Help us see off damaging 5 Year Housing Land Supply Rules for good!
14th February 2023
Government Consultation on Planning Reforms – closes 2 March 2023
The Government is running a consultation on changes to the National Planning Policy Framework ( NPPF), including the proposed removal of 5 Year Housing Land Supply Rules that have led to speculative and inappropriate development across Oxfordshire.
The Framework is the basis on which Local and Neighbourhood Plans and speculative planning applications are scrutinised, so we urge all our Oxfordshire parishes and CPRE members and supporters to respond.
The consultation can be found here
Respond by email by 11.45pm on 2 March 2023 to: PlanningPolicyConsultation@levellingup.gov.uk
Alternatively, there is an online survey if you prefer.
CPRE Oxfordshire’s 5 Minute guide to responding
This is a detailed consultation covering lots of issues. However, for those with limited time, we have tried to pick out some of the key questions and possible responses below. Please use your own words wherever possible, as this will have more impact.
Overview
Whilst there is much to support in this consultation, this is a missed opportunity to bring in a genuine brownfield first policy and to provide the protection of high-quality farmland from development that has been promised.
Q.1: Do you agree that local planning authorities should not have to continually demonstrate a deliverable five year housing land supply (5YHLS) as long as the housing requirement set out in its strategic policies is less than five years old?
YES
The removal of the 5 Year Housing Land Supply (5YHLS) rules where the Local Plan is less than 5 years old is supported. These rules have led to significant speculative (non-Plan led) developments often to the detriment of rural villages.
Beyond the 5 years, developers should still be expected to meet local policy objectives, such as using brownfield sites before greenfield. Speculative proposals for housing developments not allocated in Local Plans should also not be permitted.
Q.2: Do you agree that buffers should not be required as part of 5YHLS calculations (this includes the 20% buffer as applied by the Housing Delivery Test)?
YES
The removal is supported of buffers (up to 20%) on housing numbers currently required as part of the 5YHLS, which have led to speculative applications and inappropriate non-Plan led development in our county.
Q.5: Do you have any views about the potential changes to paragraph 14 of the existing Framework and increasing the protection given to neighbourhood plans?
YES
The increase in the protection given to neighbourhood plans where they are less than 5 years old (an extension from the current 2 years) is supported. Neighbourhood plans take considerable time and hard work to establish and are generally the most accurate embodiment of local democratic preferences and choices. As a result, local communities should be able to rely on them to be taken into account for at least five years.
Q.9: Do you agree that national policy should make clear that Green Belt does not need to be reviewed or altered when making plans, that building at densities significantly out of character with an existing area may be considered in assessing whether housing need can be met, and that past over-supply may be taken into account?
YES
National policy should make it clear that Green Belt does not need to be reviewed or altered when making plans.
On Housing Density, medium and high-density new housing can maximise the use of brownfield land and the most sustainable locations, whilst minimising greenfield land take. Higher densities can also be of societal good in making houses more affordable, reducing the need for travel, and helping ensure facilities are within walking distances.
Q.11: Do you agree with removing the explicit requirement for plans to be ‘justified’, on the basis of delivering a more proportionate approach to examination?
NO
The proposal to remove “Justified” from the examination test means the removal of the requirement to take “an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence”. Surely this is exactly what a good Local Plan should deliver?
Q22: Do you agree that the government should revise national planning policy to attach more weight to Social Rent in planning policies and decisions?
YES
Q.49: Do you agree with the suggested scope and principles for guiding National Development Management Policies?
NO
National Development Management Polices in principle might be acceptable, but not as currently proposed, which would give the Secretary of State free reign to create, modify or revoke such policies unilaterally, without consultation.
Thank you for having your say and helping to protect our countryside.
If you have any comments or questions about the above information, please do contact us: campaign@cpreoxfordshire.org.uk