Since the government published its draft revised National Planning Policy Framework (NPPF) in March, some council planners have been scratching their heads over one aspect of the consultation document in particular: the requirement to allocate small sites for housing delivery. It is becoming increasingly clear that the policy could prove to be highly onerous for local authorities, and is being proposed despite evidence that some councils are already making progress under existing guidance on encouraging housing development on small sites.
The draft NPPF states that "small sites can make an important contribution to meeting the housing requirement of an area, and are often built out relatively quickly". In that light, it calls for councils to "ensure that at least 20 per cent of the sites identified for housing in their plans are of half a hectare or less".
Should it be adopted in the final framework, the policy will mark a fundamental change in how planning authorities deal with small sites, which the government defines as capable of hosting fewer than ten homes or, where the number of units is not specified, comprise less than half a hectare. Hitherto, minor development has usually been categorised by councils as "windfall", counting towards overall housing provision numbers without needing to be part of the allocation of residential land made in local plans.
Consultant Catriona Riddell says: "Councils don’t usually identify and allocate small sites in the way that the NPPF is proposing. It takes an awful lot of resources to manage that supply and be proactive. Some might be better placed to do that because they have more small brownfield sites, but even those usually tend to come forward through retrospective windfalls rather than allocations."
Local authority planners have decried the 20 per cent goal as arbitrary and unachievable, with the Planning Officers Society as well as a number of individual local authorities from areas under the control of different political parties calling for it to be abandoned in their responses to the draft NPPF.
"It is impractical when you have a county the size of Cornwall, 100 miles from one end to the other, to sit down years in advance and identify hundreds of different sites for four or five houses," says Bob Egerton, portfolio holder for planning and economy at Cornwall Council, where the administration is led by an alliance of Liberal Democrats and independents. Egerton’s criticisms come despite the fact that the council has historically delivered around 40 per cent of its housing completions through minor developments.
Ed Freeman, head of planning at Conservative-controlled East Devon District Council, says around 30 per cent of housing completions in his area last year year were on small sites that came forward naturally because low-density towns such as Exmouth lend themselves to infill development. But he questions how planners will find small sites to allocate. "Do you end up artificially subdividing sites that major housebuilders would otherwise develop?" he asks.
A further concern is the workload generated by the need to allocate many small sites while meeting the revised NPPF’s criteria on deliverability. These are more demanding than those in the existing document, requiring "clear evidence" that housing will be completed within five years. "The deliverability of small sites is a lot harder to assess," says Freeman. "The combination of these measures will create a disproportionate amount of work with relatively little certainty about what will be delivered and how viable it is."
Labour-led Croydon Council in London plans to deliver a third of its local plan allocation of 33,000 new dwellings through the intensification of its suburbs, mainly by developing small sites. "Our whole idea is that you can enable that to happen as an organic evolution, rather than a planned top-down change," says cabinet member for environment, transport and regeneration Paul Scott.
"Allocating individual sites for redevelopment would cause huge local resentment. We have enormous difficulty persuading people that they should have flats built in their streets, without the local authority coming in and telling them numbers seven, 13 and 28 look like they have more capacity so they will be allocated for development."
However, while councils of all political stripes may be critical of allocation quotas, many are very much on board with the small site development agenda and are taking practical steps to increase housing delivery on small sites. Among them is Mark Harbottle, head of economy and planning at Tory-led Hambleton District Council, where more than 40 per cent of the 411 housing completions in 2017/18 were on minor sites. "As a largely rural authority, we have adopted some interim guidance to boost the supply of schemes of less than five houses around the larger villages," says Harbottle. "It focuses on the larger villages or cases where there are small villages that are close enough that there is a sufficient range of services for a location to be sustainable. That has worked quite well in terms of increasing the number of applications. We have had a large number of sites come forward and councillors have been happy to grant permission on them."
Croydon Council has introduced a presumption in favour of three-storey development in order to enable denser development on small suburban plots. Scott is also keen to build relationships with small and medium-sized housebuilders. "We often call them in for a chat so they put in more considered schemes and gain confidence because we are approving applications," he says.
Cornwall Council’s planning policy, meanwhile, favours infill and "rounding off" of existing settlements as approaches to make more use of small sites. It also aims to support self-build. Egerton says: "We think small sites are a good idea. They are much less contentious than larger sites because people think the housing will be for local people and won’t change the character of their village."
However, these delivery-focused measures will do little to help councils allocate more small sites in local plans. Some have suggested that a way out of the dilemma could be for planning authorities to work more closely with parishes and neighbourhood forums, aggregating the small plots identified by the neighbourhood planning process.
But the majority of adopted neighbourhood plans have not allocated any sites for housing. The Hambleton District Council area is no exception. "If we knew the neighbourhood plans would provide a conduit for the information flow about small sites, I would be more relaxed, but we haven’t had any adopted yet," says Harbottle.
"The scope for windfall development to meet housing need should be reflected in national policy and if government wants to make allocations for small sites it should be through encouraging neighbourhood plans to do that," says Egerton. "We can only hope that the government will read our submissions to the NPPF process."
The 20 per cent quota is also opposed by the housebuilding industry. "We don’t think that a
national threshold is very helpful when some local authorities have much better availability of small sites than others," says Home Builders Federation planning director Andrew Whitaker. "Some will already be delivering more than 20 per cent on small sites and setting that target may encourage them to think they shouldn’t be exceeding that level."
So, while some planning authorities are already exceeding the draft target, there is a view from both the public and private sectors that the policy is simply unworkable or, worse still, downright counterproductive.