RCA's 38 Days of the Housing White Paper; Day 8...

Everyday for the next 31 days we will be providing a link to our responses to the Government's Housing White Paper; here is our reply to Question 8... 


Do you agree with the proposals to amend the National Planning Policy Framework to:

a)    Highlight the opportunities that neighbourhood plans present for identifying and allocating small sites that are suitable for housing?

While we support this proposal, experience shows that some neighbourhood plan teams lack the experience or skills to identify potential sites nor have the finances to instruct consultants to do so on their behalf.  Strong consistent guidance should be in place for neighbourhood plan teams to refer to when identifying suitable sites.  There is very little incentive for Neighbourhood Planners to encourage new development at the moment and this has to change.

There are also availability issues associated with this as smaller sites are often not available for development and often come forward as a result of the owners’ initiative.  This makes it hard to know when or if a site will be available.  Whilst the neighbourhood plan team may not be able to allocate some small sites, they should be equipped with the knowledge to identify and assess the sites effectively and allow dialogue with individual landowners.

Additionally, as neighbourhood plan boundaries often cover rural land, there are often sites which are appropriate for housing development which are not situated within the defined settlement boundary of a village.  For example, some farms situated outside a main settlement may also be suitable for a small residential development and the Framework could be amended to include a set of criteria which can be used by neighbourhood plan groups to assess small rural sites.  Further, where a settlement boundary is not in place, proportionate growth should still be encouraged to support the rural economy.

b)    Encourage local planning authorities to identify opportunities for villages to thrive, especially where this would support services and help meet the authority’s housing needs?

We support this principle.  Encouraging all types of development in villages and rural areas is essential to support the rural economy.  In particular, development should be encouraged in villages with existing key services such as a post office and primary school which are vulnerable or at high risk of closure - encouraging diversity is key.  At present, the Framework policies covering rural housing and the rural economy of villages and rural areas are separate to each other, rather they should be combined to tackle issues in a holistic manner which will support the rural economy as a whole, this is more aligned with the three pillars of sustainable development than the current approach.

c)    Give stronger support for ‘rural exception’ sites – to make it clear that these should be considered positively where they can contribute to meeting identified local housing needs, even if this relies on an element of general market housing to ensure that homes are genuinely affordable for local people?

We fully support this principle.  The Framework gives very little guidance on rural exception sites at present resulting in an inconsistent approach when decision making between local authorities, for example a site located on the edge of a market town is considered rural by some but urban by others.  Clear definitions of ‘rural land’ and ‘urban land’ should be established.  Further, rather than allowing local authorities to consider if an element of market housing should be included in the proposal, it should be clearly stated that market housing is accepted to enable the proposals to be viable.  Stronger support and clear guidance will help steer what is appropriate in terms of a rural exception sites.

We consider that market towns (where affordable housing need is often concentrated) should also be allowed rural exception schemes on their boundaries, not just villages.

d)    Make clear that on top of the allowance made for windfall sites, at least 10% of sites allocated for residential development should be sites of half a hectare or less?

We do not support this principle and it is not clear where this 10% figure has come from.  Further evidence is required to clarify why 10% of allocated sites should be half a hectare or less to provide a full opinion on this.  Furthermore, it can be difficult to identify small sites as available or deliverable unless the landowner has come forward to promote the site.

It may be difficult for some local authorities to achieve this figure due to the nature of the sites which have come forward in the plan process.  It could result in a reduction of the overall supply and risk allocating sites which have too many constraints just to meet this requirement.  

e)    Expect local planning authorities to work with developers to encourage the sub-division of large sites?

We do not support this proposal.  It is not the role of the Planning System to dictate who can bring forward development and when. 

f)     Encourage greater use of Local Development Orders and area-wide design codes so that small sites may be brought forward for development more quickly?

We do not support this proposal.  LDOs have been available for a number of years but with very little uptake.  This is because each application needs to be determined on their own merits.  The design of the scheme at one end of the village might not be appropriate at the other end.

We do not consider that LDOs ‘de-risk’ any more than an allocation or outline consent and the time taken to secure them could be better spent taking an application through the development management process. 


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