Rotherham Core Strategy Inspector's Report
We have now spoken to RMBC, who tell us that they will be seeking to have both the lower target and the phasing reinstated, and that this will be subject of an additional hearing. To the Council’s credit, they have tried very hard to produce a Core Strategy that fulfils NPPF requirements – including large new allocations of greenfield sites and a substantial Green Belt review, in a thorough, evidence-based way.
Affected local communities are frustrated, not least because they can see brownfield sites that are not coming forward for development. The draft Strategy is a long way from CPRE’s ideal, mainly because it doesn’t give enough emphasis to recycling derelict land and it does not address the accumulating under-supply of affordable housing. Nevertheless, the Council’s planners are doing a valiant job in difficult circumstances.
At the Core Strategy Public Examination last October I quoted an experienced strategic planner who said to me many years ago, “If we annoy CPRE and the HBF in equal measure, we’ve probably got it about right.” A little simplistic, you might say, but it does express neatly that there are many competing pressures on a strategic plan, and that we would expect the finished product to show signs of reasoned compromise.
The Inspector asked participants at the Examination to point out to him how NPPF supported phasing, and we were pleased to direct him to paragraph 47 which is crystal clear on this matter: if there is insufficient land available for the first five years then sites should be “brought forward from later in the plan period.....from years 6-10 and 11-15”. That’s an unequivocal basis for a three-phase plan.
CPRE presented two scenarios to the Inspector – one with and one without phasing. With phasing, if an application comes in for a site the Council wishes to see developed within 5 years, it is likely to received permission. If an application comes in for a later-phased site, it is likely to be refused unless all available early-phase sites have been developed. Assuming that the later-phased sites are the more difficult to make sustainable, the spatial plan is better-implemented and a predictable build-rate is achievable.
Without phasing, if an outline application is received for any allocated site anywhere in the Borough, it is likely to be approved. Due to the uncontrolled supply of potential sites, the industry can build during the plan period whenever it would be most profitable to do so, with the most profitable sites being developed first. The result would be a large number of outline approvals early on, but an unpredictable pattern of when and where building might take place, no mechanisms for the Council to push development to where it would be most sustainable, and massively reduced leverage to secure affordable housing.
It is also difficult to see how Government could regard phasing as a restrictive policy: as we emphasised in Rotherham, phasing does nothing to regulate the total supply of new housing, since the plan automatically draws on later phase sites if the early phase sites are filling up fast.
Like it or not, Councils do have to identify a large number of sites – the Government will not allow them to do otherwise. But some of those sites will inevitably be better than others in terms of how they fulfil spatial objectives for sustainable devleopment, be they recycling derelict land, maintaining green spaces or reinforcing the viability of public transport and local amenities. So to deny local authorities the tools to prioritise which of their allocated sites they would prefer to see developed is to render professional spatial planners redundant. We may as well just ask developers where they want to develop, and then say, “Righto, carry on then.”
The housebuilding industry representatives at the Rotherham Examination were, in the main, candid and transparent. Most of their contributions could be paraphrased thus: “Our clients would like to develop lots of greenfield sites here, here and here. Some of them are in the Green Belt, so you should take them out. We don’t want phasing, because it will mean that Fred could develop his site but my clients won’t be able to develop theirs for a while. We don’t want to provide more than 5% affordable housing, and we don’t want to raise standards of design or energy efficiency, because anything other than our standard solution will reduce our profits. If you try to control us, we’ll appeal and we’ll win, so you may as well give us what we want.”
These are commercial organisations and we can’t criticise them for wanting to make money. But to argue that the only sound plan is one that gives developers a blank cheque and surrenders all its spatial levers is perverse, and it demeans the whole planning profession. To accept that one side of a very complex story should hold sway over the others, and that the age-old compromise between commercial developers and local communities should be abandoned, defies logic.
Andrew Wood, 7 February 2014