Changes to National Planning Policy on the Way
We have recently submitted comments on the draft amendments to the Government’s National Planning Policy Framework (NPPF). This is the national policy document that guides local authorities in the preparation of their local plans and in making decisions on planning applications.
The amendments proposed are to update the policies in the NPPF so that they accord with other consultations undertaken by the Government. Amendments include changes in the way that housing need is calculated, how local Councils are expected to monitor progress on housing and how Council’s should address pressure for development in the Green Belt.
Some of the main points in the our consultation response were as follows –
- Amendments to the presumption in favour of sustainable development will give additional strength to the protection of AONBs and Green Belt.
- The whole premise of the Housing Delivery Test is flawed, in that it involves sanctions against LPAs for something that is not wholly within their power to control.
- We object to a new policy on exception sites for entry level homes in the Green Belt, which seems to allow for additional market housing to be slipped in.
- Communications equipment such as masts and overhead cables have the potential to cause significant harm to landscapes, and this is particularly important in protected areas.
- We support the principle of minimum density standards for city and town centres as this will help to reduce the pressure for development on the open countryside.
- We do not support the removal of land from the Green Belt to allow development, and consider that housing numbers should be capable of being adjusted downwards where the only option to meet those numbers is to encroach on Green Belt
- We welcome the more detailed test to be applied to demonstrate exceptional circumstances for removing land from the Green Belt.
- Where no alternative can be found to Green Belt development (including in neighbouring districts) and exceptional circumstances exist, local authorities should be required wherever possible to create new areas of Green Belt with boundaries that can be defended in the long term.
- We are disappointed that the reference to AONBs having the highest status of protection has been removed, there is no protection in relation to the setting of AONBs, and there are no policies for addressing cumulative impacts on AONBs and their settings.
Our full response can be read here.
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Influencing Local Planning Policy
The Chiltern Society has always taken a keen interest in the planning policies being developed by the Local Planning Authorities across the Chilterns area. With the scale of development across the region likely to increase significantly over the next twenty years, it is essential that we take an active approach to influencing the contents of the emerging Local Plans. These plans are being developed by each local authority and their primary aims are to set planning policy for the next twenty years or so, and identify sites that are considered suitable for development.
As the housing targets now being set by the local authorities have been significantly increased, there is increasing pressure to use land located in the Green Belt or the Chilterns AONB and its setting for housing. In order to address the increasing workload arising from these plans, we have appointed a new Planning Officer, Colin Blundel, specifically to work with our Planning Group on planning policy matters. Since his appointment in September 2017, the we have sent in representations on the following Local Plans:
Buckinghamshire County Council – Minerals and Waste Local Plan – Preferred Options
- We were concerned that there was no reference to preserving the openness of the Green Belt in the Vision Statement.
- Whilst we supported the policies on the Green Belt and Chilterns AONB, more emphasis could be put on protecting the setting of the AONB.
- We identified the minerals and waste sites that were located within the Chilterns and stressed that great care will be required with the design and restoration of these proposals to ensure that they do not cause long term harm to the character and appearance of their location.
Read our full response here
Wycombe District Council – Local Plan Publication Draft
- We considered that the allocation of a site for 100 houses at Mill Road, Stokenchurch was unsound because the Plan failed to recognise it as major development within an AONB.
- We were not satisfied that the proposed policy relating to the Chilterns AONB was consistent with national policy as it did not require major developments to demonstrate that they were in the public interest.
- Amongst the allocations were a number of sites that may impact on the AONB and we asked that the wording of the policies referred to conserving and enhancing the AONB, rather than just limiting the impact.
Read our full response here
South Oxfordshire District Council – Local Plan Publication Draft
- The Plan did not include a separate policy in relation to the Chilterns AONB, and was, therefore, inconsistent with the plans of neighbouring authorities.
- The Council had not given sufficient weight to the AONB to meet their statutory duties under the Countryside and Rights of Way Act 2000 and to be consistent with the National Planning Policy Framework.
- We were concerned about the high level of growth proposed in South Oxfordshire over the Plan period and whether this has been sufficiently justified in terms of impacts on the AONB.
- It is not clear how the Council has taken into consideration the AONB in arriving at housing targets for individual settlements.
Read our full response here
Dacorum Borough Council – Local Plan Issues and Options
- We considered that a co-ordinated regionalised approach was required between local authorities to identify the locations for housing development on a more regional basis to try to reduce pressure for development in the AONB and Green Belt.
- More references to the Chilterns AONB and the Green Belt should be included in the Vision Statements relating to the main settlements.
- We were broadly in support of the settlement hierarchy approach proposed, concentrating on the larger settlements. Is has to be remembered, however, that the towns are immediately surrounded by the Chilterns Landscape, including both the AONB and the Green Belt.
- We considered that encroachment into the Green Belt must be a last resort for development. As the Plan emerges it will need to demonstrate that it has fully considered brownfield sites, sites within towns and villages and sites outside the Green Belt and AONB before considering Green Belt boundary changes and site allocations.
Read our full response here
Aylesbury Vale District Council – Local Plan Submission Draft
- We considered that the allocation of the RAF Halton site could lead to the site’s removal from the Green Belt in the long term and would therefore not be consistent with national policy.
- The RAF Halton site is located entirely within the Green Belt and in the immediate setting of the Chilterns AONB. Therefore, we considered that any development here must be carefully designed to fully respect these designations.
- We agreed with the Council that the RAF Halton site should be retained within the Green Belt and we would expect the Council to re-use existing buildings where possible, and particularly the existing Listed barracks blocks.
Read our full response here
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Planning Campaign Leader
Are you passionate about protecting the Chilterns as a unique and special place to live ? Do you have the drive and commitment to lead a successful campaign, building support from our community and other organisations to influence local and national government ?
Our Planning Group urgently needs a Campaign Leader to step up our campaign to prevent unsustainable development into the Chilterns Area of Outstanding National Beauty and Green Belt. You’ll be used to working in a volunteering role, and how to work with other volunteers to achieve results.
We’re looking for someone, maybe from a marketing background, with skills and experience in leadership, communication and management of diverse stakeholders to influence senior levels of local and national government. There is no need for detailed knowledge of planning regulations, as you will have support from experts in our Planning Group. However you do need an understanding of how government operates and how to collaborate with other organisations in the area such as the Chilterns Conservation Board, Campaign to Protect Rural England, Natural England, District and County Councils.
The role needs to drive out tangible results from our already publicised Planning Manifesto. This safeguards the AONB, protects the Green Belt, overhauls the methods for calculating housing need, scales infrastructure, favours brownfield and infill usage, and promotes good building design. The first goal is to build a coalition of MPs across the Chilterns to support our Manifesto and change housing calculations. The Chiltern Society supports the needs of local businesses and affordable housing for local people, rather than unfettered free market priority for multi-million pound commuterland.
To discuss more about how you could fit this role please contact:
Merrin Molesworth: firstname.lastname@example.org : tel: 01494 773381
Michael Jepson: email@example.com tel: 01494 837602
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Will your future MP support our Green Belt Campaign?
We have written to all General Election candidates standing in the sixteen constituencies across the Chilterns region asking them to support our campaign to protect the Green Belt and the Chilterns Area of Outstanding Natural Beauty from over-development. You can see a copy of our letter below.
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Our Response to the Housing White Paper
Our Planning Group has recently submitted its response to the Housing White Paper.
Within the wide-ranging White Paper, there were some proposals to welcome, including encouragement of small and custom-builders, greater emphasis on design standards, more support for providers of affordable houses, increased powers for local authorities to assemble land and deliver homes themselves, a hike in application fees to help cash-strapped planning departments, and the potential introduction of an appeal fee.
But, if anything, the White Paper increased our grave concern that in the drive to build more homes, local authorities will feel compelled to turn to Green Belt or other designated land. They are still being required to make every effort to meet theoretically-assessed “need” locally if at all possible, with no “automatic” allowance given to reduce numbers even when there is significant Green Belt or other designated land. Furthermore, the proposed revised wording of national planning policy implies that use of Green Belt land will be a legitimate way to do this, once all other options have been explored. The problem is exacerbated in areas like the Chilterns, when neighbouring authorities are also “constrained” by protected land, thus removing the scope to transfer provision elsewhere.
On top of this, the sanctions that already apply when local authorities fail to maintain a 5-year supply of allocated housing land are being supplemented by an additional housing delivery test (based on the numbers of homes actually built), seemingly oblivious to the fact that the actual delivery of housing is almost wholly outside of their control.
Even under the existing rules, 8 out of 10 local authorities in the Chilterns are seriously considering use of Green Belt land, so these threats are real and current.
Early consultation on a revised method of calculating need was promised by the White Paper, but the general election will inevitably delay this. As well as responding to consultations of this sort, our Planning Campaign is using various means to highlight these dangers and lobby for changes to the rules.
Our full response is available here and the Housing White Paper itself is available at: www.gov.uk/government/publications/fixing-our-broken-housing-market
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Working together to protect The Chilterns
A new grouping of organisations across the Chilterns has come together to protect the Green Belt and Area of Outstanding Natural Beauty (AONB) which are under threat from an unprecedented housing tidal wave. There is currently an assessed need for 135,000 new dwellings in the Chilterns, with eight out of ten local authorities in the Chilterns identifying a need to build on the Green Belt with some small incursions into the AONB. A recent workshop co-hosted by the Chiltern Society and the Buckinghamshire branch of the Campaign to Protect Rural England (CPRE) was also attended by representatives of the London Green Belt Council, the Chilterns Conservation Board, CPRE National Office and CPRE Branches from Oxfordshire, Hertfordshire and Bedfordshire.
The shared messages of the respective organisations are as follows:
- Government and Local Authorities need to make a long term commitment to protect the Green Belt and AONB, ensuring action and not just empty words.
- Realistic housing targets that account for Green Belt and AONB designations are required based on real local need not aspirational market demand.
- A clearer, more restricted, definition of ‘exceptional circumstances ’is needed for Green Belt releases and AONB developments and assurance that housing need does not override Green Belt and AONB designations. There should also be less opportunity for local government to interpret the NPPF to suit their agenda.
The team of organisations will be lobbying MPs in the Chilterns for support and will continue to work closely together to protect the best interests of the Chiltern countryside.
Watch closely for further details about the team’s planned activities!
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Our campaign to change ‘inflexible’ formula for calculating housing numbers
Did you know that 80% of local authorities in the Chilterns are making plans to build houses in Green Belt because they say there is simply no-where else for them to go? Some councils are having to make room for two or three times more houses than they originally envisaged in their Local Plans because of the inflexible formula laid down for calculating housing need.
The end result will cause serious, irreversible damage to the Chilterns countryside, which stretches through Berkshire, Oxfordshire, Buckinghamshire, Hertfordshire and Bedfordshire.
We have written to the 15 MPs that cover the Chilterns area to request meetings, including the Prime Minister Theresa May whose Maidenhead constituency borders the Chilterns and whose country home, Chequers, is within the Chilterns Area of Outstanding Natural Beauty (AONB). It says the current formula for calculating housing need is clumsy and inflexible and in need of fundamental reform.
We believe that at the heart of the problem is the planning concept of Objectively Assessed Need (OAN) and the expectation that each planning authority should meet this need within its own area. This essentially requires councils to calculate future housing needs by looking at past trends. In effect it leaves no leeway to consider the capacity of the area to accommodate the numbers.
We’re concerned that the Government’s latest Housing White Paper fails to recognise that in some circumstances OAN cannot be met without irreversible damage to the character of an area or undermining the fundamental purposes of Green Belt.
We are calling for a four point change:
- Housing targets to be determined more flexibly and intelligently
- Green Belt, AONB and the overall character of an area to become legitimate reasons for reducing housing targets
- Real housing need in an area to be considered instead of calculating numbers via a one-fits-all formula
- Councils to be given the ability to deliver a range of homes in terms of tenure, type and size that meets genuine local need.
We appreciate that there is a need for new housing – indeed in this area there are particular issues for young people wishing to stay in the area they grew up in. But what is needed for such people is genuinely affordable or low-cost homes and in this respect the current system lets them down. By and large, local councils cannot exert meaningful influence to ensure that the right type and number of housing for this local need is delivered.”
Read our letter to MPs here:
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Development pressures in the Chilterns remain, despite Housing White Paper
The Chilterns Green Belt and its Area of Outstanding Natural Beauty (AONB) remain under unprecedented threat from development despite assurances in the new Government White Paper on Housing, says the Chiltern Society.
The Society, with 7,000 members the leading conservation charity in the Chilterns, is examining the details of the White Paper and the likely consequences on the area and will give a considered response in the Government’s public consultation.
However, Society trustee Paul Mason is concerned that the fundamental problems facing the area remain.
“A tidal wave of tens of thousands of new houses are planned in Buckinghamshire, Hertfordshire, Bedfordshire and Oxfordshire.
“Some of these are on Green Belt and encroach the AONB. The Society is not opposed to the provision of new housing to meet local needs. But for everyone’s sake we must protect the special setting and heritage of the Chilterns. Protected countryside must remain protected.
The White Paper declares the commitment of the Government to the continuing protection of the Green Belt but the Society believes the Government needs to re-examine the way it calculates housing need. The current method puts impossible pressures on councils in the Chilterns, forcing them to make short-sighted planning decisions which damage protected countryside and its setting. The Society will be making this clear in its response to the White Paper.
The Chiltern Society shares the concerns raised by the London Green Belt Council that measures for the protection of the Green Belt may not be robust enough. We also agree with the position expressed by the Campaign to Protect Rural England (CPRE) that MPs and local authorities need to ensure that the commitment to the Green Belt outlined in the White Paper actually translates into achievable targets and appropriate well designed development.
For information : The Government Housing White Paper, titled ‘Fixing our broken housing market’ was published on 7th February and sets out proposals on how the Government intends to boost housing supply and, over the long term, create a more efficient housing market whose outcomes more closely match the needs and aspirations of all households and which supports wider economic prosperity. Specific proposals are made with respect to the Planning Process;
- Making sure every part of the country has an up-to-date, sufficiently ambitious plan so that local communities decide where development should go;
- Simplifying plan-making and making it more transparent, so it’s easier for communities to produce plans and easier for developers to follow them;
- Ensuring that plans start from an honest assessment of the need for new homes, and that local authorities work with their neighbours,so that difficult decisions are not ducked;
- Clarifying what land is available for new housing, through greater transparency over who owns land and the options held on it;
- Making more land available for homes in the right places, by maximising the contribution from brownfield and surplus public land, regenerating estates, releasing more small and medium-sized sites, allowing rural communities to grow and making it easier to build new settlements;
- Maintaining existing strong protections for the Green Belt, and clarifying that Green Belt boundaries should be amended only in exceptional circumstances when local authorities can demonstrate that they have fully examined all other reasonable options for meeting their identified housing requirements;
- Giving communities a stronger voice in the design of new housing to drive up the quality and character of new development, building on the success of neighbourhood planning;
- Making better use of land for housing by encouraging higher densities, where appropriate, such as in urban locations where there is high housing demand; and by reviewing space standards.
As ever, the devil is in the detail of how this will be translated into action. The Chiltern Society Planning Group will be watching closely.
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Planning threats coming early in Hertfordshire
Three large areas of Green Belt could be lost this year to housing development around Hemel Hempstead and Tring if current plans are approved.
Dacorum Borough Council wants to bring forward proposals to build 1,500 houses in what many consider a knee-jerk reaction to perceived housing demand in the area.
Green Belt is, of course, supposed to be protected and developed only in exceptional circumstances. Yet this latest move is unlikely to be the end of the Green Belt land grab. Dacorum and neighbouring Hertfordshire local authorities are planing to review Green Belt as part of a wholesale review of their Local Plan.
The Government continues to insist the Green Belt is safe in its hands. Yet the reality is many local authorities are steadily whittling it away as they try and cope with the Government’s unrealistic method of calculating future housing demand.
The public consultation on this latest onslaught on the Green Belt – featured as part of Dacorum’s Site Allocations Modifications document – ends at midnight at Sunday 5 February, 2017. You can comment here and/or speak to your local councillors.
The Chiltern Society has launched a planning campaign highlighting the unprecedented threat to the Chilterns from development and suggesting ideas to ease the pressure. For more details about the work we’re doing, please see our planning pages. Anyone interested in helping to protect the Chilterns from these sorts of threats by joining our team of Planning Field Officers should contact us on 01494 771250 for further details.
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Join our heroes defending the Chilterns!
The Chiltern Society opposes development within the AONB which fails to conserve or enhance the natural beauty of the landscape. The Society also opposes any new development in the Green Belt which fails to protect its openness or undermines its purposes, including the unrestricted sprawl of large built-up areas and neighbouring towns merging into one another.
Government planning criteria and methodology is putting most local authorities in a position where they feel a need to take a cavalier and short sighted approach to the beauty and heritage of our special Chilterns landscape.
District councils in the Chilterns are putting the Green Belt, and even the AONB, at risk. A tidal wave of tens of thousands of new houses are planned across Buckinghamshire, Hertfordshire, Bedfordshire and Oxfordshire. Some of these are on Green Belt and encroach the AONB. Local preferences and priorities are simply being ignored.
Do you care for the appearance of our lovely Chilterns countryside? Are you concerned about the increasing threat from unwarranted developments threatening the Green Belt and AONB?
One of the primary aims of our Planning Group is to firmly resist the worst excesses of the development wherever it can. Our Planning Field Officers are the unsung heroes of the Chiltern Society at the front line of our efforts to protect and enhance the Chilterns.
What do our Planning Field Offers (PFOs) do?
- Monitor and respond to planning applications throughout the Chilterns but especially those affecting the Area of Outstanding Natural Beauty (AONB), Green Belt and open countryside
- Act as respected consultants to Local Authorities regarding emerging planning documents that might affect the future development of the Chilterns area
- Examine and respond to draft Government guidance documents and other consultations
- Represent the Chiltern Society at public inquiries, hearings and examinations relating to local planning and development
We urgently need additional Planning Field Officers to help protect our Chiltern landscape and heritage.
The Chiltern Society Planning Group is always interested in new volunteers to fill PFO vacancies across the Chilterns. There are several vacancies for PFOs in the following areas;
- Three Rivers
- Wycombe North
- Aylesbury Vale North
- South Buckinghamshire
- Central Bedfordshire (particularly Luton)
- North Hertfordshire
- South Oxfordshire
If you are interested in one of these vital PFO roles, please contact the Society Office on 01494 771250. Planning knowledge is not essential but would be helpful, guidance on the role will be provided.
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