A few days ago a local landowner and developer announced plans to build 155 homes on land near the village of Cottingley (yes folks the place where the fairies live). The site in question is in the 'green belt' although the owners have, I suspect, a reasonable chance under Bradford's local plan of seeing it allocated for housing. I'm also sure that the development will be fought tooth and nail by neighbouring residents.
The applicant knows that he has to make the case that there is an overwhelming need for the the homes such that the Council can set aside the current 'green belt' designation. They have this to say:
“We are aware of a very acute shortage of local housing and we are proposing to submit a planning application that not only delivers market and affordable housing to meet a local need but also propose very extensive areas of public greenspace to be enjoyed by all local residents. We are proud of our local business development achievements and have held this land for a considerable number of years."We are then reminded that the Council has failed year after year to get anywhere close to the target set for new homes (it was over 800 short for 2017-18) and that there is a real shortage of housing as witnessed by the rise in house prices. I'll leave this to play out (I'm no longer Cottingley's local councillor) but my best guess is that, despite the lack of a five-year land supply, the development will be refused on 'green belt' grounds.
Instead I'd like to talk about Bradford's local plan and, more broadly, about the local plan process in general. Responding to the proposed development the Council says this:
“The proposed core strategy does not allocate any housing sites in Cottingley, however, the review is in its early stages and will be subject to consultation and examination. It could be several years before it is formally adopted.”The first part might mislead - the purpose of the core strategy is to establish what housing is needed and where. It may not allocate housing sites but it does identify the amount of housing needed in places like Cottingley. Bradford Council formally adopted a core strategy in July 2017 and this tells us that Cottingley needs 395 new homes during the plan period. Given the village is entirely surrounded by 'green belt' the only place for this housing to go is on that 'green belt'. So the landowner has a point.
But Bradford Council, a matter of months after approving a core strategy and before it had got round to deciding precisely where it wanted the new housing (and other stuff) to go, has decided to review its core strategy. Ostensibly this review responds to changes in national planning policies such as a standard method to the calculation of housing need and adjustments to the definition of affordable housing. The Council also spotted - I made a lengthy representation at examination on this so it wasn't a surprise - that a lot of housing sites in the inner city are not viable and is saying now that "deliverability and viability" are central to plan-making.
So, while Bradford Council does have an adopted core strategy it doesn't have a completed local plan and is reviewing that core strategy. The Council say that formal adoption isn't expected until "early 2022" and this assumes the process runs smoothly, that there aren't further tweaks needed following national policy debates and that the politicians allow time. And only when this process is complete can the Council begin to look at actual allocations. It could be 2025 before the Council has a complete, examined and adopted local plan. The process of producing the local plan started in 2008 - seventeen years filled with consultancy reports, housing assessments, calls for sites and regulatory appraisal documents, examinations and political bun fights.
Am I alone in thinking this is no way to run a planning system and that it's no surprise to see landowners, house-builders and developers jumping the gun to push forward sites they want to develop - sites Bradford needs to meet housing requirements. And Bradford is not alone - by 2017 over 40% of English planning authorities had not adopted a plan and many began their process before Bradford. And, since this year's local elections, council after council is trying to pull their local plan (examples include Vale of White Horse, Woking, Guildford, Braintree and Uttlesford) because the new political leadership got elected off the back of opposing housing development. The system is a joke.
If a sensible government wants to improve housing delivery, save local councils money and have a planning system that is accessible then the best piece of advice I can give them is to scrap the local plan process. It is unwieldy, over-complicated and inefficient. It's reliance on a comprehensive evidence base is ludicrous because the time taken to gather the evidence and have it examined makes that evidence, in a dynamic environment, out-of-date. The result is Councils, Bradford is a good example, that do and redo strategic housing market assessments and land availability assessments in a vain endeavour to get an up-to-date plan. Great news for consultants but not for an efficient planning system.
We need either a much simpler and more broad brush system or else to deal with applications on a case-by-case basis using rules on rolling land supply (five years worth of housing sites, for example) alongside wider protections (landscape, heritage, ecology, etc.) to make decisions rather than wait for an allocations plan. Alongside sensible changes to national policies around 'green belts' such as excluding previously-developed land from 'green belt' constraint this could result in a planning system more able to meet need that the elaborate and expensive plan-led approach we use today.
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