FOSH Consultation Response

The Changes to the current planning System‘ consultation closes at 11:45 1st October. Many of the ‘technical’ questions the Government has posed in the ‘Open Consultation’ are for the Local Authority to answer. However there is scope to make our views on the key issues known – and that is what the FOSH have done.

The 4 main Government proposals are:

  • changes to the standard method for assessing local housing need
  • securing of First Homes through developer contributions in the short term until the transition to a new system
  • supporting small and medium-sized builders by temporarily lifting the small sites threshold below which developers do not need to contribute to affordable housing
  • extending the current Permission in Principle to major development

The Planning for the Future’ Consultation, which ends October 29th, is even more far reaching. Councillor Georgina Allen summed up the Government’s very controversial proposals when she remarked recently:

The Friends of South Hams are working with a number of community and interest groups to prepare a detailed consultation response. In the meantime, here is the FOSH response to ‘Changes to the Current Planning System

Changes to the current planning system consultation
Ministry of Housing, Communities and Local Government,
3rd Floor, South East Fry Building,
2 Marsham Street,
LONDON
SW1P 4DF

TechnicalPlanningConsultation@communities.gov.uk

29th September 2020

Friends of South Hams Representation.

A key part of this consultation is to seek engagement from a wide range of people on the proposed changes to the current planning system.

The ’Friends of South Hams’ are a community group who campaign effectively to protect the South Hams and its countryside, in particular the South Devon Area of Outstanding Natural Beauty, and to ensure that development is appropriate, in the right place, so that it benefits the local community and visitors

The range of proposals contained in the ‘Changes to the Existing Planning System’ consultation is aimed at significantly increasing the number of homes that would be built in the South Hams.

We note that no evidence has been presented by the Government that a higher level of housebuilding will have the intended outcome of reducing average house prices in in our area, still less that there will be any benefit for existing residents trying to step onto or climb the housing ladder.

The two current consultations have nothing substantial to say in relation to the national climate emergency or impact on creating a greener environment.

We do not believe that the Government’s recently announced commitment to ‘protect’ 400,000 hectares of English countryside, to support the recovery of nature, will have a significant effect on the already highly protected South Hams and that the threat to the area from the higher housebuilding numbers is increased by the proposed changes to the existing planning system.

Inappropriate development

We argue, that there is little justification for the proposed increase in the housebuilding requirement and we also believe that the risks of inappropriate development will increase.

 Reducing the supply of affordable homes

There are also a range of other proposals in the consultation document which would affect the provision ‘First Homes’. We believe the proposals to change the threshold for developer contributions by temporarily lifting the small sites threshold below which developers do not need to contribute to affordable housing, from 10 to up to 40 or 50 units to support SME builders is likely to significantly reduce the supply of affordable homes in our area, where the majority of sites are under the proposed threshold.

Harming the environment

We believe that the activities that are detailed here (i.e. increasing the number of homes that the council would be required to provide for in the Local Plan) would have a significant negative impact on our environment. At the moment there are no details in the consultation document in terms of how this would be addressed.

 Need for affordable rented housing

The overwhelming need in rural areas is for affordable rented housing. Requiring 25% of affordable housing contributions to be First Homes will squeeze out affordable rented housing. Given the high house prices and relatively low rural incomes, the national price and income caps will make First Homes unaffordable to many South Hams rural residents.

Revised standard methodology

The revised standard methodology and the removal of the existing ‘cap’ would, we believe, increase the housing requirement for the South Hams from the current estimate of 324 to 760 dwellings, an increase of 137% in the number of houses which need to be built annually in the district.

Not compatible

Given the constraints on development arising from the protected areas, such as the South Devon Area of Outstanding Natural Beauty, we do not see how this proposed level of development could be compatible with the Local Authorities’ existing sustainability, bio-diversity and environmental objectives.

Widely held views

We also believe that our view is shared by a number Parish and Town Councils, and local planning authorities in Devon and other parts of the South West of England which would also see substantial increases in the number of privately owned homes that they would need to provide in their Local Plan, due to the increased emphasis in the current proposals on the affordability factor.

We therefore object to the use of the revised formula simply to increase the number of privately owned homes in the South Hams.

Steep property ladder

Whilst the discount for First Homes would be a good financial incentive and allow a greater number of people onto the first rung of the housing property ladder, there is little detail in the proposals as to how the subsequent sale of a property will ensure that the home remains affordable in the future. We believe that the schemes will create wide gap between what is affordable as the ‘first rung on the property ladder’ and that of the second rung property – for which no discount is available. If house prices were stabilised (by increasing supply) then moving on from the First Home may be as difficult as joining the market in the first place.

No explanation

The government has not explained clearly in the consultation how the proposed changes would be specifically benefit SME builders.

Unaffordable housing

We also believe that the change in the threshold for the provision of affordable housing is inconsistent with the government’s concerns to promote affordability. The proposal seems to be inconsistent with the justification for a revision to the standard methodology to address the issue of affordability. Our Local Authority would be prevented from asking developers to provide affordable housing for sites that fall under a new threshold.

We therefore object to the proposals in this consultation document to increase the threshold from 10 homes to 40 or 50 at which contributions for affordable housing can be obtained.

Permission in Principle

It is proposed to extend the current ‘Permission in Principle’ (PIP) arrangements to major development so landowners and developers would have a fast route to secure the principle of development for housing, without having to present detailed plans first.

We are concerned that extending the scope of PIPs to housing developments up to 150 homes i.e. below the current Environmental Impact Assessment threshold, that the community would only be able to comment on the principle of development and would only have limited information about the planning proposal and very limited consultation time to respond.

We therefore strongly object to the proposals for an expanded role of PIPs.

Opportunity missed

We are deeply concerned that the government’s current proposals fail to address the provision of social housing. It is our view that simply building more market price homes isn’t enough to help many of those who are faced with the housing crisis, because this is only likely to influence prices over the long-term. We do not believe that simply aiming to reduce house prices by increasing the supply in some places will solve the current crisis.  We suggest that to make homes more affordable we have to build more affordable homes.

Economic impact of social housing

For every £100 million invested in affordable housing supply via both public and private finance generates £210 million of economic output in the wider economy and sustains 1,270 jobs.1.

For decades housing built and managed by councils and housing associations was a source of pride, security and a start in life. Labour and Conservative Governments saw this as essential in meeting people’s housing needs and aspirations.

We highly recommend that the government considers enabling Local Authorities to re-engage in developing social hosing for rent. 

       Summary:

  • Question 6. We object to the use of the revised formula simply to increase the number of privately owned homes in the South Hams
  • Question 15. We object to the proposals in this consultation document to increase the threshold from 10 homes to 40 or 50 at which contributions for affordable housing can be obtained
  • Question 24. We strongly object to the proposals for an expanded role of PIPs.
  • We highly recommend that the government considers enabling Local Authorities to re-engage in developing social hosing for rent

Ian Bryan

29th September 2020

For and on behalf of the ‘Friends of South Hams’

Email:  friendsofthesouthhams@gmail.com     

FOSH Web     

FOSH Facebook

1.https://scotland.shelter.org.uk/__data/assets/pdf_file/0009/1218609/Economic_impact_of_housing_investment.pdf/_nocache

FOSH © 2020
FRIENDS OF SOUTH HAMS

This Web site is for those who love the South Hams “The jewel in the crown of Devon” and who wish to protect and enhance the South Devon Area of Outstanding Natural Beauty.

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