On 16 December, the government announced how it would be responding to widespread concern about its proposals to use a central computer model of household growth estimates and house prices to impose house-building targets on local communities. The outcome of this approach would have resulted in a requirement to build vast quantities of homes in London and the South East of England.
The model would have been particularly harmful to protected landscapes such as the Chilterns AONB. As we set out in our response to the consultation on this proposal, the fact that house prices are significantly higher in the AONB is partly the result of some people being prepared to pay more to live in a beautiful place, rather than being indication of how many more homes are needed here. However, this does not take away from the fact that some small-scale, affordable development is needed. As our Management Plan sets out: “Where a local community need is shown, the Chilterns Conservation Board should support the development of well-designed, small-scale homes within villages which are affordable for people who work within or have long-standing family connections to the Chilterns AONB”.
The government’s announcement last week promised that the changes would “encourage more homes to be built in England’s 20 largest cities and urban centres”. This is intended not only to make the best use of land that has already been developed, with access to employment, services and facilities, but also to assist with “levelling-up” the economy in the midlands and the north, and relieving pressure on the south-east.
This appears to be good news for the Chilterns AONB. In particular we strongly welcome some of the messages given in the government’s write-up of the consultation outcome, published on 16 December. For example, in response to concerns that “in some places the numbers produced by the standard method pose a risk to protected landscapes” the government has clearly stated:
“We should be clear that meeting housing need is never a reason to cause unacceptable harm to such places. But harm or homes is not a binary choice. We can plan for well designed, beautiful homes, with access to the right infrastructure in the places where people need and want to live while also protecting the environment and green spaces communities most value. (…) We can and must strive to build more homes, but to do so with sensitivity and care for the environment, heritage and the character of existing communities.”
There are likely to be differing interpretations of what constitutes “unacceptable harm”, but finding ways to meet housing need while protecting and enhancing the natural beauty and heritage of the Chilterns AONB is one of the Conservation Board’s main purposes. We are therefore pleased that the government has made this commitment in response to the concerns that we submitted, along with others in the protected landscapes community.
While this is definitely a step in the right direction, there are still some areas to think about; The largest cities and urban areas will be encouraged to provide more homes by applying an additional 35% “uplift” in those areas. As far as we can tell, there will be no commensurate reduction of the figures elsewhere, including in protected landscapes or in the south-east as a whole.
The relevant areas will be identified using the Office for National Statistics list of Major Towns and Cities, but fortunately with moderation. For example, the definition of “London” currently extends as far out as Hemel Hempstead, whose boundaries are already being pushed up to the edge of the AONB through the emerging Dacorum local plan. Instead, “London” will only be the Greater London administrative area. The list of 20 urban areas will be subject to continuous review, though, and it is conceivable that other urban areas around the Chilterns AONB, such as Hemel Hempstead/Watford or Luton/Dunstable, could qualify in future years.
The list already includes Reading, parts of which abut the Chilterns AONB boundary (as well as that of the North Wessex Downs). It is not yet clear what the outcome of the application of the 35% urban uplift will be in and around somewhere like Reading. The published guidance says that the uplift will be applied only to the single local authority in each urban area (other than London) that has the highest population. Presumably it will be up to all of the councils in each urban area to work cooperatively to distribute the additional housing requirement between them, which may be problematic judging by existing difficulties with the “duty to co-operate”.
The expectation in the new guidance that the uplift should “be met by the cities and urban centres themselves, rather than the surrounding areas, unless it would conflict with national policy and legal obligations” is confusing, since it (a) fails to account for circumstances where the uplift (let alone the original housing requirement) cannot be met within that area, and (b) appears to place the emphasis on respecting the “national policy and legal obligations” operating within the urban local authorities at the expense of those in neighbouring areas.
In the case of Reading, for example, the urban area extends across Reading Borough and parts of Newbury and Wokingham. In the examination of the recently adopted South Oxfordshire Local Plan there was a discussion about whether land was needed within South Oxfordshire district to meet development needs arising in Reading. Fortunately, representations from Reading Borough Council clearly stated that there was no need for a (further) incursion of the built-up area of Reading into Oxfordshire. This might not remain the case if the Reading conurbation is expected to provide 35% more homes, and these cannot be met in those three local authorities while respecting national policy and other obligations there.
The key issue here is not with the principle of seeking to direct more growth to existing cities and other urban areas, but doing so on the basis of an apparently arbitrary uplift (why 35%?) applied to a centrally-determined list of urban areas (why the top 20 by population?), without considering either their existing growth ambitions or the opportunities for redevelopment in their areas, and the “areas or assets of particular importance” within or around them that the National Planning Policy Framework (NPPF) seeks to protect.
We shall be keeping a close eye on how this policy works in practice.
Dr Matt Thomson joined the Chilterns Conservation Board as Planner in June 2020. He has a wealth of experience joining us from his role as Head of Land Use and Planning at CPRE, the countryside charity, where he has oversaw a push for national planning policy to recognise the intrinsic value of open land, the countryside and rural communities.