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Date: 8/12/2006

Whilst there are many good features of the new policy advice on the delivery of housing the Planning Officers Society (POS) has stressed that it has two fundamental concerns. Geoff Cross, for POS, said “ Of the three things we particularly worked on it is disappointing that only the need for the trigger for a review of 5 year land supply at the local (as opposed to regional) level has been accepted.”

The exclusion of windfall from the required 10 year housing land supply without robust evidence of genuine local circumstances that prevent specific sites being identified (para 59), will substantially change the level of greenfield development. That is because the previous reference to counting windfall development has been deleted, and over half of current permissions are on windfall sites in England . The level of windfall development is likely to continue with the PPS's continuing brownfield emphasis, (which has been strengthened from previous drafts). The exclusion of windfall development is therefore likely to drive greenfield release up to take overall development levels above the Government's 200,000 dwelling p.a. target. Greenfield is likely to rise from the current 30-50,000 dwelling level to 150,000+ as a result of the approach.

The exaltation to grant planning permission for suitable unallocated sites prior to the review of Local Development Documents after next April, if there is not a demonstrable up to date 5 year housing land supply (para 70/1), taken with the advice that the PPS may supercede the Development Plan (para 68), significantly changes things. The pre-eminence of the Development Plan as a material consideration will no longer apply to residential proposals where there is no agreed 5 year land supply. “This is reminiscent of the situation that previously followed the 1980 & 1984 circulars when many housing developments were determined on appeal solely on the basis of a lack of a five year land supply” said John Silvester, Spokesperson for POS.

In its response to the draft Planning Policy Statement 3: Housing the Society supported the proposals for five and fifteen year land release triggers and the sub regional and local authority breakdowns. However, it believed the Regional Spatial Strategies (RSS) are unlikely to be in a position to determine the circumstances under which land should be released throughout the country since the proposals are predicated on Housing Market Assessments   (HMA) being applicable in all areas and in London and remote rural areas they are unlikely to reflect sub regional joint working structures. POS said this is a critical flaw and needs to be re-examined.

The Society was of the view that decisions about triggering the release of 5-15 year land need to be taken at the local market area level and any RSS triggers of land release are likely to be based on broad criteria which would not adequately reflect community involvement, Housing Market Area Partnerships views, or a clear understanding of the balance of the appropriate area factors in the HMA. The Society believed the RSS will only be equipped to oversee the cooperative arrangements necessary in any sub regional area identified in the RSS, thus for those parts of a region which lie outside an identified sub-region the RSS will not be able to provide the necessary guidance.

The Society requested the PPS is amended to make it clear the RSS should only determine the general area in which local planning authorities will be expected to work to determine any 5-15 year land release at the sub regional level and local authority levels.



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