues of the need for affordable housing and the proliferation of second homes are highlighted in that Section. The following policy is also relevant: LWP3: To support the provision of well-designed affordable housing in keeping with landscape character across the AONB, particularly where it is related to local employment opportunities. 4 A “Priority Action” in this Section is LWA3: Clarify the scale of need for affordable housing for local people, support its provision, and lobby for improved mechanisms to provide it. New approach to housing provision proposed by the Government 5 The new approach to the planning for the provision of new housing as set out in the consultation document consists of the following two elements, the first of which is more relevant to the concerns of the Board. The need for housing, together with demand, is to be assessed in future on a robust evidence base which looks at housing markets and is developed in partnership with stakeholders; and 6 Proactive planning to maintain a five year supply of housing land within a 15 year time horizon. The Government considers that the present approach to planning for housing set out in PPG3 does not take enough heed of market conditions, resulting in under-supply in areas of high demand. This leads to worsening affordability, as poorer households are unable to enter the housing market. In paragraph 24, the Government “expects regions and local planning authorities to take account of housing markets when developing housing plans, and in planning decisions”. However in paragraph 27 it is recognised that “The desirability LIVING AND WORKING SUB COMMITTEE 6TH SEPTEMBER 2005 AGENDA ITEM 9 of increasing land supply for housing has to be balanced against other objectives, social and environmental”. 7 Section 2 of the paper sets out the proposed policy approach. Of relevance to the Cotswolds AONB and the remit of the Board are the following. 7.1 The paper proposes the identification by Regional Assemblies of sub-regional housing markets, not simply based on administrative boundaries. 7.1.2 In the Regional Spatial Strategy decisions are required as to whether these markets should be designated for high levels of new homes; managed growth; low levels of new homes; or for managed reductions in housing. 7.1.3 An example of this approach can be seen in the South East Regional Housing Strategy Plan on page 22 of the paper. Within these sub-regional markets local authorities would be expected to work together in collaboration with other stakeholders on joint housing need assessments and assessments of housing land availability. Local authorities are encouraged to produce joint Development Plan Documents to deliver housing at a Subregional level. This would be of particular value for the Cotswolds AONB, if that were identified either as itself or as part of a larger, sub-regional market. 7.2 The contents of Paragraph 19 (p24) of Section 2 are of importance to the designated landscapes in areas of high housing demand such as the Cotswolds. It says “,The approach of using ‘floors’ and ‘ceilings’ could be extended to more local areas to recognise that there are often significant differences within broad housing market areas. Whilst the housing market as a whole might be identified for high growth, certain areas within it might be managed more closely in order to deliver other objectives. In areas of restricted growth however, for example, some rural areas, particular attention will need to be given to accompanying policies on the provision of affordable housing to ensure that land supply is able to deliver a range of affordable housing that will help support the creation of mixed and inclusive rural communities”. 7.3. Paragraph 27 (p27) of Section 2 makes clear that “Local authorities should allocate developable, urban brownfield land first, where these sites offer the most sustainable option for development. Sustainability Appraisal provides the framework to test the sustainability (in economic, social and environmental terms) of sites and areas for future development”. Discussion 8 New housing in rural areas is subject to strict control, subject to guidance in Planning Policy Guidance note 3 and Planning Policy Statement 7. Outside areas allocated for housing in Local Plans, only housing required to meet local needs is permitted. Exceptions can be made for affordable housing where a need is identified. All current Local Plans reflect these national policies. 9 The introduction of a consideration of the needs of the market for housing could, on the face of it, undermine this policy framework. There is undoubtedly a huge demand for new housing in attractive rural areas such as the Cotswolds. To meet this demand, much of which is for second homes, thereby bringing about in due course an increase in affordability would require new house building on a scale which would threaten the purpose of designation. The response from the Board should clearly indicate the harm which could be caused by reliance on market forces alone in an attractive area such as the Cotswolds. LIVING AND WORKING SUB COMMITTEE 6TH SEPTEMBER 2005 AGENDA ITEM 9 10 As noted above, the government recognises that these market forces have to be tempered by amongst other things, environmental objectives. These must include the conservation and enhancement of designated landscapes. The response from the Board should welcome this recognition of the damage unfettered market forces could cause. 11 The proposal for closer collaboration by local authorities on planning for housing in sub-regional market areas should be welcomed by the Board. There would be a role for the Board in such a process, not least to ensure that affordable housing needs were being assessed and met on an AONB wide basis as proposed in the Management Plan. 12 The recognition of the need to make provision for affordable housing in areas of restricted new housing should be welcomed by the Board. This is in accordance with the relevant policy of the AONB Management Plan. 13 The need for a Sustainability Appraisal of any housing strategy should be welcomed by the Board. This will include an assessment of environmental impacts, including reference to the AONB Management Plan. Supporting Documents Planning for Housing Provision ODPM Consultation Paper July 2005