Dear Supporters,
The Government are consulting on changes to planning policy. The closing date is 7th December.
In September, the publication of new (2016) household projections by the Office for National Statistics led to a significant reduction in the overall numbers generated by the standard method for assessing local housing need.
It was thought that this would mean that the housing targets for Wirral would be significantly reduced, as the previous 2014 household projections were too high.
However, in order to meet the Governments arbitrary target of 300,000 houses nationally, the Government want to chance planning policy to ignore the reduced 2016 projections and to specify that the higher 2014 projections must be used.
They are now consulting on this proposal to continue using the out of date 2014 projections:
We urge you to respond to the consultation by the 7th December. You can be absolutely certain that Developers are flooding the Consultation with responses urging the government to stick to the higher 2014 projections.
You can respond on line :
Further info can be found here:
It is quite a detailed technical consultation, so if you need a response to help you, then see some answers below. please use, amend, add to as you see fit!
It really is important that you take just a small amount of your time to fill this consultation in, the results of this consultation could dramatically affect the housing targets for Wirral.
Thank you for your support!
Question 1:
Do you agree that planning practice guidance should be amended to specify that 2014-based projections will provide the demographic baseline for the standard method for a time limited period?
No I strongly disagree that the 2014 based projection should provide the demographic baseline. This would simply force a justification for the Governments completely arbitrary target of 300,000 homes. This arbitrary target has now been proved to be too high and will not solve the need for social / affordable housing or encourage urban regeneration. Housing Need assessments must be based on the most up to date assessments to ensure that the right number of homes are built in the right places, meeting local demographic need.
It is not acceptable to say that the 2014 targets should be used, because the 2016-based data would lead to delays in plan-making. It is more acceptable to have an delay in planning making, than to have plans which are inappropriate, are more likely to lead to the destruction of the Green Belt and farmland, do not take account of Brexit and do not consider the need for mitigation against climate change.
Question 2
Do you agree with the proposed approach to not allowing 2016-based household projections to be used as a reason to justify lower housing need?
No, the 2016 based household projections are more up to date. They should be included as a reason to justify lower housing need.
Question 3
Do you agree with the proposed approach to applying the cap to spatial development strategies?
The Combined Authority should agree with its Constituent Authorities the approach to be taken. This would lead to a more joined up approach enabling more reuse of Brownfield sites and reduction of the need for Green Belt Development.
Question 4
Do you agree with the proposed clarifications to footnote 37 and the glossary definition of local housing need?
No, the Local Housing need should not be used as a basis for assessing whether a five year supply of specific deliverable sites exists. The 5 year housing land supply should be made up of allocations in an up to date Local Plan the Brownfield Register and sites with any form of planning permission.
The Planning Departments of Local Authorities have had diminishing resources over recent years and they are now debilitated, to such an extent, they are no longer able to carry out proper planning and development management functions. If the Government is serious about defending the Green Belt and the Countryside, they must ensure that Developers are not allowed to exclude sites with permission from the local authorities five year housing land supply. The Government should not be relaxing planning laws in favour of Developers and should ensure that Councils can defend their five year housing land supply without having to defend costly legal appeals which are draining resources from cash strapped Councils.
Question 5
Do you agree with the proposed clarification to the glossary definition of deliverable?
No, the wording does not go far enough. The Government should modify the wording to include a definition which notes the ruling from Judge Lindblom, Oct 2017 (East Riding v St Modwen): which stated that to be deliverable, a site has to be capable of being delivered within 5 years, but it does not need to be certain or probable that the site actually will be delivered within five years. He added: “The fact that a particular site is capable of being delivered within five years does not mean that it necessarily will be. For various reasons, the landowner or housebuilder may choose to hold the site back. Local planning Authorities do not control the housing market. NPPF policy recognises that.”
The simplistic chosen definition of “deliverable” does not give protection to Green Belt, Farmland, Land of Special Landscape Value etc. The definition of deliverable should ensure a Brownfield First policy, ensuring that only when all “deliverable” brownfield sites, empty properties etc have been used, should alternative Green Belt sites etc be considered deliverable.
A system which allows developers to continue to “landbank” housing which already has planning permission can not be allowed to continue.
Question 6
Do you agree with the proposed amendment to paragraph 177 of the National Planning Policy Framework?
No, the insertion of the word “significant” is open to interpretation and will only lead to more harmful impacts. The proposed wording will allow developers to produce their own assessments to conclude that there is no adverse harm when developing a site.
This will lead to more harm to farmland, green belt and green spaces. Recent reports by the UN and the Government has highlighted that we must act now to triple our efforts to mitigate against climate change or face climate and environmental catastrophe. If the Government is serious in wanting to mitigate against climate change then the NPPF should be used to put the mitigations in place. Any harm, no matter how small, is serious and should be avoided. Any mitigation should ensure that all impacts are positive before planning permission is granted.