SGMGB is the umbrella organisation covering 30 groups across Greater Manchester


Below is there response to the Housing White Paper

Planning Policy Consultation Team
Department for Communities and Local Government
Third Floor
Fry Building
2 Marsham Street

17 Aprl 2017

Re: Response to Housing White Paper: Fixing Our Broken Market

The following sets out the response of Save Greater Manchester Greenbelt Association (SGMGBA) to the Housing White Paper (HWP).  SGMGBA is the umbrella organisation that represents over 30 community organisations across Greater Manchester in response to the draft Greater Manchester Strategic Framework published in October 2016.


The HWP starts from the premise that the cause of the housing crisis is a shortage of housing and reiterates this point throughout. SGMGBA views this as an over-simplification of a complex problem that has developed in recent decades.   Some experts interpret the statistical data as showing no shortage of housing and that building more will not bring prices down. For Iain Mulhern argues, “the best data we have shows that: the UK does have enough housing; housing costs are not high by the standards of the last 25 years, and have in fact fallen over the past decade; and additional supply, while welcome, will not have much impact on house prices or housing costs”[1].  This is not to say the UK does not have some significant distributional issues, such as homelessness, a lack of social housing and tighter restrictions on Housing Benefit for those who struggle to pay market rents but these issues are separate from the macro issues of housing supply, cost and the impact of additional house building on the housing crisis.

Furthermore, the HWP does not take sufficient account of other changes in social and economic factors which have also influenced the ability of people to obtain appropriate housing including: significant under investment in social housing; modern household structures; levels of employment; spending and saving habits; interest rates on savings; ease of obtaining a mortgage; houses being used as an investment opportunity rather than a home. Simply building more houses will not have much impact when there are many complex factors that need addressing.

SGMGBA is therefore particularly concerned about the impact that the HWP will have on the UK’s Greenbelt.  The HWP appears to see the building of more houses as the panacea to the UK’s housing crisis.  Many local and combined authorities take a similar, simplistic view and are increasingly attempting to decommission large swaths of Greenbelt across the UK to enable house building.  Furthermore, the HWP, in its current form, will further facilitate this approach.  In this next section, we highlight our concerns about how the HWP will empower local authorities to build on Greenbelt land.

Specific Responses to HWP Questions

HWP Step 1: Planning the right homes in the right places

Question 1

  1. NPPF Paragraph 156 already requires strategic policies to deliver homes and jobs needed in a local authority’s area so an additional requirement for housing is, in our view, unnecessary.
  2. The Local Plan should specify all development sites in the area. If a Combined Authority identifies additional strategic sites there should be a requirement that the Local Planning Authority (LPA) should consider any such strategic site in its area, or which would affect its area.
  3. We agree with the proposal to revise the National Planning Policy Framework to tighten the definition of what evidence is required to support a ‘sound’ plan. Also, Local and Combined Plans should accord with the national planning policy, including the National Planning Policy Framework (NPPF), with evidence on past performance of development completed.

Question 2

It is more appropriate that different levels of plans work together rather than a degrading of functionality as the result of the HWP’s attempt at simplification.  For example, strategic sites identified by a Combined Authority must be scrutinised by the planning committee of affected local authorities.

Question 3

We urge the Government to make clear that calculating housing need must be a two-stage process. Stage one is objectively assessed need (OAN policy-off) and stage two is an estimate of the housing requirement (OAN policy-On).

Local authorities should not be pressurised to adopt a housing requirement in excess of what is known to be deliverable from past experience.  The estimate of the housing requirement should be specified with the range of its uncertainty resulting from the intrinsic uncertainties inherent in the estimation process.

We agree about stopping double counting of households in projections across geographies as picked up in the GMSF demographic appraisal.

Question 4

We believe that the components to this question all relate to the fundamentally important NPPF Paragraph 14, which has been the subject of several judicial reviews, yet it is still not clear how NPPF Paragraph 14 is to be interpreted.  Also, the present confusion is compounded by planning inspectors interpreting Paragraph 14 differently. We believe that one of the very important purposes of the HWP is to correct this regrettable state of affairs, especially having in mind that the NPPF intended to be a simplification of national planning policy that was intelligible to the ordinary public.

  1. We strongly agree. The definition of “sustainable development” is at the heart of planning policy and there should be a clear definition of what it means. We are happy to accept any coherent definition, but without one it is not possible without endless debate to interpret what subsequent policy statements mean.  “Suitable” in relation to brownfield land must not be restricted to land, which is shovel ready. It must also include land, which is need of extensive decontamination or is subject to other constraint (see answer to question 15).
  2. There is already a presumption in favour of development that is in accord with Policy that pre-dates the NPPF. The Government should not introduce statements, which imply weakening of the three dimensions of sustainable development, namely economic, social and environmental as specified in NPPF Paragraph 7.
  3. Note 9 should begin, “Restricted sites include …”. We accept the addition of “Ancient Woodland and aged or veteran Trees” to the list.  We also believe that the following categories should be included in the Note 9 list: valued landscapes, hedgerows, Local Wildlife Sites and Best and Most Versatile Agricultural land.
  4. NPPF Paragraph 14 needs to be radically redrafted, so it makes clear the difference between OAN (policy-off), usually simply referred to as Objectively Assessed Need, and OAN (policy‑on) referred to as the Development Requirement; the requirement takes into account the protections accorded to protected land i.e. makes a negative correction to the OAN. We agree with removal of ‘golden thread’ as it is an inappropriate phrase.

We also believe that the NPPF pushes greenfield before brownfield and therefore is not facilitating sustainable development.  As such, it is not consistent with Government’s rhetoric claiming to value Green Belt land.

Question 5

We agree that regulations should be amended so that all local planning authorities are able to dispose of land with the benefit of planning consent which they have granted to themselves

Question 6

Local authorities either alone or in partnership with developers, constituted as a Development Corporation with powers of compulsory purchase, could undertake the assembly of highly contaminated urban brownfield land financed by planning gain.  An area developed in this way could be made attractive to people who would otherwise relocate to a countryside greenfield area.

Public investment should focus on brownfield reuse, not on opening up further land in countryside.

Question 7

It is good to refer to the environmental benefits as one of the ‘equal’ three pillars.  We fully support the need for urban places to become more attractive to retain people who would otherwise look to move out of these areas.

Question 8

We urge the Government to ensure that exception sites are retained for the social good and affordable housing types and tenures and not so readily allowed for market housing, where it is not exceptional.

Question 9

We believe that Garden Villages fuel greenfield development in advance of needed brownfield regeneration.  Where all other options have been exhausted we accept planned development of land in the countryside is better than unplanned development in the countryside.  Infrastructure delivery must be commensurate with the scale of the development and public transport is a key element of new settlements to manage travel demands in the future.

Question 10a, b, c, d, e & f

We can do no better than quote a recent article published on the CPRE website[2]:

“Permanence is one of the two essential characteristics of Green Belts, along with openness. Green Belt’s permanence is critical to minimising land speculation by developers and encouraging the long-term management of Green Belt land for farming, nature reserves and other natural resources. In policy and practice this has meant that Green Belt boundaries, once set, should endure for at least the typical 15-year life of a development plan and, preferably, for longer.


The White Paper now suggests that Green Belt boundaries can and should be reviewed every five years, as part of the new legislative requirement to both have a Local Plan and then to review it every five years. This interpretation is supported by paragraph 22 of the Government’s very recent response to the Select Committee inquiry on changes to the National Planning Policy Framework (NPPF).


This isn’t the only way that Green Belt’s protection is weakened by the Paper. The Government’s reiteration that Green Belt can be released only in exceptional circumstances sounds reassuring – until we realise that under the definition of ‘exceptional circumstances’ in the Housing White Paper it looks like these circumstances are set to become much less exceptional.


The proposed definition of ‘exceptional circumstances’ test (para 1.39 of the White Paper) suggests ‘housing requirements’ should be one component. But in many areas, housing requirements are often highly ambitious and well above recent trends of actual housebuilding. There is no prospect of there being the kind of public investment in housing that would enable these requirements to be met any time in the future – so the test could be used by developers and some local authorities to justify a constant state of Green Belt review. This is a fundamental change in emphasis from previous statements by ministers that housing demand alone isn’t a reason to change Green Belt boundaries.


We also fear that the requirement to ‘examine fully’ other options may prove to be toothless in practice. Since the introduction of the NPPF in 2012, planning inspectors have rarely challenged local authorities who have actively sought to promote Green Belt release, even where there are significant amounts of brownfield land available. Bradford and Leeds are key recent examples of this.


The White Paper has plenty of valuable insights on the broken housing market and how we can fix it, but it appears to seriously undermine the Government’s manifesto commitment to protect the Green Belt. Breaches of the Green Belt and our protected landscapes are a symptom of this broken market, and not a workable or sustainable solution for it.”


SGMGB believes that the HWP proposals will weaken protections for Green Belt land.  Green Belt planning policy is a success, an envy of the world, it delivers compact cities.  As it stand the HWP will undermine this success.

Question 12

  1. Where the housing requirement of a local plan has been examined as sound it should inform the Neighbourhood Plan. This should stop arguments. It could incentivise local plans to be adopted more quickly.  In the meantime the neighbourhood plan should accept a reasonable number of houses based on a figure derived from past net completions.  A good point is made by National Office about LPA misusing the target.  In Lancaster District, the Council officers are threatening a local parish (Hest with Slyne) with high housing numbers to push for a site to be released from Green Belt against local wishes.
  2. We agree with the HWP proposals.
  3. We agree with the HWP proposals.
  4. Poor design should be able to be cited as the grounds for refusal, especially in rural places and those adjoining rural and Greenbelt spaces.

Question 13

  1. We agree with the HWP proposals.
  2. We agree with the HWP proposals.
  3. We agree with the HWP proposals.
  4. We believe all places need good quality open space (both informal and formal).

Question 15

Currently Brownfield Registers are restricted to ‘suitable’ brownfield sites only.  They should include a record of all sites, not just public sector.

The Government should ensure that Brownfield Registers record all previously developed land, albeit with sub-categories of green sites that are “suitable”, amber – sites ready to go with moderate intervention, and red sites that are so constrained they are unlikely to be reused without significant investment.  If all brownfield is unrecorded it is difficult to accept land in countryside should be allowed for development, as allocating further land for development will hinder the prospect of constrained brownfield land being reused and this will serve to blight the communities and places within which they are located.

HWP Step 2: Building Homes Faster

Question 16

  1. We disagree with the suggestion of a one year position as not only is it highly impractical, it risks being found ‘out of date’ with the consequent threat to land in countryside, and the 10% uplift is punitive, and is likely to penalise Green Belt land. We support additional transparency concerning site viability assessments to understand fully when a developer claims a site to be unviable.
  2. and c) We need to understand more about the housing requirement methodology. In terms of build out rates, please see our comments on phasing in answer to Question 21.

Question 17

  1. b) Sites allocated in local plans ought to be the focus for development. We are concerned that the performance delivery test will unfairly penalise local authorities. Annual monitoring reports must inform the local plan effectiveness and robustness of the housing need figure.  As the market won’t buck economic trends local authorities should not be unfairly penalised for houses not being delivered when they have given consent for enough houses.

Question 18

In our view the fee should be substantial and reflect the scale of the development; it could be refunded (by PINS) if the appeal is allowed.  Local authorities should not be liable for costs in the case of a successful appeal for not having advised the applicant on how the proposal could have been made acceptable when the applicant has not sought advice.

Question 19

No comment

Question 20

This is good.  We support a brownfield focus of public sector investment to unlock potential in existing urban areas rather than needlessly bulldozing land in countryside.  (See answer to Question 15 all brownfield land should be recorded).

Question 21

Our response to this question and several following questions is based on a recommendation that CPRE Lancashire presented to Sajid Javid on 27 March 2017 in the context of a meeting of Nick Thompson, CPRE Lancashire Branch Chairman, with the Secretary of State and Tony Caldeira (Conservative Party Mayoral Candidate for the Liverpool City Region).

Local Planning Authorities (LPAs) need adequate powers to ensure that developers build out their planning consents in a timescale, which allows LPAs to remain compliant with the 5-Year Housing Supply (5YHLS) Rule and so avoid the damaging consequences of failing to satisfy the rule.

In summary, we recommend the following scheme for monitoring and controlling the build out of a planning consent from start to completion:

  • Given that it is the developers who build the houses not the LPAs, we believe that the planning consent should specify the phasing of the build-out in time intervals appropriate to site circumstances over the entirety of the delivery of the consent.
  • The first phase would have a duration appropriate for the preparation of the site and incorporation of necessary infrastructure (roads, utilities, etc); for a very large site or a highly contaminated brownfield site, this might be as long as 3 years, but one or two years would be more usual depending on the size of the site. Subsequent phases would have durations appropriate to the number of units to be completed, typically three years, until the consent is fully delivered.
  • If at the end of each phase progress were unsatisfactory and the developer was unable to provide an acceptable explanation for the delay, the LPA would be empowered to exercise an appropriate sanction. Possible sanctions are specified in section 2.39 of the HWP, and we believe that others are possible, but we do not have the capacity to specify them here; the ultimate sanction would be withdrawal of the planning consent.
  • Throughout the entire duration of the build-out, the land associated with the development would remain in the estimate of the housing land supply. At present, if the consent refers to a large number of units, after five years the land associated with the unbuilt units is excluded from the estimate of the housing land supply. Thus, in order to remain compliant with the 5YHLS rule, the LPA must allocate the equivalent amount of land, often putting at risk the unnecessary development of further greenfield or Green Belt land. We regard it as essential that LPAs are empowered to stop this irrational process.
  • LPAs must be given the resources required to implement this monitoring and control function.

Much more could be said about the control that this form of phasing gives to LPAs. It has the merit of flexibility and takes account of the interests of large-scale developers who are not trying to game the system (land banking, controlling development rates to maintain house prices) and by giving LPAs the tools with which to influence delivery makes LPAs accountable for delivery in a fair way.

  1. a) The start date and the build out rate would be automatically be factored in the phasing scheme as specified above.
  2. b) Ditto.
  3. c) Yes. Monitoring is vital to understand how well local plan policy is performing, and how it should be best refined in the future. But, monitoring is not a replacement for the enforcement of the timings specified in the planning consent.
  4. d) Yes, as specified above in the above phasing scheme.

Question 22

The presumption is that the development of the site under consideration is only because there is no “suitable brownfield” site available and it satisfies all the requisite planning policies. Subject to that proviso, we are in favour of the proposal being permitted, but the consent should specify the build out timing in the spirit of the phasing proposal in Question 21.

Question 23

The fact that the developer has a backlog of extant permissions in a given housing market should be a significant material consideration for an LPA assessing the application.  This means the LPA can refuse the application on this ground, but does not have to.  We applaud the Government’s offer to reign in the biggest housing developers, who routinely land bank sites in order to trigger approval on greenfield land never intended for development.  It threatens needless development of the countryside.


Question 24

We do not see why a bone fide new developer would be deterred by calling to account developers who are not delivering on their consents.  See comment to question 23.

Question 25

Our proposal above gives the flexibility about timings necessary without effecting the housing land supply.  We believe the timescale should be commensurate to the scale of the task presented by the development of the site.   See answer question 21.

Question 26

Ditto.  See answer to question 25.

The LPA should be able to exercise its power of serving a completion notice without it being regarded such an exceptional measure that it has to be referred to the Secretary of State.  An over-reliance on the Secretary of State undermines the predictability of the planning system.

Question 27

Ditto. See answer to question 25.



Question 28

  1. Yes, and the metric used to test compliance with the 5-year housing land supply rule should be the Housing Requirement (see answer to question 4), i.e. OAN (policy-on).
  2. Agree with using the Government DCLG figures rather than housing figures supplied by developers due to the obvious conflict of interest.
  3. We agree, however there ought to be a mechanism, which recognises the building of houses in replacement of large scale demolitions as part of urban regeneration schemes.
  4. We agree.

Question 29

The performance measures would be acceptable only if LPAs were given real powers to enforce delivery as set out in answer to question 21.

Question 30

We suggest powers for LPAs to establish Development Corporations alone or in partnership with developers, register providers or community trusts.

Question 31

  1. a) We agree to amendment of national policy to revise the definition of affordable housing so LPA’s, developers and the general public have clarity.
  2. b) We welcome and encourage the introduction of an income cap for starter homes to make sure the people genuinely in need of support are the ones who receive help
  3. c) We welcome the incorporation of a definition of affordable private rented housing to protect those in need and prevent exploitation.
  4. d) We welcome the intention to publish the revisions stated, however we feel this must be implemented at the earliest possible date and must not be dragged out which would only benefit developers.

Question 32

  1. a) SGMGBA does not agree that national planning policy should expect local planning authorities to seek a 10% minimum of all homes on individual sites for affordable home ownership products. The figure of 10% minimum is far too low. Large developers will, in order to maximise profits, build only to the minimum requirements this leaves LPA’s in need of more affordable homes handcuffed by policy.  It is common sense that this proposed policy will not work for all areas and this needs to be addressed.  There is also the question of inclusivity, how can developers offering a minimum of 10% off-site affordable housing contribution be contributing to an inclusive, diverse and sustainable community?
  2. b) A sensible and practical policy for affordable housing should be forth coming and take into account the flowing considerations
  3. Caution should be exercised when proposing that developers can provide affordable private rent in place of other products. In private development we have seen the leasehold scandal, poor quality build and poor customer service, it is only right that the government is sure they can exercise full control of private development in order to protect the general public.
  4. the policy should not apply to qualifying developments such as supported housing, custom build schemes and community land trusts. A rural exception site may actually need a quota of affordable housing so to restrict the ability to provide this does not make sense.

Question 33

Exclusions should apply to supported housing, custom build schemes where the aim is very low cost housing across the whole development and community land trusts.

Question 34

We welcome the proposals to amend national policy to make clear that sustainable development must reflect economic, social and environmental roles.  The NPPF has been too developer led which has resulted in planning policies, especially around sustainable development, being open to interpretation often in planning inquiries and high court.  Setting the government’s intention that all three core principles are evenly weighted is a crucial step and would have avoided the paragraph 14 rulings.

Question 35

  1. a) Agree
  2. b) Agree

Question 36


Question 37


Question 38









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