The labyrinth of planning ......... and a way out of it

The Minotaur surprised while eating
Maggi Hambling - Tate

I know this may seem stupid but I am starting to feel really sorry with all those involved with the AVBC attempts to produce a viable Local Plan .......... from the understaffed planning department to obviously befuddled responsible councillors .... oh and not forgetting the large number of Amber Valley residents who make their views known at hearings and through the consultation process. It brings to mind the Labyrinth in which the Minotaur was trapped; constantly revisiting passageways that never led to freedom. Does that sound like the AVBC Local Plan process? Ah yes, the beast of planning, never sure of what it is trying to do nor how to do it. I draw this allusion because of the maze that AVBC now inhabits (hopefully there is no need to apologise for including Maggi Hamblings wonderful painting - - that's how I see the current impasse).

It just gets worse : AVBC's Local Plan Inspector's note July 2018

Timetable chart extract from Inspector's note

So the hearings will resume just around the time that AVBC staff will be organising an election in 15 wards ................ but there are serious doubts that they will be able to redraft their plan by April'May 2019. What AVBC is attempting is a complete rewrite of the Local Plan so many factors have to be considered; not least because the inspector wrote:

"The process of identifying and proposing additional sites for housing and other uses should be carried out in an open and transparent way, using an appropriate methodology which objectively considers and assesses the reasonable alternatives. The Council should set out clearly its reasons for selecting the reasonable alternatives chosen, which should then be subject to an equal examination. This would be best achieved by the production of an Addendum to the Sustainability Appraisal (SA).

 With regards to the submitted SA, although I acknowledge, for instance, that it is important to take into account additional information that may be available in respect of a site which is the subject of a current planning application, this should not be at the expense of a site which does not have the benefit of further detailed supporting evidence. In cases such as this, the Council should consider the possibility of similar provision being made on the other site or sites in order that the reasonable alternatives are assessed on an equal basis". (that second paragraph is a killer)

There is considerable cause for concern as they have been basing the housing forecasts on pre-existing planning applications and it would be prudent to assume that the green belt assessment will follow this pattern, a re-assessment of hitherto rejected planning applications to develop land such as AVA/2017/0322 which proposed 185 homes on 10.6 hectares of green belt land off Crich Lane in 2017.  (more on planning application AVA/2017/0322 go here)

A pertinent question would be, "how many rejected applications to build on green belt land could be referenced by AVBC?"

Back to the positive

Pinglewick village at the end of Acorn Drive in Belper. Admittedly built in the 1970's on a green field site.
The boxed in area is 0.1477 hectares containing 65 dwellings with a density of dwellings per hectare of over 400.

You can find a video of the developer describing the construction of Pinglewick here.

We discussed in a previous blog post that a better way forward for AVBC would be to assess how much development could be undertaken on brownfield sites ............ using as an example the work undertaken or commissioned by the NP4B team. This prompted a thought ........ just how many hectares of brownfield locations were included in the AVBC brownfield site register?  The answer, after a simple totting up (didn't even have to take my socks off) is 149.36 hectares. Which leads on to how many dwellings could be built on these brownfield sites:

Yes of course not all of the sites would be suitable for housing or at appreciable densities but as the target number of homes in Amber Valley is 9,770 there is a fair degree of leeway ........... especially as there are a considerable number of windfall and other large housing developments that have been built since 2011. The Office of National Statistics (ONS) lists 56,130 households paying council tax in 2016 whereas in 2011 there were 52,596 ............ an increase of 3,534 though how many of these extra dwellings are counted towards the Local Plan target is a moot point (a development below a certain number of houses is not "statistically" relevant ... apparently). If we assume an incremental increase of 700 homes per year of which a conservative third or 233 can be counted as part of the Local Plan target then by now (mid-summer 2018) the target has dwindled to somewhere around 8,200. If these calculations were acceptable to the inspector then there would seem to be enough brownfield site capacity in Amber Valley to match the target. If, as would seem sensible, the Local Plan end date was adjusted (2011 - 2028 = 17 years) to 2035 then we could assess the true value of brownfield sites for years to come. No need for development of green belt or green field land.

A further look at densities

We should also note that densities above 80 are achievable on some sites as per these two examples:

• Belper East Mill development proposal is over 600 dwellings per hectare so renovation of existing though moribund industrial premises offer significant advantages.
• Pinglewick is over 400 dwellings per hectare.

Examples of acceptable housing densities can be found here in an Architect's Journal article - Planning Suburban Housing Density and three informative graphics from that publication are copied below:

35 dwellings per hectare

50 dwellings per hectare

80 dwellings per hectare

A cautionary note is that two extant planning applications for local brownfield development sites, the Arbru site in Milford and Derwent Street North in Belper were for density of dwellings per hectare of 22 and 26 respectively. There is obviously a lot of scope for the council to be in discussion with developers and funding bodies in an attempt to unlock the potential of our derelict brownfield sites.

Despite election pledges AVBC look to develop on green belt land?

The performance of Amber Valley Borough Council is becoming more and more disturbing. This blog has referenced AVBC quite a few times, admittedly never from a position of approval except for that one post about homelessness in Belper when the diligence and obvious compassion of the council officer involved was duly noted. I am sure that there are other officers who are equally as involved with their allotted responsibilities but I fear that they are battling against overwhelming odds. I am trying to hold on to this belief though a recent development in the inspection process of the AVBC Local Plan has once again led to questions of competence. The nub of the Local Plan is to allocate land for the development of 9,770 homes within the time period of 2011 - 2028. There is also an added imperative that development should not be delayed towards the latter end of this period so AVBC has to demonstrate that 5,000 homes will be built in the initial 5 years. In the real world the 5 years started in 2011 but in the world of Amber Valley the 5 years starts now. According to Labour Councillor Ben Bellamy AVBC had spent over £1 million by 2017 on unsuccessful attempts to produce a plan (see here Ben's excellent article in Nailed - Belper Independent news).

It is obvious that AVBC has been struggling to produce a viable Local Plan for some years and yet again their shortcomings have hit difficulties during the inspection process:

Inspector’s Note on Land North of Denby

The Council considers that the process of identifying and proposing additional sites is likely to require the release of land currently within the Green Belt. As such, the Council proposes to undertake a Borough-wide Green Belt boundary review in order to inform this process. The Council has confirmed that, given that part of the site known as Land North of Denby is within the Green Belt, any review of the Green Belt boundary is likely to include an assessment of this site. 

Following the review of the Green Belt, the Council will then consider whether any potential sites within the Green Belt, including that which forms part of the Land North of Denby, could be identified and proposed as Housing Growth Sites, including the assessment of Reasonable Alternatives. A Sustainability Appraisal will also be carried out. 

This map is helpful in understanding what land is being considered :

This map which is included in AVBC's Local Plan clearly identifies the green belt land that is to be considered for development. AVBC is employing external consultants to carry out this appraisal which, as the council admits, is looking solely at green belt land re-designation. This is not just waiving the white flag of defeat but a clear statement that after years of election promises to voters this Tory administration is willing to renege on their pledges (for more on this see here .........and also here where the Tory record of building on green belt land is explored plus Labour's opposition to it). Apologies for the seeming incestuousness of referencing earlier BelperStuff posts but they do contain some interesting links.

There is another way - the alternative of Brownfield site development

Here in Belper there has been a spirited opposition to development of greenfield land such as Bullsmoor and Belper Lane and we can now see that Neighbourhood Plan for Belper has taken this on board with their strategy of restricting any large scale development in the parish to brownfield sites (see here NP4B Viability study of brownfield sites for the Parish of Belper). The majority of these sites are contained within the AVBC Local Plan but they have relied solely on the planning applications by developers to determine the number and types of housing that would be built. NP4B has realised that the AVBC plan envisages larger homes configured to a suburban density; for instance the Arbru site in Milford comprising 136 homes has a density of 22 dwellings per hectare. By raising the density and type of dwelling ( less bedrooms to suit starter homes and downsizing from larger homes on the outlying estates) to 30 and 50 dwellings per hectare, which is more in line with the urban nature of these sites the target figure for development in the parish can be contained on brownfield sites. Indeed, with careful planning these sites could provide the homes needed for the next 20 years without recourse to development on green field or green belt land. This depends upon the NP4B being passed at a referendum and a methodology being found to produce the homes that are desperately needed rather than the AVBC method of relying on what he market decides to build.

Brownfield sites in Amber Valley (from AVBC Local Plan)

So what should AVBC do?

The simple answer is that the borough should decide that: 

• A Green Belt Boundary Review should only be undertaken following a borough wide Brownfield Site Viability Survey.
• AVBC to negotiate with developers to build homes that are needed on brownfield sites (as for example outlined in the NP4B Housing Needs assessment 2016 - note the 360 additional sheltered homes need within the parish by 2028)
• AVBC to explore funding streams to promote brownfield site development (they could start here, New Government measures to promote brownfield site development - with a gross potential of £4.2 billion.)
• AVBC does have a brownfield register so why not add that to the specification you give to your consultants.

Has AVBC done any of this?

Cognitive dissonance

Last year I shared a conversation with a Tory borough councillor (representing Duffield) who boasted that, "we have reduced Amber Valley staff numbers by 134 ......... that is the way you manage local government". He said far more than that but I found his comments so unsavoury that I'll not repeat them here. I could see that he was convinced that staff cuts were a good thing but when I pointed out the consequences of a reduced planning department that was struggling to deal with planning applications and produce a viable Local Plan he could not see the connection.  The point was not lost on me that he measured borough council success on how much money could be "saved" by making staff cuts rather than the council serving the community in a meaningful way. It is the mentality of small government.

Local Government planning departments have lost 60% of their funding since 2010

The Councillor's belief that the market will supply the homes needed without any intervention by local authorities is current Conservative thinking and has been since the Thatcher years so he's not alone. The evidence however does not support this belief:

The private sector and housing associations have proved to be inadequate providers of new homes for a growing population. Privatisation of housing supply has failed. For anyone who believes in smaller government and the primacy of private companies in dictating what and where is to be built a chart such as the one above will cause them to have a headache. So what do they do? The evidence disproves core conservative doctrine ........... the only way is to let private developers loose on virgin land whilst in our town centres old industrial buildings rot.

But what would Labour do?

We will protect the greenbelt, and prioritise brownfield land for development. (an extract from their 2017 Housing Manifesto - New Deal on Housing

This is also the policy of local Labour councillors.