Borough of Poole

APPENDIX

Borough of Poole’s general response to the consultation questions set out at Part 4 of PPS3.
Name:Lucy Cooper

Organisation:Borough of Poole

Address:Civic Centre, Borough of Poole, Poole, Dorset, BH15 2RU

Email:

Please find below the Borough of Poole’s general response to the consultation questions set out at Part 4 of PPS3. A schedule is also included with additional comments that we would wish to have taken into consideration.

  1. Do the policies set out in the draft PPS3 deliver the Government’s housing objectives (set out in paragraph 1)?

The Government’s objective is to ensure a choice of housing size, type and tenure within communities that are sustainable, inclusive and mixed, in locations with good access to jobs, key services and infrastructure.

Housing Market Assessments

We agree that PPS3’s key policy of determining the region’s level of housing provision and its distribution through sub-regional housing market assessments will enable a more targeted approach to the issue of medium to long-term housing provision, and enable a greater responsiveness to the housing needs of catchment populations, not only in terms of basic unit number provision, but also with respect to required unit tenure, size and type. In addition, the housing market assessment approach will bring a better appreciation of housing needs, supply and demand within in a broader, spatial context, encompassing economic and infrastructural shifts and patterns. Clearly, such an approach will have implications in terms of human and financial resourcing for individual local authorities, particularly at the outset. However, by encouraging more collaborative, cross-authority working costs may be spread and the benefits of data and information be shared across a wide area.

Housing Land Availability Assessments

A sub-regional approach to assessing land available for housing development is also welcomed by Borough of Poole, and will provide a constructive assessment of the potential land resource commensurate with the aims and objectives of the housing market assessments. However, we would agree with the Housing Land Availability Assessments draft practice guidance document (2005), paragraph 51, that unless there is consistency of approach, methodology and output methods between local authorities, such assessments may hinder a full sub-regional understanding of housing demand and potentially harm appropriate supply.

Brownfield Land

We support the Government’s continued commitment to achieving at least 60% of additional housing on brownfield land. We also accept that in order to achieve this level of brownfield development, local planning authorities will need to encourage higher densities. Whilst the indicative density ranges set out in Annex C of the document provide a guide to what can be achieved in certain locations, the emphasis on excellent, sustainable and energy efficient design when developing to high densities cannot, in our view, be understated. In light of this view, and the statement given in PPS1 – Delivering Sustainable Development, that “good design is indivisible from good planning” (paragraph 33), we would welcome a reiteration that individual applications must be dealt with on a design-led and not density-led basis.

Density Ranges and Annex C

In respect of the Borough of Poole, we have an additional concern that the density guide in Annex C and the references to setting out density ranges that will apply across a Plan area at paragraphs 12 (h) and 19 may be counter productive to the Government’s aim to achieve higher densities within mixed and sustainable communities. For example, we would estimate that, outside of the town centre area, the majority of residential development in Poole currently reflects a ‘suburban’ character, as set out in Table 1 of Annex C. In some instances, residential sites within such areas may present an opportunity for residential development at significantly higher densities than those identified as ‘Suburban’ in Annex C. In its current wording, Annex C may hinder opportunities to maximise the efficiency of sites in accessible, suburban locations. Whilst we note that the densities in Annex C are ‘indicative’, it is our view that advice regarding the application of the density ranges should explicitly encourage a flexible approach so as to support pockets of higher, or indeed lower, densities within specific types of location. However, it is important that in encouraging high density development that PPS3 places firm emphasis on the importance of the good design – good planning partnership, and not encourage a ‘planning led by density’ attitude.

Car Parking Policy

Encouraging a real shift in attitudes and practices away from the private car and towards more environmentally, socially and economically sustainable transport modes requires a cross-policy approach, of which robust but reasonable car parking guidelines and policies are an integral part. We therefore question the wisdom of the Government’s revised approach to car parking policies as set out at paragraph 20. Promoting a policy approach based on ‘expected car ownership’ absorbs the status quo of unsustainable transport and settlement patterns and fails to provide an aspirational policy framework to effect positive change. The proposed framework builds in a degree of uncertainty and ambiguity and will undoubtedly be counter productive to broader efforts to encourage a more sustainable approach to transport choices in residential areas.

Affordable Homes

We welcome the Government’s continued commitment to encouraging the provision of affordable homes within mixed and sustainable communities. We agree that a site-size threshold policy, either expressed as number of homes or area, can be a helpful approach in some circumstances to achieving affordable homes within mixed communities. However, in urban areas such as Poole, large, allocated sites and non-allocated sites capable of achieving more than 15 units (the indicative national minimum threshold) will become increasingly more scarce, and therefore our ability to realistically achieve the required affordable housing quota may be hampered. In light of this inevitable land resource trend, we welcome the apparent flexibility built into PPS3 on this issue, and appreciate that forthcoming housing market assessments and existing data regarding housing need will help the Authority determine an appropriate site-size threshold policy.

However, we are also mindful that smaller site size thresholds could impact on the overall financial viability of sites that may come forward for development. The development of affordable units on small sites is likely to be financially unattractive to developers, and applications will be subject to delays as S106 agreements are negotiated and completed. Creating such a climate for residential development may cause other long-term discrepancies in the balance of housing stock and type as smaller sites are brought forward for flat development in order to maintain financial viability. Whilst clearly flatted development has a valuable place in the range of housing types, housing market assessments and housing needs surveys may indicate that such development will not meet long-term and sustainable need. Clearly, LPAs will need to balance issues of demand and appropriate supply and make judgements as to how best to formulate policies to meet local affordable housing need. However, the issue raises important questions about affordable housing deliverability, and we would welcome a wider, high-profile debate, with all stakeholders, on this matter in order to inform appropriate action in the future.

Environmental Sustainability and Energy Efficiency

Whilst the policies outlined in PPS3 may help deliver a choice and balance of housing stock, there is serious concern and doubt as to whether truly sustainable communities can be developed given the document’s acute shortcomings with regard to sustainable design and construction methods. The unsustainable nature of current patterns of living, development and resource use is such that there is now an urgent need to provide local and regional planning bodies with a robust policy framework in order that they can deal confidently and effectively with climate change at a local and sub-regional level, and help deliver the Government’s own stated targets.

Paragraph 39 in particular represents a missed opportunity for local authorities to influence a genuine shift in attitudes and practice in sustainable construction and design by inviting LPAs to merely ‘encourage’ developers to apply the Code for Sustainable Homes, and then only in the case of ‘strategic sites that deliver a large number of new homes’. It is inevitable that housing developments, both large and small, will have an impact on environmental factors such as CO2 emissions, water usage, waste generation and disposal, and ecosystems, both during construction and when occupied. Therefore we would welcome robust and unambiguous tools to ensure that housing developments across the board can apply environmental ‘best practice’.

Managing Delivery and Development

We are concerned that the approach set out in paragraph 41 (a-c) is contrary to the principles and spirit of the plan-led system. The criteria for assessing applications for housing which are received in advance of the relevant DPD being reviewed are, in our view, too lenient and, particularly in rural areas and urban fringes, could result in the proliferation of greenfield development undertaken in an ad hoc manner and which does not accord with a strategic and spatial approach. We would welcome a review of this paragraph to reflect the requirement for a strategic approach to the provision of sustainable residential development and the creation of mixed communities.

  1. Are the arrangements for delivering PPS3 clearly set out in relation to:

(a)Working in sub-regional housing markets?

The specific detail regarding how local authorities are to work collaboratively with other local authorities within sub-regional housing market areas is slim, however other government advice specifically addresses this issue. Certainly, the emphasis on a sub-regional approach to determining housing supply and demand is quite clear in the document, and it is clear that this is central to the Government’s aims of achieving a housing supply that realistically meets demand, and securing a viable choice to serve communities.

(b)Determining the regional level of housing provision and its distribution?

In the main, the guidance on this issue is relatively comprehensive (paragraphs 7 and 8). However, paragraph 9 is surprisingly brief in its direction to regional planning bodies regarding influencing housing supply in areas of high and low demand. Particularly with respect to areas of high demand, there is no guidance as to how local and regional authorities are to identify and plan growth areas, growth points, new freestanding settlements etc. The scant planning guidance, and lack of obvious ‘joined-up’ thinking between such solutions and the other aims and objectives outlined in PPS3 is alarming given the environmental, economic, infrastructural and social implications that such settlement options would undoubtedly have. We would welcome more clear and robust advice on this issue.

(c)Allocating and releasing land for housing?

We welcome a less prescriptive approach to the issue of reviewing non-housing allocations for housing or mixed use development than that expressed in Update to PPG 3: Housing: Supporting the Delivery of New Housing. It is our view that the housing market assessment approach will allow LPAs to be more responsive to housing need, and enable housing need to be assessed within a realistic economic context. Given that LPAs must deliver housing which supports and contributes to vibrant, economically active communities, a flexible approach to land allocation review is needed in order to ensure that all economic, social and infrastructural aims are delivered.

(d)Making efficient use of land?

As stated above, we welcome the Government’s continued commitment to providing 60% additional housing on brownfield land. We are also in agreement that efficient use of such land can be achieved through densities upwards of 30 dph, depending on location. However, we would welcome a stronger statement ensuring that excellence in design, residential character, (which includes planning for meaningful and accessible open spaces within developments) and real, identified housing need are not sacrificed for the pursuit of high density development.

(e)Planning for mixed communities?

In order for communities to be mixed, sites must offer a mix of housing type, tenure and size, and be accessible to, or unilaterally provide, those social, environmental and economic facilities that enable spaces to become places. It is imperative that in the rush to fulfil housing target, the creation of vibrant, supportive communities is not lost. The current emphasis in PPS3 does not provide that assurance. In addition, we reiterate here the problems we anticipate with regard to affordable housing provision in the long-term that are set out above.

(f)Planning for rural housing?

The Borough of Poole is largely an urban and suburban location, and does not include ‘rural communities’ per se. However, by engaging in the sub-regional housing market area approach, we accept that the Borough may, in the future, be required to consider the implications of the HMAs housing demand and supply on the rural communities of partner authorities.

(g)Designing for quality?

We welcome the emphasis on community engagement and wider stakeholder participation in developing plans and policies to help develop attractive, vibrant and inclusive communities. The urban design principles set out in paragraphs 34-37 are sound and can be adapted to the circumstances of individual local authorities. However, we would welcome mention of the contribution that energy efficiency and environmentally-friendly principles can make to the quality of urban design and the long-term success of communities.

(h)Greening the residential environment?

As stated under Q.1, we find this section the weakest in PPS3 with respect to meeting the Government’s aims of delivering sustainable development and communities. It is imperative that LPAs are given the opportunity to positively influence the environmental direction of future development. We would welcome a revision of paragraph 39 in order to bring PPS3 in line with both the Government’s stated environmental targets and ambitions, and with the urgency of the environmental situation that we currently face.

(i)Managing delivery and development?

We are in agreement that in terms of managing choice and balance of delivery of housing to feed a realistic demand, the housing market assessment approach offers a sensible and useful approach. However, it is essential to achieve a proper balance between the delivery of housing and the integrity, appearance and character of our urban and green environments. The importance of excellent, sustainable and context-driven design cannot be overstated and we would welcome a reiteration in PPS3 that poor design will be rejected by LPAs.

  1. Are the definitions set our in Annex A clear?

Yes, the definitions are clear.

  1. Equality Issues

We welcome the inclusion in policy of the requirement to address the accommodation needs of gypsies and travellers.

PPS3 – Housing (Consultation Paper)

Supplementary Schedule

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Issues and Comment

General / Reference is made to the companion guide to PPS3. We would welcome the publication of this guide as soon as possible in order for a full assessment of the implications of PPS3 to be determined. Particularly in respect of affordable housing, the companion guide is crucial. We would welcome an update of the progress of this document on the ODPM/Planning web site.
13 / We would welcome greater clarification about how the 5 year supply of developable land is to be calculated, given that such land is to be available from the date of adoption of site specific allocation documents. This approach relies on the date of adoption of a Site Specific Allocation document as published in the LDS and as such does not make allowance for economic, commercial and other events outside of the LPA’s control which may alter the status of land identified for housing and may result in adoption being delayed. In addition, land release identified on this basis will result in a greater disparity between the timetables of DPDs and the RSS, which could in turn lead to possible confusion and uncertainty across the plan-making process.
20 / Our concerns about the ability of the proposed car parking policy approach to enable significant, positive change with respect to sustainable communities and transport options are set out in the main document. If such an approach is adopted, more advice and guidance will be required on how LPAs are to calculate ‘expected car ownership’.
31 / Advice contained at this paragraph loosely sets out circumstances in which developing greenfield land may be developed for residential development. In our view, this advice is contrary to that set out in the draft South West RSS which deters LPAs from considering greenfield residential development. We would appreciate clarification as to the status of advice in the RSS on this issue.
39 / This paragraph suggests that LPAs ‘give purchasers and tenants information on the running cost and sustainability of their new home’. Whilst this Authority fully supports encouraging applicants to apply the principles of sustainable development and construction, we would question that it is the LPAs’ role to ‘give purchasers and tenants information on the running costs and sustainability of their new home’. In our view, communicating this type of detail should be the responsibility of the developer or agent. We would welcome clarification as to the roles and responsibilities in respect of this aspect of the Government’s sustainability agenda.

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