Written evidence submitted by the Campaign for National Parks [NPP 27]

Executive Summary

• National Parks deliver numerous benefits to the nation, many of which derive from their high quality environment and the fact that they have generally been protected from over-development.

• As these are attractive places to live, house prices in National Parks are often significantly higher than the regional average. The current approach to housing delivery in National Parks, as set out in local plans, ensures that the limited development opportunities available cater for local needs rather than the high demand for market housing.

• Some of the changes in the consultation will undermine existing housing policies and the planning protection for National Parks and could lead to significant amounts of additional development in inappropriate locations.

• Rather than reducing the protection for National Parks, the Government should be enhancing it by introducing stronger protections against major development.

Introduction

1. The Campaign for National Parks is the independent national voice for the 13 National Parks in England and Wales. Our mission is to inspire everyone to enjoy and look after National Parks – the nation’s green treasures. We have been campaigning for 80 years to ensure that our National Parks are beautiful, inspirational places that are relevant, valued and protected for all.

2. We welcome this opportunity to submit evidence to the Committee on the Government’s consultation on national planning policy. We are very concerned that the Government has failed to consider the wider implications of many of the proposed changes, some of which will undermine existing planning protection for National Parks. Rather than reducing the protection for National Parks, the Government should be strengthening them. In addition to some comments on the current consultation, our evidence explains why national planning policy needs to be changed in order to provide stronger protection for National Parks.

3. Our evidence focuses on National Parks as that is what our charitable purposes relate to but most of the issues covered are equally applicable to Areas of Outstanding Natural Beauty (AONBs).

Protecting National Parks from over-development

4. National Parks are inspiring spaces for people to enjoy and improve their health and well-being[1], whilst making a significant contribution to the economy through tourism, farming and other related businesses. The annual turnover for businesses in National Parks was £10.4bn in 2012[2], and many of those businesses benefit from, if not rely on, the high quality environment of the Parks. National Parks also provide key environmental resources and services, such as water provision and carbon storage in peat soils and forests, which can mitigate the effects of climate change.

5. To make sure our National Parks are able to continue playing this important role more needs to be done to strengthen the protection for them. The National Planning Policy Framework (NPPF) emphasises the special status that National Parks should be afforded in planning policies and decisions and makes it clear that they have the highest status of protection. However, National Parks currently face a significant level of threat as a result of the continued prioritisation of economic growth over the environment which is leading to increased pressure for major developments and the erosion of planning protection.

6. We recognise that there is a need for sustainable, appropriate development in these settings if the areas are to remain living, working landscapes, but it is crucial that National Parks continue to be protected from over-development. Many of the benefits which National Parks provide, including tourism and rural economic growth, would be lost if anything were to detract from the special qualities for which they are valued. The challenge is to ensure that these benefits are not compromised by insensitive change, unsympathetic land use or irresponsible development.

Delivering housing in National Parks

7. The high quality environment in National Parks makes them attractive places to live. Based on 2011 Census data we know all the National Parks have an increasingly ageing population, indicating that they are seen as particularly attractive places to relocate to for those who are retired. We also know that second home ownership is an issue in National Parks. Consequently, average house prices in National Parks are already significantly higher than the average house price in their respective region. The premium for a property in a National Park varies from 27% to 90% but in five of the 10 National Parks it is over 60%[3].

8. The current approach to housing delivery in National Parks, as set out in Local Plans, ensures that the limited development opportunities available cater for local needs rather than meet the high demand for market housing. Several of the measures proposed by the Department for Communities and Local Government would undermine this long-standing approach and could lead to significant numbers of completely inappropriate housing developments in National Parks. Given that current policies restrict development in these areas, and that houses can be sold at a premium, developers are likely to be keen to build new housing in National Parks. They are also likely to want to do this quickly in order to maximise their profits, as the price premium is unlikely to be maintained if the additional planning protections which make National Parks such attractive places to live are removed.

Comments on the Government’s consultation

9. Although an equalities statement was published alongside the consultation document reviewing the impact on different groups of people, there is no evidence that the Government has undertaken any assessment of the impact that the proposals will have in different types of area. This is a serious omission given that the focus of the consultation is on delivering new homes and many of the proposed changes could undermine existing measures aimed at providing homes, particularly affordable homes, for those who need them most in National Parks.

10. We believe that there is a strong case for exempting National Parks and AONBs from several of the proposals in the consultation, including:

• Increasing residential development around commuter hubs – the definition of a hub proposed in the consultation document includes any rail station that has, or could have in the future, a service at least every 15 minutes during normal commuting hours. In theory, virtually all rail stations could have a service of this frequency, meaning that this policy would allow very dense housing development around small rural rail stations in designated landscapes.
• Supporting housing development on small sites – this is effectively introducing a presumption in favour of development on sites of less than 10 units if they are within or immediately adjacent to existing settlement boundaries. Over time, this could lead to a significant amount of additional development in National Parks as all settlements gradually expand in size. This proposal also undermines the existing policy on rural exception sites and will do nothing to deliver affordable homes to help meet local housing need.

Changes to national planning policy to provide better protection for National Parks

11. The major development test, which is set out in paragraph 116 of the NPPF, makes it clear that planning permission should be refused for major developments in National Parks and AONBs except in exceptional circumstances and where it can be demonstrated they are in the public interest. This is now a well-established part of the planning process but it is only one of a number of planning policies that have to be taken into account and it does not always offer sufficient protection to designated landscapes, as demonstrated by the recent decision by the North York Moors National Park Authority (NPA) to grant planning permission for the world’s largest potash mine. In this case members prioritised the economic benefits of the proposal at the expense of the environmental damage to the Park and argued that the potential for huge economic benefits represented exceptional circumstances.

12. The test was originally created in 1949 but its wording has been weakened over time. Originally there was a requirement to reject a proposal if it did not meet certain conditions but now all that is required is for the decision maker to include ‘an assessment’ of the need for and possible alternatives to, the development. The North York Moors NPA was legally able to approve the potash mine even though the assessment of the planning application identified that there would be significant damage to the National Park. In theory, permission could be granted for a major development in a National Park even if it met none of the conditions in the test as long as a thorough assessment had been undertaken and considered by decision makers.

13. Another concern is that the criteria against which proposals are judged have been weakened over the years. No longer must a proposed development be shown to be absolutely necessary in the national interest; it is sufficient under the NPPF if it is needed ‘in terms of any national considerations’, and an assessment of the impact of refusing, or permitting it, upon the local economy is clearly intended to play an important part in the consideration of the ‘need’ for the development.

14. In addition, whereas previously a major development would fail the test unless it was shown that there was no alternative scope for the development outside the Park, under the present formulation, the decision maker merely has to take into account the cost of and scope for developing elsewhere. Under the present policy it would be possible for a major development to get the go-ahead even though alternative sites were available in less environmentally sensitive areas.

15. To ensure National Parks are better protected against major development, the wording of the major development test must be strengthened and it should be made clear that it is a series of conditions which must be passed before major development is allowed in National Parks rather than just a series of issues which must be assessed. A stronger version of this test would make it clear that proposals for major developments in National Parks will be permitted only if it is demonstrated that they satisfy the following conditions:

(i) that the proposal is absolutely necessary in the national interest, which includes the furtherance of National Park purposes; and

(ii) that the proposal cannot practically be accommodated in an alternative location outside the National Park.

January 2016