PPS3 - Plus ça change.....

One gets the impression that Greg Clark’s announcement the other day (in his capacity as 'Minister for Decentralisation') was more about headline-grabbing than garden-grabbing. I have been taking a look at the new version of PPS3 (which is what all the fuss was about) and was struck not so much by the changes as by the extent to which this PPS remains unchanged. This is not a wholly recast policy statement, but simply the third edition of the existing PPS3, first published in November 2006, revised in January 2010, and now revised again. Furthermore, even those changes which were headlined may not be so dramatic in their effect as Fleet Street hacks were led to believe.

The definition of ‘brown land’ has been amended so that it now excludes land in built-up areas such as private residential gardens, parks, recreation grounds and allotments, which has not previously been built on, and also land which was previously developed but where the remains of the permanent structure or fixed surface structure have blended into the landscape in the process of time (to the extent that it can reasonably be considered as part of the natural surroundings). There is no longer a presumption that land that was previously-developed is necessarily suitable for housing development, nor that the whole of the curtilage should be developed.

At the same time, the policy on housing densities has been relaxed. However, the section on “Efficient use of land” (paragraphs 45 to 51) remains in place. Using land efficiently is still a key consideration in planning for housing, and there is still a sentence which reads: “Regional Spatial Strategies should set out the region’s housing density policies, including any target.” (Shome mishtake, shurely?) LPAs are still told that they should develop housing density policies having regard (among other things) to “the spatial vision and strategy for housing development in their area”, including the level of housing demand and need and the availability of suitable land in the area, and the desirability of using land efficiently. As against this, they must also take into account the current and future level and capacity of infrastructure, services and facilities such as public and private amenity space, in particular green and open space, current and future levels of accessibility, particularly public transport accessibility, the characteristics of the area, including the current and proposed mix of uses and the desirability of achieving high quality, well-designed housing.

Quite clearly, this revised version of the advice in PPS3 does not do what the press has been led to believe it does. The important point is that most of the garden land and other sites which are no longer to be labelled as ‘brown land’ will in any event be within the urban envelope or other settlement boundaries, and so are still potentially suitable for housing development in policy terms. I shall certainly be advising my house-builder clients to press on with their ‘garden-grabbing’ proposals!

A reader commenting on one of my recent posts points out that this and the various other changes announced by DCLG are turning out to be an ill-thought out mess. There must be hundreds of appeals (he suggests) that are going to be re-opened, from small single house developments to urban extensions. Whether this will happen in practice may be open to question, but I would certainly agree with the general proposition that Pickles and his merry men are proceeding to make an unholy mess of the planning system. Is this Sir Humphrey’s latest ploy? – Let ministers get themselves into a thorough muddle over town planning and then step in with some helpful suggestions to the next Secretary of State and his new ministerial team as to how the mess might be cleared up.

© MARTIN H GOODALL