Select Committee on Office of the Deputy Prime Minister: Housing, Planning, Local Government and the Regions Written Evidence

Memorandum by the Peak District National Park Authority (NPA) (AH 28)

Locally Needed Affordable Housing in the Peak District National Park: Developing Rural Exceptions Policy Into Practice, November 2005

  A submission to the ODPM Committee on Affordability and Supply of Housing—on behalf of the Peak District National Park Authority (NPA) outlining the results of a long term, sequential process to the improvement of policy and implementation for housing in a highly constrained nationally recognised landscape. This work has been commended by the East Midlands Royal Town Planning Institute is one of 16 finalists in the RTPI's national awards to be announced in February 2006. We hope that the submission will assist the Committee in its valuable work.

  This submission summarises:

    —  the nature of the problem in the Peak District National Park;

    —  the land-use planning solution that has been developed over the past 16 years; and

    —  the partnership working that forms an essential part of that solution.

  The hyperlink to NPA documents that set out the full suite of policy and guidance is Peak District National Park Authority (scroll down page when open for detailed links to Structure and Local Plans and Supplementary Planning Guidance). The hyperlink to East Midlands RSS is Government Offices . . . East Midlands . . .

  The NPA has made representations to Government based on this work as part of the response to the Barker review and in writing in response to two recent consultations on PPG3. In these it stressed the overriding need for Government to ensure that any changes to the planning system or guidance in relation to affordable housing should take care not to prejudice past successes. The two written responses are appended to this submission. The requests for further discussion have not been taken up.

  We are very concerned that future policy changes should not jeopardise past success and feel that this is best explored in discussion. In addition, there is a need for:

    —  a clear understanding with mortgage lenders as to the relationship between section 106 agreements and lenders' concerns about possible encumbrance in the event of re-possession;

    —  introduction of a specific use-class for affordable housing if rural sites are to be shown on plan;

    —  attention to be given to the disparity between need assessments arising from housing authority commissioned surveys on the one hand and population / household models on the other. This is apparent at all spatial levels; and

    —  clarity on the effect of non-land use policy changes on the supply of affordable housing—for example in relation to personal pension proposals and any possibility of further right to buy affecting social housing stock.


    —  The local housing market is under severe ongoing external pressure: easily reached from conurbations with demand for commuter, retirement and second homes.

    —  Many local people cannot compete in the housing market.

    —  Government and the National Park Authority want balanced, sustainable communities, compatible with statutory purposes to conserve and enhance the Park and promote understanding and enjoyment.

The Land-use Planning Solution

  The NPA has ensured that policy and practice respond to changed circumstance, politics, committee and appeal scrutiny, as well as to local, regional and national forums. It is determined that affordable housing should remain available to meet local need in perpetuity. It has retained a tenure neutral policy consistent with Government guidance (unlike those authorities that view affordable housing only as social housing).

    —  1988: Established and convened the Peak District Housing Forum to consider housing delivery.

    —  1989: First to apply the Ridley (now PPG3 Annex B) "rural-exceptions" approach to an entire Authority area.

    —  1994: National Park Structure Plan seeks population stability in tandem with strategic conservation by adopting zero allocation for open market housing and permitting (by exception) locally needed affordable housing.

    —  2001: Local Plan criteria for need and "localness".

    —  Regional Spatial Strategy—RSS 8 (NB: a member of the NPA is on the Regional Planning Board) now includes a notional National Park housing figure of 50 dwellings a year to 2021, clarifying its insignificance for regional targets—see sub-area text at 3.5.19 and also policy 17.

    —  2003: SPG interpreted policies further: clarifying concepts of affordable or "more affordable" and the value of tenure neutrality. It guides users through surveys and applications. Individual need is accepted as proxy for variable small scale need that cannot be accurately measured. This provides flexibility and choice: adding "lower rungs" to the housing ladder. It also helps to retain members of the local community who may otherwise have to move out of the area to move up the housing ladder.

    —  2005: A robust Section 106 Agreement ensures affordabilty "in perpetuity" and developer/owner/tenant "buy in" to the system.

    —  Involvement of the District Valuer assures an impartial relationship between "restricted" and open market house prices.

    —  Nearly 400 affordable dwellings restricted to local occupancy permitted over the past 15 years with new housing located where most needed.

    —  Government stresses that "exceptions route" housing should remain affordable "in perpetuity". Although involving Registered Social Landlords helps the long-term affordability of social housing, it does not restrict the private market. Many authorities seek a standard discount on the resale of private restricted occupancy properties, but this cannot take account of local housing market and income or lending policy variations over time. In our view and past experience this is dangerously open to future challenge (eg in appeals against the refusal of permission to remove conditions or agreements which the house owner thinks no longer appropriate).

Environmental Enhancement

    —  With some exceptions, development tends to be small-scale, but remains cumulatively significant in a protected landscape. High standards of design have been achieved, adding to local distinctiveness. Costs demand innovation.

    —  Affordable housing is physically integrated into settlements with obvious social benefits.

    —  Whereas many other Planning Authorities limit the extent of design control, all development proposals are treated as an investment in the Park (cumulatively several £ million pa). This approach fosters local businesses and skills. It contributes to the economy by adding to the area's attractiveness, with a strong context for appropriate modern developments.

    —  Development is now in the additional context of recent comprehensive SPG for renewable energy in the National Park.

Working in Partnership

  The National Park straddles, four regions, 12 local authorities including four counties and four metro districts and 127 parishes. There are numerous agencies and several housing providers.

  The NPA is not a housing authority. It works with constituent authorities and other agencies addressing the local need for affordable housing:

    —  helping establish the Peak District Rural Housing Association;

    —  contributing financially to housing enabler posts; and

    —  achieving high standards of design via informal partnerships with architects and local builders.

  Membership of the NPA convened inter-agency Peak District Housing Forum includes officers from constituent housing and planning authorities, housing associations, the Housing Corporation, House Builders' Federation and Government Office for the East Midlands (GOEM). The forum:

    —  draws together expert opinion and helps generate ideas;

    —  successfully lobbied ministers (eg rural top slicing and exemption from purchase grant);

    —  has steered a joint study providing insight into issues around locally needed affordable housing in a protected landscape;

    —  gained a National Housing and Town Planning Council award; and

    —  continues to review and refine policy and practice.

  The NPA has carefully concentrated on its own role as land-use/spatial authority whilst building into the planning system the relevant and independent contributions of others on community need for affordable housing and the appropriate:

    —  size and type needed;

    —  value; and

    —  cost to the occupant.

  The NPA does, however, act as catalyst for periodic review of the roles played by the various contributors. By way of example, discussions are currently underway with the Derbyshire Building Society to investigate the response of lenders to the full set of measures now in place within the National Park.

Does the system work and might it be applicable elsewhere?

    —  YES

    —  Its strength is its diversity. The process is relatively complicated because of the need to ensure that locally needed homes of different types and tenure are provided (as either "social" or relatively affordable "restricted market") and retained as such in perpetuity. However we have refined our system and it is possible to issue planning consents within eight weeks.

    —  At the local level difficult issues can arise—such as expectations that all locals are eligible for the housing even though they do not comply with occupancy requirements; site constraints and build costs in local materials; "nimbysm"—less now because local people are aware by example that developments will be to a high standard of design both physically and functionally. These provide feedback into our partner-working structures and result in ongoing refinement. This process would allow for local circumstance and appropriate policy variation to be expressed. Elements of the system could transfer regardless of use of the rural exceptions route.

  In this way, and working within National Park purposes and duty, the Peak District National Park Authority has:

    —  Delivered robust Development Plan Policies to conserve and enhance the National Park whilst permitting nearly 400 locally restricted "affordable" homes to meet long term local needs: consistent with regional and local targets.

    —  Refined policies using community and stakeholder engagement to give practical detailed guidance (SPG).

    —  Maintained a tenure neutral approach, benefiting choice.

    —  Produced a robust legal agreement, ensuring future "affordability" and availability of the housing to meet local needs in "perpetuity."

    —  Helped to deliver well designed, well liked, housing developments that sustain local communities.

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