Regional Planning Guidance. The Government has considered the Crow report and has produced its own version of a revised RPG9. Comments must be with the DETR at the Government Office for the South-East, Bridge House., 1 Walnut Close, Guildford GU1 4GA by 19 June. It has clearly repudiated major aspects of Prof. Crow\rquote s approach and figures, but it has changed so many things in the process that it is very difficult to see how the figures for additional dwellings really compare. For instance., it has recast the format of SERPLAN's draft, has abandoned a long-forward look for regional planning in favour of a five-year one, and has juggled with figures accordingly. Whereas SERPLAN's 1998 estimate was for 861,700 additional dwellings over 25 years., i.e. an average of 34,468 p.a. (though RPG,9 quotes a more recent SERPLAN figure of 666,600 over 22 years. = 33,330 p.a.), the Government. though favouring 5-year periods, gives no five-year figures but only an annual total of 43,000 p.a.
These figures compare with Prof. Crow' s estimate of 1,098,500 over 22 years., = 54.,925 p.a. All figures exclude London. Moreover., R.PG9 does not give a regional breakdown, remitting that task back to SERPLAN; and, merely as an illustrations dividing its (the RPG9) figure of 4.3.,000 between authorities in the proportions which they had in SERPLAN's figures. whilst making clear that the Government thinks that that is nut the right breakdown anyway.
Please note that LGBC do not claim infallibility for my interpretation above. It is extremely difficult to follow what has happened. (and things are not made any easier by the fact that the figures used in Essex are based on projections over a 15-year period!)
On Green Belt. the Crow report encouraged authorities to review their Green Belt boundaries. but when Prof. Crow appeared before the House of Commons Select Committee on the DETR he was pinned down to saying that he did not think it necessary to go into Green Belt at all. This seems to have had some influence on PPG9. in which Policy E2 on Green Belt reads:
'There is no regional case for reviewing green belt boundaries in the light of this strategy. In preparing development plans local authorities should frame policies in accordance with advice in PFG2 (Green Belts). Where there are local exceptional circumstances which justify a review of green belt boundaries, such a review should follow the advice set out in PPG2. Such a review should also take account of sustainability and quality of life criteria including: proximity to urban areas well served by public transport. Intrinsic environmental quality of the contribution made by the Green Belt to the planning objectives for the area'.
PPG3. Our main comments on the draft were that green belt should be stated as having the hig hest protection in the sequential process for selecting land for housing; it should not be linked to scenic quality; that the wording about green belt boundaries should be changed; and that the words for adjoining' in the context of affordable housing for Green belt villages should be deleted.
.But as with the draft RPG9 the resultant PIDG3 is an attempt to have it both ways. The section on sequential criteria for the release of land for housing, is largely unchanged from the draft: it does not refer to green belt., or to any other special designation of land. or to scenic quality. It introduces a 'rural exceptions policy', which relates only to villages and is intended to be a policy of 'permitting very limited exceptions to established policies of restraint'; and does no t permit the advance designation of such areas In development plans. So far as the application to greenbelt is concerned, the annex explaining the policy remains as,. set out in, PPG2, but it does., in the context of affordable housing in villages. include the words 'or adjoining' - which were not in PPG2. The same sort of double-speak is used elsewhere in the context of urban extensions, using words which could cause us a lot of trouble.
The Government is strongly in favour of maintaining the green belt. There may be occasions, however, where green belt boundaries have been tightly drawn and there may be a case for reviewing these boundaries and planning for development where this would b e the most sustainable of the available options. An extension of in urban area into the green belt may, for example be preferable to new development taking place on a greenfield in a less sustainable location. Nonetheless the Government regards this as an exceptional policy which should not com promise the objectives for which green belts were designated'.
The effect of PPG3 is to reinforce the priority for using previously developed sites., but (as usual) to leave loopholes which developers will seek to exploit. The policies will bite at the str ucture and development plan stages rather than at the planning Application and appeals stages (except possibly for 'rural exceptions' in villages). This means that, more than ever, members must be alert to make themselves heard at the formative stages of planning.
Green Belt and divided Ministerial responsibilities. Out attempts to involve Mo Mowlam so far at least, have resulted only in a reply to our President from Beverley Hughes, Parliamentary U S of S at the DETR. She says that there is little in my analysis with which she would disagree, except for the status of green belt in relation to the sequential test for allocating land for housing. She says:
'The new PPG3 (Housing,) makes clear that, where they offer the most sustainable solutions for locating new development, there may be a case for reviewing green belt boundaries which have been too tightly drawn; or the extension of an urban area into the green belt may be preferable to development of greenfield beyond. Nevertheless such options are viewe d as exceptional and should be pursued only once all the alternatives have been explored, and should not compromise the objectives for which green belts were designated. The Government remains committed to the green belts and the presumption against inapp ropriate development within them remains'.
Conclusion
So, summing up, all three sections above, we have a situation where housing requirements are more than originally estimated by SERPLAN but much less than estimated by Prof. Crow; but the detailed allocation of the total is very fluid. The new RPG9 is still open for comment., but the new PPG3, which reasserts support for green belt whilst weakening PPG2 in some ways, is not. So where do we go from here? We must still try to get the expression 'intrinsic environmental quality' removed fr om RPG9. We should quote Beverley Hughes' gloss on PPG3 'such options should be pursued once all the alternatives have been explored' whenever relevant. We should renew our criticism of the Countryside Agency., which is responsible for some of these ills even if they were inherited along with staff from the former Countryside Commission.