The Government is proposing that each Local Planning Authority must identify previously unallocated brownfield sites which are suitable for housing development, and that each must put in place Local Development Orders for 90% of these sites by 2020, with 50% having LDOs by 2017 (‘Building more homes on brownfield land – Public consultation. response and feedback’)
I have long said that Simplified Planning Zones have a role to play in helping to bring forward sites for development (not just for housing), and it has surprised me that so few Planning Authorities have even considered them as part of their tool-kit (in fact I am convinced that many have never heard of them). So, I support the use of Local Development Orders where appropriate, but not as a blanket solution imposed from on-high.
The Government’s consultation document sets out a proposed definition for brownfield land suitable for housing which I agree with. However, it must be stressed that not all brownfield land sites are suitable for housing because of their location and it must be recognised that this is a vital issue. Sites for housing must be well serviced by transport and communications; be well supported by infrastructure and services of all sorts, and be in locations where jobs and employment can be easily accessed. We must avoid the mistakes of the past where housing numbers were given priority above all else, and the wrong sort of homes in the wrong locations were built with us still paying the social and economic costs today.
I am also concerned about large sites being designated as brownfield when in reality only a small proportion of these sites were actually previously developed and there are large areas of undeveloped greenfield within the ownership envelope – for example on large Ministry of Defence Sites. I am not saying that the greenfield should not be developed, where appropriate, but the figures mustn’t be ‘fiddled’.
As an ‘incentive’ Government proposes that for those authorities which fail to have Local Development Orders in place central Government ‘designate’ them (essentially do the job themselves). I think it is vital that there must be some sort of difference in treatment between those authorities which under-perform despite their best intentions and endeavors, and those which are being deliberately obstructive (or are just incompetent) in planning for and processing appropriate development in the appropriate locations. Punishing poor performance which is due to lack of resources to carry out the work required to a high standard will lead to resentment, as well as risk inappropriate development due to the work being taken over and carried out by the ‘centre’ which does not fully understand the local circumstances.
Establishing Local Development Orders will only work in providing Places which Work for People if Local Planning Authorities have the required level of resources to develop good quality orders. Development Orders must be of high quality if the right sort of development is to be delivered in the right locations, and to secure the wide spread support from local communities. It needs to be recognised, and accepted, by Government that the aim is not to deliver a high level of house building at any cost, but to deliver ‘Places which work for people’ and which are sustainable through a constantly changing economic, environmental and social environment.
The interim target of having DLOs in place for 50% of suitable sites from 2017 does not provide sufficient time to prepare high quality Development Orders, and quality is just as important (and in the long-term, more important) than quantity. ‘Designating’ authorities, with their powers taken over by central Government, should only be done if they are being deliberately, or negligently, obstructive rather than lack of sufficient progress is due to lack of resources.
All in all, the proposed approach from central Government is only sensible if the local authorities have the required level of resources to do the work to a high quality. These resources must be available according to need, not subject to a bidding competition to a limited pot of funding. If the Government wishes to have more sites allocated for housing development, instead of using the ‘stick’ they may be better off understanding and addressing the reasons why Local Authorities are tardy in bringing forward sites for development: often this is because the funding required to service the additional population arrives too late or not at all.
It is vital that local planning authorities have sufficient and high quality planners, and other professionals and professional support, to develop and deliver Local Development Orders, as well as the resources to provide the evidence and the level of detail appropriate for each development order. Without the necessary resources the proposals will be seen as a heavy stick with which to beat local communities rather than a genuine effort to help provide the appropriate homes in appropriate locations in appropriate communities.
Update:Since posting the above I have seen this report from the IFS ( http://www.ifs.org.uk/publications/7621 ) which says that Local Authority Planning and Development Departments have had the largest cut of all other service areas, with their funding cut by half of what they had in 2009/10. This looks worrying in view of my opinion that Making Places which Work for People requires good Planning.