Dear Supporters,
we need as many people as possible to respond to the Government’s Consultation on Housing and Planning Reforms. Their proposals will see Wirral Council required to allow Developers to build 28,000 houses on the Wirral, increasing the population by 60,000 (a 20% increase) and putting our precious Green Belt at risk.
Guidance on How to Respond to the Government's Consultation: (option 2 is the easiest)
- The Government prefer that you respond via the Citizen Space Portal, involving a highly technical 106-Question survey. Wirral Green Space Alliance will respond to this survey but, if you feel you are able to respond thus, please do so. You do not have to answer all the questions but simply entering YES or NO will mean your responses are counted. You can respond to the survey via the link: https://www.gov.uk/government/consultations/proposed-reforms-to-the-national-planning-policy-framework-and-other-changes-to-the-planning-system/proposed-reforms-to-the-national-planning-policy-framework-and-other-changes-to-the-planning-system
2. Alternatively, you can email your comments to: PlanningPolicyConsultation@communities.gov.uk
3. Or, you can write to: Planning Policy Consultation Team, Planning Directorate – Planning Policy Division,
Ministry of HC&LG, Floor 3, Fry Building, 2 Marsham Street, London, SW1P 4DF.
Deadline for Responses is Tuesday 24th September at 11.45pm. Thanks for your help and support.
4. For those with limited time available to read and digest the full Consultation documentation, we suggest the email route would be the easiest option. When you email, it is important that you state:
(i) whether you are replying as an individual or submitting an official response on behalf of an organisation and include: your name, your position and name of the organisation (if applicable);
(ii) you a responding to the Government’s Consultation on Housing and Planning Reforms; and
(iii) which survey question(s) you are responding to and ensure that the text of your response is in a format that allows copying of individual sentences or paragraphs (by copy-&-paste), as this will help extracting/counting your view(s) on individual issues.
Wirral Green Space Alliance would appreciate receiving copy of your Response(s), preferably by email to johnheath@barnstables233.co.uk . Thanks for your help and support.
5. Wirral Green Space Alliance would particularly request your help by your responding to the following Survey Questions: Q15 Housing Stock basis; Q23 Grey Belt Land definition; and Q24 Degrading of GB.
6. Examples of what you can consider including could be as follows, but please use your own words as we have been advised individual words carry more weight, whereas copy-&-paste text may be discounted.
7. Question 15: Do you agree that Planning Practice Guidance should be amended to specify that the appropriate baseline for the standard method is housing stock rather than the latest household projections?
Start your (email) response (same for each Question) by stating your name and that you are an individual (or representing a particular organisation.) Then state you are responding to Q15 (for example) of the Consultation Survey. Then you could say any of the following (but please try to use your own words):
· No, I do NOT agree the Standard Method for Calculating Housing Need should be based on the existing Housing Stock number: this is irrational. It should be based on the most up-to-date Census information and population/household projections at the relevant Local Authority levels.
· No. Basing the Standard Method on Housing Stock is a “one-size-fits-all”, arbitrary, unfairly-allocated method which is not based on actual need, which should be ‘locally assessed’.
· No. For instance, where a local authority has produced all the homes needed (or nearly), why should they have to deliver homes that are by definition not required? Developers would not build such mandated houses where there is no market but the ‘failing’ council would be penalised.
· No. Basing the Standard Method on existing housing stock is “overly simplistic” and does not target homes where they are needed or where employment is available. Also, London, which has the worst housing crisis in the UK, will see its actual target drop by 18,000 and its true ‘need’ reallocated. Such examples (amongst many others) would encourage polluting commuting, harming the environment.
· No. For example, Wirral’s Population grew by 417 between 2011 and 2021, yet the proposed Standard Method would see Wirral required to build 28,080 extra houses over the 16-year Local Plan Period, increasing the population by over 60,000, which is a 20% increase. Where will these extra people come from? How will they be employed? How will the already stretched Infrastructure and Public Services be provided for 60,000 extra people? The locally-assessed Housing Need is accepted to be just 4,500: 14,000+ have been included in the emerging Local Plan, so 28,080 is pure nonsense, and undeliverable.
· No. For example, in Wirral’s case, at the 28,080 additional dwellings mandated Target, it is calculated the Brownfield capacity would leave around 12,000 to be built in Green Belt. Developers would choose to build on the best, most profitable Green Belt land and ‘land-bank’ the rest. As the Target would be vastly more than Market Demand (the real NEED), the planned and desperately needed Regeneration of the deprived and run-down east of the Peninsula, where life-expectancy is over 12 years less than in the west (just 5 miles away), would simply not happen - once again – with awful consequences.
· No. Basing the Standard Methodology on existing housing stock would not deliver homes where they are ACTUALLY needed but would increase the likelihood of building on Green Belt causing massive, irreversible, environmental damage at a time of Climate and Ecological Emergency.
· No. Basing the Standard Methodology on existing housing stock would allow Developers to target food producing farmland which will be needed to grow food, particularly as climate change accelerates. This land is also needed to mitigate against floods and drought, and to provide carbon sinks.
8. Question 23: Do you agree with our proposed definition of grey belt land?
· No. The Definition is far too wide. Even where Previously Developed Land, the sites could have developed a significant ecological value which should be afforded ‘weight’.
· No. “any other parcels and/or areas of Green Belt land that make a limited contribution to the five Green Belt purposes” is too open to interpretation. Who decides on the level of contribution? Does the reference to “contribution” relate to “any other parcels” or just “areas of Green Belt …”?
· ‘Limited contribution’ and ‘weakly performing’ Green Belt are not defined or terms in Planning legislation, and yet have already been used to argue for release of swathes of Green Belt.
· No. ‘Other areas’ have included ‘alongside roads’ and ‘on the boundaries’ of urban areas (referring to the acceptability, even promotion, of ‘urban extensions’), without any limitations of size, etc.
· No. For example, Wirral is a special case where Merseyside CC and now its successor, ‘Liverpool City Region’, repeatedly and unanimously confirmed the Policy of drawing Green Belt Boundaries tightly around urban areas, specifically to direct regeneration of the longterm deprived areas, far exceeding the base level of protection afforded Green Belt through the 5th Purpose. This Definition would remove the ‘special case’ status and allow Urban Extensions and development beside isolated buildings and roads.
· No. The introduction of ‘Grey Belt’ (which is not a belt at all) serves mainly to mask the inevitability of significant release of Green Belt for development as the extent of deliverable ‘Grey Belt’ land has a relatively small capacity when set against the massive increases of the mandated Targets.
· No. There is a growing number of instances where Green Belt sites and parcels of land have been deliberately left unfarmed, unmanaged, even stripped and used for unauthorised, inappropriate and destructive uses, becoming unsightly and termed ‘weakly performing’ and/or so hideous as to be candidates for “tidying up” through a neat development of houses. The ‘Grey Belt’ category, as defined and already being targeted by landowners, developers and consultants, will only accelerate this abuse.
9. Question 24: Are any additional measures needed to ensure that high performing Green Belt land is not degraded to meet grey belt criteria?
Yes. Related to the last item of Q23 above, the proof of land use over the previous 10 years should be required so that Google Earth historic images could be used to expose deliberate degrading of GB and attract Refusal and possibly penalty.
We appreciate that the Consultation is not that easy to respond to, but by simply emailing in a small response to a question you are making your voice heard. The more responses that we can submit, the better.
Thank you for your support