23rd November 2016
Published last week, Revision 9 of Planning Policy Wales (PPW) is a missed opportunity. PPW has evolved through many iterations and has lost its focus - it now runs to 250 pages. The National Planning Policy Framework in England is just 65 pages and after publication in 2012, is only now subject to consultation on potential changes.
One of the biggest planning issues for Wales is housing delivery. The Welsh Government’s Cabinet Secretary Carl Sargeant has set a target (to deliver 20,000 new affordable homes from 2016 to 2021. Disappointingly, the Government has not set a target or provided a commitment to significantly increase general market housing provision.
The lifeblood of housing delivery is readily developable housing land. The Welsh Government sets a minimum requirement for a five-year housing land supply based on councils’ adopted Local Development Plans (LDPs). Yet throughout South Wales there is a major shortage of readily developable housing land that can be built on in the next five years. As our table below shows, this is a persistent problem (download).
South Wales Authorities Five-Year Housing Supply Position
Date of adoption
|2012||2013||2014||2015||2016||Five year shortfall of homes**|
|Bridgend||Sept 2013||5.1||5.7||6||5.4||5.1||100 (surplus)|
|Rhondda Cynon Taf||Mar 2011||4.5||3.7||2.8||2.4||1.5||6863|
|Merthyr Tydfil||May 2011||3.6||2.9||2.5||2.8||1.6||1474|
|Blaenau Gwent||Nov 2012||7.6||3.3||2.6||2.1||1.35||1763|
|Vale of Glamorgan||No adopted plan||3.3||4.3||7.3***||2.2||0||0 as no adopted
LDP and at Examination
* Date of adoption Local Development Plan
The shortfall across South Wales against the 5 year land supply requirement is 19,600 home. (Note excludes Vale of Glamorgan and therefore is an under-estimate).
The Welsh Government’s preference for fixing this situation is to focus on reviews of Local Development Plans. Caerphilly began a review of its LDP two years ago, only to abandon it this summer. Rhondda Cynon Taf and Blaenau Gwent, with equally as poor land supply as Caerphilly, have not begun their reviews. The LDP review process takes two to three years, through consultation, examination and adoption, assuming there are no slippages. It takes a further two to three years for large sites (100 or more homes) to proceed through the planning application system and start delivering homes. So LDP reviews will not address the housing shortage quickly.
The need for housing is now. There is no expression within PPW of the material weight to be attributed to the lack of five-year housing land supply unlike the “considerable weight” which should be given to protecting agricultural land of grade 1, 2 and 3a (Paragraph 4.10.1), or the “substantial weight to any harmful impact that development would have on a Green Belt or green wedge” (Paragraph 4.8.14). Whilst Technical Advice Note 1 Housing at paragraph 6.2 states that the housing land supply should be “treated as a material consideration…. and given considerable weight,” this document does not have the same policy weight as PPW. It is also amiss that the weight given to 5 year land supply is the same as that for protecting agricultural land i.e. “considerable”.
The revision to PPW in Edition 9 does nothing to address this situation. This was a missed opportunity to potentially rebalance the need to deliver housing in line with the Government’s aspirations and stated objective. We believe in future PPW should be made far more concise and in particular should state that:
Substantial weight will be attached to the lack of a 5-year housing land supply, and that housing proposals should be approved provided they represent sustainable development as defined by PPW and are broadly in accordance with the overall objectives of the LDP.
Director, WYG, Cardiff
For more information contact Ben via E: firstname.lastname@example.org