Duncan Hartley, director of planning at rural development consultancy Rural Solutions, highlights a number pointers on applying the National Planning Policy Framework (NPPF) to boost housing supply in rural areas.
1. Challenge outdated approaches by local authorities
Many local planning authorities and planning professionals are repeatedly failing to apply paragraph 55 of the NPPF correctly. The key part the paragraph states: “To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities”. The paragraph qualifies that where there are groups of smaller settlements, development in one village may support services in a village nearby and so enhance or maintain the vitality of these interdependent rural communities. The guidance goes on to state that policies which restrict or exclude development in one settlement for the benefit of another should be avoided.
We have found many local planning authorities which are still slavishly following and repeating the safe and known old order of settlement hierarchies and are not grappling with the new order. It is essential that these approaches are challenged at the consultation stages of the local plans and that an evidence base is provided or sought which identifies how the decision takers can assist in enhancing or maintaining the vitality of all rural communities.
2. Properly apply the new transport policy regime
The NPPF does not require that locational choices for development are made purely against an objective to reduce the use of the private car, seeking instead to balance the transport system in favour of sustainable transport modes and give people a real choice about how they travel. It recognises that different policies and measures will be required in different communities and that opportunities to maximise sustainable transport solutions will vary from urban to rural areas (paragraph 29).
The framework has deliberately moved away from a focus of locating the majority of development in service centres, where it can be accommodated without the need for residents to travel to access services and employment that was at the core of earlier policy (Planning Policy Statement 7). However, much local plan policy is still being written and planning decisions are still being made with the old order in mind. It is essential to note that accessibility is one issue of sustainability, to be addressed in the planning balance on the three dimensions and it is not the singular dominating matter.
3. Up to date housing pipelines are not an automatic barrier to additional housing
The successful application of NPPF paragraphs 49 (housing supply not up to date) and 14 (presumption in favour of housing supply) for rural and urban housing schemes continues to be commonplace in the absence of demonstrable five year supplies of deliverable housing sites. However, even when local planning authorities have their required supply base, that is not the end of the story. The aim of policy in the framework (paragraph 47) is to boost significantly the supply of housing. The proposed changes to the NPPF in December 2015, John Howell MP’s review of the local plan process in September 2015 and the Rural Planning review (February 2016) are only a handful of current policy and practice review processes that focus heavily on the urgent need to make step changes in the delivery of housing.
It follows that just because a council can meet its targets does not mean that more housing should necessarily be refused. We are seeing repeated appeal examples, where rural housing schemes are being allowed where the schemes are helping to deliver on this challenging national objective, even if councils have demonstrated their five year housing land supply.
4. Marshal a strong evidence base
It is no coincidence that the short 52-page framework uses the word ‘evidence’ 29 times. It is an obvious statement that a strong evidence base must lie at the heart of all planning decisions. However, we so often see the failure of arguments for rural housing schemes, resulting from the paucity of evidence presented by councils and professionals. There are very significant sources of accessible data on the internet or to be purchased at limited cost. The skill is in not only finding those resources but in translating and applying them correctly.
5. Read and make use of recent appeal decisions
Appeal decisions are always helpful in seeking clarification on the application of policy. Below, I itemise only a few material issues of note that have arisen from recent rural housing appeals:
– Skewed sustainable development decision taking: “In applying the presumption in favour of sustainable development it is necessary to undertake a balancing exercise that is skewed in favour of granting permission” (Inspector, Pete Drew);
– No Cap on Sustainable Development: “In any event, sustainable development should not, I consider, be restricted solely because a projected allocation has been met, if otherwise found acceptable.” (Inspector Peerless);
– Development in one village supporting services in another: “…Toft, in combination with Comberton, is capable of meeting a number of the day to day needs of its residents.” (Inspector Radcliffe);
– Car use and short journeys: “Whilst the proposed (transport) offer provides a reasonable choice, the rural nature of the site and complex travel patterns associated with everyday life are such that the car will remain the most popular choice,..…. Accordingly, it is likely that most car journeys would be short. This is a matter that weighs in favour of the proposal…” (Inspector Preston).
The above briefly represents only a handful of pointers towards seeking to achieve planning permission and allocation of rural housing schemes. England’s rural areas make a vital and valuable contribution to social, economic and environmental vitality. Rural settlements are great places to live and good places to host housing. The conclusion of any credible analysis must be that the rural area of every local authority should have a fundamental place in its spatial strategy for the development of new houses. The NPPF is a very significant tool in the delivery on the nation’s housing need. There is clearly still much we can learn from and in its application.
By Duncan Hartley