We are submitting these views to help inform the Government as part of its consultation on four proposals to change the existing planning system.
We endorse the response submitted by the national Association of Green Councillors (AGC).
Specifically, we comment as follows:
The standard method for assessing housing numbers in strategic plans
1. We acknowledge the need to build more housing – but it must be the right housing, of the right size, in the right place.
2. The focus on the “number of dwellings” does nothing to address the complexity of housing need. There is a world of difference between 300,000 executive homes in the Green Belt and 300,000 student bedsits in the city centre but the Government’s proposed approach does not differentiate between these two extremes. Whether set locally or nationally, any targets must be broken down by size of dwelling.
3. Developers aim to maximise profits by squeezing in as many separate “units” of accommodation as possible. However, this does harm to city centres like Sheffield, where there is a shortage of accommodation for families or for longer-term use. Conversely, there is an excess of student accommodation, which is not being filled. Having an overall target for new homes puts pressure on the local authority to meet the target with large numbers of very small flats instead of the range and mix of housing types that are needed.
Delivering First Homes
4. We understand this policy proposal to mean a reduction in the amount of affordable housing to rent, in order to increase sales of discounted housing.
5. This is the wrong approach: there needs to be more affordable housing to rent and more social housing.
6. The Government’s response to the earlier “First Homes” consultation demonstrates that most local authorities shared these concerns, whilst those organisations set to profit from this change (principally developers) supported the proposal.
Supporting small and medium-sized developers
7. We note this proposal will reduce the amount of affordable housing to be provided.
8. Despite the headline, it appears that large property developers will be the main beneficiaries, as the proposal relates to threshold changes for “small sites” not “small businesses.”
9. At present, property developers can be exempted from providing any affordable housing at all if the development is less than 10 properties. These building firms will not benefit from the proposed change.
10. We do not support the lifting of this threshold. If a property developer is big enough to build at least 40 or 50 homes in one go, as is proposed, we do not believe most people would regard them as being a small business that should be exempt from any contribution to affordable housing whatsoever.
Extension of the Permission in Principle consent regime
11. We do not agree with this furthering weakening of planning control by local authorities. We oppose this move towards greater centralisation, taking power away from local communities.
12. Whilst the permitted development scheme is different, it also has the effect of taking power away from local communities. Our experience is that the existing permitted development regime has led to poor quality residential conversions that cause problems for residents of both the conversions and neighbouring properties. As councillors, we have to respond to issues that could have been designed out had adequate planning controls been in place. We have been made aware by disabled people that permitted development conversions can result in inadequate access for disabled people because of the lack of local authority scrutiny. We therefore do not agree with increased deregulation. It conflicts with the aim of the “Planning for the Future” white paper to focus on good design.
13. It also seems to offer little advantage for developers and we note the Government’s own evidence that developers have limited understanding of the current system “permission in principle” regime.
Equality
14. We are concerned that no equality impact assessment has been carried out on these proposals as a whole, other than for the First Homes proposal. Disabled people face many more barriers to adequate housing compared to the general population. BAME populations may face additional barriers due to lower average incomes and to family size.
15. The public sector equality duty, which is the legal duty set out in section 149 of the Equality Act 2010, includes the particular duty to have due regard to the need to take steps to meet the needs of people with disabilities where they differ from the needs of those without disabilities. It also includes the duty to have due regard to the need to tackle prejudice and promote understanding. This may be particularly relevant, for instance, to the arrangements for affordable housing.
16. The proposal should therefore not be taken forward without a full equality impact assessment.
Cllr Douglas Johnson
Sheffield Green Party
1 October 2020
Comments
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