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Digest of comments received following consultation on Draft Revised NPPG3 of March 2002
CONCLUSION
Paragraph 94
AC: The inclusion of a conclusions section should be considered very carefully to ensure that it does not allow for reinterpretation of issues considered in detail in the body of the text. Does this section actually do anything not already covered or more appropriately stated in the Introduction?
CAA: We consider that the 'key message' of seeking a good balance between the provision of land for reasonable housing requirements and the safeguard of the natural and cultural heritage and its associated recreational and quality of life values has been omitted. We urge that this message is also included.
CALA: Support the overall key messages of this NPPG, namely, good design and deliverability, preferably via the development plan system or via planning applications if there are delays in plans being adopted.
HCC: Should contain a third "key message" about community involvement or should include it specifically within the second "key message".
SEPA: Would wish to see greater emphasis in conclusion on need to provide greater emphasis on environmental implications of new development
Paragraph 95
BH: Support contents. 2 nd sentence, delete, 'and in'. Append, 'and at the right time'. In order to reflect importance attached to the delivery of housing.
HFS: In the last sentence substitute "Homes for Scotland" for "housing providers".
KEPPIE: It is important that this NPPG and PAN confirms clearly that this is not the sole criterion for releasing land or identifying the appropriate level of land required. Flexibility is therefore important and elements require to be included at both strategic (where appropriate) and local levels. It is therefore extremely important that advice in this NPPG is followed up through the Local Plan and development control process as previous planning policy has been to inflexible and not meaningfully addressed issues of locational distribution, quality and range of development sites and house types.
SC: A reduced emphasis on precise housing numbers is desirable but longer term forecasting will be necessary to estimate the amount of land that is likely to be required
SLF: Believes that the "Conclusion" in paragraphs 94 and 95 are very important, and would like to add only that the flexibility implied in the last sentence of paragraph 95 is critical to overall success.
Notes
Paragraph 96
ECA: Comments apply regarding paragraphs 29 and 60
Glossary
BH: Affordable housing - delete, 'publicly' in order to reflect that subsidised housing may also be provided by private developers, by way of 'discounted price', or 'golden share'.
Effective housing land supply - insert, 'agreed between Homes for Scotland and local authority to be' after 'or' in the second line.
CAA: The Brundtland Report 1983 amplified the definition of sustainable development given in the Glossary to his document as follows: 'At a minimum, sustainable development must not endanger the natural systems that support life on earth: the atmosphere, the waters, the soils and the living beings'. This amplification should be included in Glossary as sustainable development is often misconstrued as meaning 'sustaining development'.
CALA: Need for definition of 'effective housing land supply' to be strengthened and duplicate the current NPPG 3 with the time period under consideration being 7 years.
Definition of 'brownfield land' should explicitly include infill land that has not been previously developed or alternatively a separate definition of the term.
'Greenfield sites' should be defined as land without the present settlement envelope.
Zoned open space could be clearly flagged up as not brownfield.
ELL: Suggest the definition of Brownfield land would be clearer, and reduce lengthy debate on its interpretation, if it followed that given in DTLR's Planning Policy Guidance 3: Housing (Annex C).
FR: Definition of 'housing requirement' should be included: "The overall need for new housing in an area, due to natural increase and other factors (such as net in-migration) regardless of housing tenure."
Definition of Housing need: '…Housing need refers to households lacking their own housing or living in housing which is inadequate or unsuitable, who are unlikely to be able to meet their needs in the housing market without some assistance…' [DTLR Guide to housing needs assessment (2000): Glossary A2.2]
Affordable housing: "Housing made available at a cost significantly below full second-hand market value to meet an identified need. It includes social rented accommodation, some shared ownership" BUT NOT private sector rented accommodation, and publicly subsidised housing for sale. The reasons for omitting the two latter are as follows:
Private rented housing is market priced housing. As a result it is by definition not affordable to those in housing need as defined above. The private rented sector features, on the whole, low quality housing. Certainly the cheaper end of it, which is where the benefit tenants are found, has very high levels of both unsuitability and unfitness. It is not available at less than full market value. The real point, however, is that it represents the market, and is thus unaffordable without housing benefit to those in housing need. The private rented market has come to be a 'sink' for those in housing need who cannot obtain social rented housing.
Publicly subsidised housing for sale. All newbuild housing is much more expensive than what can be bought in the second hand market. The minimum market price is defined not as the cheapest dwellings (which may have serious repair costs) but as the price of housing that does not require significant repairs but is the cheapest housing that is in reasonable supply (by size category). Subsidy never bridges this gap. The result is that 'low cost market housing' may well be bought, but certainly not by those in housing need. The produce 'low cost market housing' tends simply to be cramped market housing. Therefor, neither affordable to those in housing need, nor adequate housing in the long term for those who can afford it. Communities Scotland has admitted that their low cost market housing does not directly meet housing need, but that people would vacate social rented housing to buy it, and thus indirectly help to meet housing need. This is a largely spurious argument. Since the low cost market housing in question is not as cheap as second hand housing, the odds are that poorer households such as would be found in social rented housing, would buy second-hand housing and not low cost. Moreover the Right To Buy legislation has creamed off most of those in the social rented sector who could afford to buy. The results of housing needs surveys show, that those in social rented tenure are now generally very poor, and unable to buy any form of housing, let alone new build. Thus there is no rational case for including any reference to new build housing for sale in the description of affordable housing.
HFS: To reflect a proposed change to paragraph 68, insert "agreed by the local authority and Homes for Scotland to be" after "or" in the second line of the definition of "Effective housing land supply".
JA: The changing definition of Brownfield Sites. It seems to me to be valid to look at what it is and also what it is not in order to define a concept. Why has the latter part of the definition been dropped in this new NPPG3?
MLC: Definition of "affordable housing" does not require the second sentence. It should not refer to public subsidisation, as it is not the source of subsidy that determines affordability
Remove "period under consideration" from definition of "effective house land supply". The words "free or" are removed as they could be construed as creating two categories of effectiveness. Suggested definition should be:
"That part of the established land supply which is expected to be free of development constraints, and will therefore be available for the construction of houses."
M&M: The definition of 'effective housing land supply' should be strengthened, to duplicate that in the current NPPG3 with the time period under consideration being seven years.
OHA: The glossary of Effective Housing Land Supply definition appears narrower than that contained in paragraph 27 and the definitions should be brought into line. Suggest it is amended to read "… which is free or expected to be free of all development constraints, including ownership and infrastructure ones…"
Private Sector Housing - To prevent confusion, we suggest the sentence is added "this will include homes built for outright sale by Housing Associations". Also not clear on the purpose of the second sentence, relating to owner occupied sector. Owner occupied sector would come within the definition of private sector housing. There are various types of development in which the ownership element is split between the developing Housing Association and the owner (currently shared ownership and shared equity housing). We suggest that where an owner has the right, eventually, to move up to 100% ownership, this element should be classified as private sector houses.
Public Sector Housing - suggest the word 'registered' is inserted before Housing Associations. The reason for this, and the preceding, comment is to achieve clarity on the different types of Housing Association which can operate which are: -
- Registered Housing Associations i.e. those which are registered with Communities Scotland under the Housing (Scotland) Act 2001. Orkney Housing Association, as a registered Housing Association, welcomes the definition of registered Housing Associations as public sector.
- A number of bodies may use the title Housing Association but are not registered. These could be bodies operating entirely without public sector money or subsidiaries of a registered Housing Association providing housing for outright sale. Suggest that both these categories be more appropriately classified as private sector houses.
It may have been unnecessary to spell out in such detail these points in planning advice. However, it is likely, somewhere in Scotland the issue may become relevant in planning appeals.
PCS: Demand - note that it can be satisfied by existing housing or by new housing requiring additional land provision. There is some possibility for understanding here, at least for the layman. We have assumed that para 77 means that for each housing market area the planning authority should ensure that the housing land requirements to satisfy the housing demand is provided in full. Conceivably, however, "housing land requirement" could be the land required for housing after all the other housing requirements in the NPPG, apart from demand, have provided for. Maybe a definition of "housing land requirement" should be provided in the glossary to clarify.
PKC: It is suggested that the definition of 'affordable housing' is revised, and that a definition for 'low cost housing' is added.
PH: "Effective housing land supply" - This definition should be amended to include "agreed by the local authority and Homes for Scotland/Housing providers" after "or" in the second line of this definition.
RC: Public Sector Housing: The term used in the Local Housing Strategy guidance for social rented housing providers is Registered Social Landlords.
Housing Market Area (HMA): There is no reference to mobile demand across the larger city areas or to a 2 nd tier HMA which could be used to address the mobile demand issue.
Greenfield Land / Greenfield Sites: The definitions are slightly different in the NPPG and PAN, which will lead to further confusion.
Greenfield/Brownfield: There is still uncertainty over which definition covers "Urban Greenfield" sites e.g. land within urban areas which has never been developed e.g. alongside a railway line, or has been a garden or grounds of a large house or hospital.
RH: The definition of 'effective housing land supply' should be strengthened, to duplicate that in the current NPPG3 with the time period under consideration being seven years.
RICS: Definition of "brownfield land" implies that it exists only within existing settlements in urban areas.
RTPI: Concerned that the definition of "effective housing land supply" continues to include land which is "free or expected to be free of development constraints" in the plan period. Would be appropriate if windfall sites were defined in the glossary.
SSDP: There still appears to be a lack of appreciation of the impact of effective housing land supply which would be much enhanced by the removal of the words "period under consideration" and "free or" from the glossary definitions
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