Planning matters

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Will brownfield land registers solve Greater Manchester’s housing crisis?
It is well-known that Greater Manchester is not immune from the national housing crisis. Going forward, the first draft Greater Manchester Spatial Framework’s (GMSF) housing target is still considered too low by many observers (including ourselves). However, at least it has confronted the issue of Green Belt release. Greater Manchester’s Mayor Andy Burnham campaigned on, and has delivered on this matter through his review of the draft Framework, and it will be covered in the much anticipated, upcoming 2nd draft of the GMSF. Whether this represents the promised “radically changed” approach to make more use of the city region’s brownfield sites, and reduce the impact on the Green Belt, we will have to wait to see. New rules in force since last April mean that all local planning authorities (LPAs) had to publish a brownfield land register before 31 December 2017. Nationally, Lichfields’ analysis shows that only approximately half of English local planning authorities have published their brownfield land registers (BLR); the registers tend to simply include sites identified in strategic housing land availability assessments/ allocated housing land. This is possibly related to, and symptomatic of, the slow delivery of local plans, with patchy coverage at best nationally and a similar development planning pattern across Greater Manchester too. As part of Lichfield’s analysis highlighted in this blog, we focus on the Mayor’s stated aim of tackling the city region’s ever-growing housing crisis with the re-use of brownfield sites. How will the GMSF make better use of brownfield land, and how realistic is this policy approach? Publication of the region’s registers in December 2017 provides some insight on this issue. To be fair, all 10 Greater Manchester authorities have published their registers, reflecting their wider regeneration aspirations and the drive to maximise the re-use of brownfield land for housing-led development. In total 1,314 PDL sites have been identified across Greater Manchester which collectively have the capacity to deliver around 100,100 new homes over the next 15 years. How many of these are deliverable without significant public sector investment will be interesting to see. It is by any measure a significant number, but it only helps to crystallise the case for retaining the Green Belt around Greater Manchester or not; the number of homes on BLR sites equates to only around 44% of the draft GMSF housing target of 227,200 new homes up to 2035. Many within the industry considered this aspiration to be too low already, identifying how it failed to serve aspirations for economic growth and the Northern Powerhouse agenda. Irrespective of this, we all have to grapple with where the other 127,100 or more homes will be built. It is also fair to say there is a mixed picture across Greater Manchester in terms of distribution of brownfield land. Figure 1 below compares the quantity of brownfield land to the previous draft GMSF requirement. Only Manchester, Salford and Bolton can deliver over half of their target. Six local authorities (Bury, Oldham, Rochdale, Stockport, Tameside and Trafford) can only deliver less than 30% of their requirement. Figure 1: Brownfield land register proposed dwellings compared to the previous draft GMSF’s requirements   Source: GMSF, MHCLG The capacity gap in Trafford (86%) and Stockport (88%) is very substantial to say the least. So what does this mean for the future spatial strategy, and what are the consequences? How are Trafford’s and Stockport’s (and others’) needs to be met, without further increasing the affordability gap and the pressure on house prices. The previous draft GMSF identified a series of greenfield sites - predominately from the Green Belt - that would be required to meet need, contributing some 63,850 dwellings overall. Since it was formally adopted in 1984, the Greater Manchester Green Belt boundary has largely remained unaltered and it is a highly controversial topic - hence the Mayor’s review of the first draft GMSF. However, even if one adds all of the potential GMSF allocations to the BLR sites, the total falls a long way short of housing targets. Taking Greater Manchester as a whole, BLR sites and potential GMSF allocations will only deliver 72% of the city region’s housing requirement overall. Again the picture is highly variable, with Bolton and Bury close to achieving their requirement, but others, including Trafford and Tameside, having significant shortfalls. Figure 2: Total GMSF allocation & proposed brownfield land register units compared to the previous draft GMSF requirement Source: GMSF, MHCLG Furthermore, when considering the identified allocations, the GMSF has focused primarily on a few very large sites coming forward to meet the shortfall in supply. This results in inevitable pressure on infrastructure in key communities. We will have to wait and see how the 2nd draft GMSF responds to these issues, but it may for example include a broader range of sites, of different sizes and locations in order to de-risk the delivery issues and problems associated with not achieving the housing requirement. Brownfield land is one step towards meeting the requirement, and key questions will remain around delivery, and how long term requirements are to be met.   However, as demonstrated in Figure 3, there remains a shortfall of 63,245 homes to meet even the first draft GMSF housing target.  Regardless, the 227,000 GMSF requirement still remains well below the level of housing necessary to address housing pressure and the under-delivery that the city region has experienced over the years, even before considering the long-term economic growth needs of the conurbation at the heart of the Northern Powerhouse. Figure 3: Identified housing shortfall Source: GMSF, MHCLG Conclusion Whilst there is much to be welcomed in the Greater Manchester local authorities publishing their BLRs before the deadline, it seems that the re-use of brownfield land for housing can only be part of the solution. Even if every one of these sites were to come forward as intended, the local authorities still need to identify land for more than 127,100 homes just to meet the GMSFs conservative targets. If less land is to be removed from the Green Belt, there remains significantly more deliverable sites that will have to be found to meet need. This is even before a debate as to whether a target of 227,200 is suitably ambitious for a great conurbation such as Manchester, that should be driving the economy of the North in the Northern Powerhouse agenda.   Image credit: A.P.S. (UK) / Alamy Stock Photo  

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Factory floor to front door

Factory floor to front door

Tom Willshaw 12 Jan 2018
Assessing the case for removing light industrial to residential permitted development rights The temporary permitted development right (PDR) for change of use from Use Class B1(c) light industrial to C3 residential came into force on 1 October 2017. This means that light industrial premises which have a floor area of less than 500 sqm can now be converted to residential use under the prior approval process, rather than requiring an application for planning permission. The temporary PDR is in force until 1 October 2020 (though any changes of use permitted during this period are permanent). The process is subject to various limitations and conditions, which are covered in an earlier blog by my colleague Owain Nedin. The new PDR represents another of the Government’s wide-ranging measures aimed at boosting housing supply across the country. However, the PDR raises some potential issues for the future economic vitality of local areas that local planning authorities may need to consider. These include: permanent loss of business space, particularly of smaller industrial and workshop premises which can play an important role in the local economy; limiting the ability of local areas to plan effectively for business needs, employment and growth; and creating potential uncertainty for businesses and reduced scope for land use planning and place making for the local planning authority. Local planning authorities have the ability to remove PDRs by introducing what is known as an ‘Article 4 Direction’. This allows authorities to require change of use applications, meaning they can refer to the development plan and weigh material considerations into the balance in the process of making a decision. An Article 4 Direction requires a clear justification and a defined boundary for the proposed exemption area. Local authorities must therefore compile the necessary evidence to meet these requirements. There are two main types of Article 4 Direction: immediate and non-immediate. An immediate Direction removes a PDR with immediate effect, but must be confirmed by the local planning authority following local consultation within six months, or else the Direction will lapse. A non-immediate Direction comes into force after a period of 12 months and the PDR is removed upon confirmation of the Direction by the local planning authority following local consultation. Lichfields has developed a staged analytical framework to support local authorities in making a robust case for implementing a non-immediate Article 4 Direction. The framework draws on a range of economic data sources, local commercial property market signals and the existing planning policy position. It enables local authorities to scope, evidence and prepare the case for an Article 4 Direction, by identifying and quantifying light industrial stock that qualifies for the PDR and the wider significance of this space within a local area in terms of business activity and economic value. In turn, this can allow an appropriate exemption area to be defined and taken forward through the due process as the basis for making a Direction. Lichfields recently prepared such an analysis (also including offices which are subject to similar PDRs) for the town of Newhaven on behalf of Lewes District Council. Newhaven was one of 18 locations that were awarded Enterprise Zone status in 2015. As part of the analysis, Lichfields quantified the number of eligible light industrial premises in the town and the proportion that fall within the Enterprise Zone area. Light industrial floorspace clustering example output.  The analysis shows that Newhaven is an important location for light industrial activities in Lewes District, containing around a quarter of the local authority’s total stock of light industrial space. Furthermore, the vast majority of light industrial premises that are eligible for the PDR are within the Enterprise Zone, which has been designed to help stimulate the growth of the local economy. The quantitative analysis was coupled with site assessments to identify the function of different employment clusters in the town. The analysis concluded that the Enterprise Zone supports considerable light industrial activity, which is likely to develop further given that priority sectors for the Enterprise Zone include environmental technologies and healthcare and biologics. Lewes District Council’s Planning Applications Committee reviewed Lichfields’ analysis and found that it provided “clear evidence to support the implementation of Article 4 directions in Newhaven to protect office and light industrial use”. The Committee resolved to approve the Directions in October 2017 and these are likely to come into force later this year. They will serve to protect employment floorspace in Newhaven, thereby supporting the expansion of innovative, high value growth sectors in the Enterprise Zone. The new PDR has potential implications for industrial locations across the UK. The recently published Draft London Plan encourages London Boroughs to introduce Article 4 Directions where appropriate to ensure they can retain sufficient industrial and logistics capacity. As identified in Lichfields’ London Plan Insight, the vast majority of Boroughs are expected to retain or increase their existing industrial capacity. The implementation of Article 4 Directions will be vital to support the economic function of industrial clusters across the capital to help meet the ambitious targets for economic growth set out in the London Plan. Lichfields’ Article 4 Direction framework brings together robust analysis of local property markets and economic indicators which can help local authorities identify and prepare the case for making a Direction. For further information, please see our information flyer or get in touch.

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