SUPPLEMENTARY MEMORANDUM BY CPRE (RWP
16A)
1. Positive land use planning is essential
to ensure future development in the countryside addresses rural
economic and social needs. It is also critical in protecting the
beauty and diversity of the countryside which underpins the nation's
economic, social and environmental well-being. This supplementary
evidence addresses the role of the planning system in relation
to both rural businesses and the rural environment and identifies
the importance of extending and integrating the planning system
more effectively into rural, especially agriculture and forestry,
policy and practice. It has been prepared in the light of the
Performance and Innovation Unit's report on Rural Economies.
2. CPRE identifies four key strands to the
debate over planning in the countryside:
— is planning a barrier or positive
solution to rural development?
— planning and discerning development;
— valuing agricultural land;
— planning and land management.
3. These issues are addressed below.
POSITIVE PLANNING
4. The planning system is not a barrier
to social and economic progress in rural areas. It is part of
the solution. The debate about deciding what is "acceptable
in the countryside" descends too often into an apparently
inevitable choice between promoting or restricting new physical
development through planning control. The Rural White Paper needs
to conduct this debate on new ground. It should recognise the
positive role the planning system is already playing and focus
attention on removing the real barriers to economic and social
progress. These are not a lack of planning permission for using
land or buildings but constraints on access to jobs and services
such as a lack of childcare, training facilities, transport, IT
links, healthcare and business advice.
5. Claims about the planning system restricting
change an diversification need to be tested against the evidence
and not by anecdote:
— 88 per cent of planning applications
in the 171 rural districts are approved and nationally 35 per
cent of appeals are successful (DETR 1999 and Planning Inspectorate
1998-99);
— 88 per cent of planning applications
for agriculture are approved (Rural Development Commission 1998);
— only one in six farmers who have
not diversified cite planning as a reason (NFU 1999);
— lack of financial and management
skills are the main constraint on the growth of small and medium
sized businesses (RDC 1997);
— the majority of Local Plans contain
policies supporting rural diversification (RDC 1998);
— over two thirds of local authorities
are compiling registers of sites and premises for business (CPRE
1995);
— 80-90 per cent of applications for
re-using traditional buildings for economic activity in remote
areas are approved (Department of the Environment 1995).
6. These realities are poorly recognised
in the conclusions which have been drawn from the 1998 report
of the Rural Development Commission Rural Development and Land
Use Planning Policies in 1998 by both the DETR/MAFF Rural
White Paper discussion document and the PIU report on Rural Economics.
These suggest local planning authorities are being too restrictive.
7. By contrast, CPRE believes the RDC research
provides much information to suggest the contrary. It shows that:
— local planning authorities should
be congratulated for applying the Government's policies for reducing
the need to travel and encouraging urban renewal with vigour by
concentrating development in existing settlements;
— local designations are increasingly
based on rigorous landscape assessments and there is no evidence
that such designations are adding damaging restrictions;
— approval rates for planning permissions
are running at 90 per cent and the main reason for refusal is
the inappropriateness of the development in the countryside—something
to be welcomed;
— local planning authorities are strongly
supportive of the priority to address social and economic needs
but too much is being expected from the land use planning system
which cannot address many of the barriers to opportunity which
exist.
8. In some cases existing policy needs to
be more effectively implemented. The welcome emphasis in PPG7
The Countryside on prioritising farm building conversions
for economic rather than residential use resulted in 87 per cent
of local planning authorities giving it a policy priority. Yet,
64 per cent of applications in 1992-93 were related to residential
use (Department of the Environment 1995).
Planning to ignore you?
9. One of the most damaging recommendations
in the PIU report on rural economies is the suggestion that agricultural
uses should be placed within the B1 Business Use Class. This would
extend permitted development rights (thereby removing the need
to submit a planning application) to changing the use of farm
buildings to light industry, business or warehousing. Similar,
albeit more far reaching, ideas were floated by the Government
in a consultation paper on Permitted Use Rights in the Countryside
amidst general efforts to deregulate the planning system in
1989. They were rapidly dropped in the face of almost universal
criticism.
10. The effect of this proposal is to suggest
that the use of farm buildings for other purposes will be acceptable
in all locations and that there should be no public input into
decisions over a change of use. Farm buildings down narrow country
lanes or sensitively located on the skyline would be treated in
the same way as those within villages. Equally, the subsequent
use of permitted development rights for extensions, changes to
windows, decoration, new hardstanding and the erection of temporary
structures is likely to prove controversial in many cases. There
would also be an incentive to erect bogus agricultural building
for later use. The safeguards against permitted development rights
(through issuing Article 4 Directions) are weak and ineffectual
and cannot be prayed in aid of such a sweeping change.
11. The whole approach also appears to contradict
the PIU's welcome emphasis on the need for stronger local involvement
in rural policy decisions. It recognises that "change would
generally be assisted by greater use of local deliberative processes"
and yet makes proposals to remove the opportunity for public input
into planning decisions over the use of farm buildings. This is
a recipe for conflict which falls into an all too familiar trap
of confusing the need to apply for planning permission with the
likelihood of it being granted. Planning controls are not preventing
the effective use of farm building, but they are ensuring that
inappropriate conversions do not go ahead and insensitive applications
are improved. In most cases this means development proceeds but
in a manner which is much better suited to the locality and with
wider public support.
DISCERNING DEVELOPMENT
12. The Rural White Paper should improve
the way in which the planning process can be used to stimulate
more sustainable economic development and filter out development
which brings no rural benefits and has an alternative location.
This requires changes in both policy and practice.
— needs audit—the social and
economic needs of rural areas need to be identified as a precursor
to preparing development plans and making planning decisions so
that the "match" between development proposals and rural
needs can be assessed and clear plan objectives set.
— discerning policies—the development
process should be more effectively managed to prioritise needs,
including, for example, through safeguarding land for social housing
and prioritising economic over residential conversions of existing
farm buildings. This can be further implemented through planning
conditions and agreements. In pressured areas or those where there
is ample scope for urban renewal it may be appropriate to control
footloose development and stipulate that development should require
a rural location (eg Policy S13 of the East Sussex Structure Plan
states that "Proposals for new development in the countryside
will be required to demonstrate that a countryside location is
necessary and that a town or village location would not be suitable.
. .")
— positive and participative culture—the
culture of the planning process and the skills of planning officers
needs to encourage a more positive and participative approach.
Local planning authorities should be helping businesses identify
how new development can meet planning policies and objectives
as well as refusing unacceptable development. All local planning
authorities should hold registers of available sites and premises.
Local planning authorities should be working in partnership with
local businesses and communities, Regional Development Agencies
and their own economic development departments to identify how
needs can be met within the framework of development plan policies,
including through the use of animateurs to stimulate debate and
participation and the preparation of rural strategies.
VALUING AGRICULTURAL
LAND
13. The PIU report's proposals to remove
the special status of the best and most versatile (Grades 1, 2
3a) agricultural land in the planning system has attracted particular
attention. The importance of the agricultural land issue and the
risks of changing the system should not be underestimated. Policies
for the protection of agricultural land have been a crude but
highly effective way to protect the countryside from unnecessary
development. This has brought benefits beyond the simple protection
of farmland and it is essential that these be retained in any
new national framework for valuing this land which is introduced.
14. The current system has significant limitations,
however, and CPRE has been pressing for many years for a more
wide ranging approach to valuing land which addresses other issues.
The PIU's proposals for this new approach are welcome, although
it will be important to avoid simply "protecting areas of
high environmental value" in the same way as is currently
achieved through designations. Soils contribute to much more than
the production of food and fibre and even on this measure the
agricultural land classification (ALC) is narrowly drawn. The
character of the countryside stems from the diversity of soils
and the ALC should be replaced by a more multi-functional approach
in the new Soil Protection Strategy and a revised PPG7. It is
also important that we continue to value land for its agricultural
functions. As the Royal Commission on Environmental Pollution's
report on Sustainable Use of Soil (1996) concluded "soil
is a vital resource which we believe has been taken too much for
granted". It recognised that a continuation of current rates
of urbanisation of farmland would "represent a significant
reduction in the UK's capacity to produce food". A new approach
will also need to use existing planning mechanisms to the full
and not seek to re-invent the wheel. It should be closely integrated
with the "sequential approach" to the location of development
which is now being introduced so that the policy presumption is
to make best use of urban land and only release rural land where
no alternative better locations exist and/or rural needs are being
met.
15. The new approach will not only need
to address the wider value of farmland but also be as readily
used in planning decisions as the current agricultural land classification.
The simplicity of the current system is a major reason for its
effectiveness. A new approach will need to demonstrate its effectiveness
before the existing policy presumption against the development
of the best and most versatile land and MAFF's special role in
the planning system is replaced. The problems caused by a weakening
of local landscape designations in the current PPG7 before the
introduction of an effective approach to countryside character
need to be avoided. The overall effect of introducing the new
framework should be to offer greater protection to rural land
as a whole.
PLANNING AND
LAND MANAGEMENT
16. The Rural White Paper needs to address
the anomalous position of agriculture and forestry in the planning
system and bring a more integrated and participatory approach
to both the use and management of land in the countryside. This
recognises the wider public benefits which agriculture and forestry
bring and which warrant appropriate funding from the public purse.
The issue has been most recently highlighted by the UK Round Table
on Sustainable Development report Aspects of sustainable agriculture
and rural policy (1998) which concluded that closer co-ordination
between land use planning and land management policy was needed.
It was also addressed in the joint report of the working group
set up by CPRE, the National Housing and Town Planning Council
and the Association of District Councils on Planning control
over farmland (1990). The PIU report also highlights the anomaly.
17. This requires action to:
— remove the privileged position of
agriculture and forestry by withdrawing permitted development
rights for agricultural and forestry development and the temporary
use of land so that new farm buildings and other developments
are brought under normal planning controls;
— address the omission of agriculture
and forestry from the legal definition of "development"
in the Planning Acts. Major agricultural operations (such as the
ploughing up of moorland or ancient meadows) and major felling
and planting operations should be brought under planning control.
Extensive permitted development rights should be granted for other
agricultural and forestry operations;
— integrate forward planning for land
use and land management. The objectives and policies of Regional
Planning Guidance, Structure Plans and Local Plans need to be
shared with those of management plans (eg for AONBs), countryside
strategies, indicative forestry strategies and the new regional
chapters of the Rural Development Plan being set up to implement
the Rural Development Regulation. This will allow for greater
synergy between planning, land management and funding streams
to achieve shared objectives as recommended by the Round Table;
— implement the EU's requirements for
Environmental Impact Assessment for major agricultural activity
that should have been implemented by 1988.
January 2000
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