There is a risk that the draft PPG3 will encourage the common fallacy of identifying the types of housing provision that will be required in future with the needs of those sections of the community which are experiencing the most rapid growth.

  Thus, it refers to the change in the composition of households over the next two decades expected in the Government's household projections, and comments:

"Much of the projected growth will be in one-person households. Local authorities should therefore adopt policies which take account of the potential nature of demand arising in their area . . ."—Para 8

  But newly forming households can no more be equated with the occupants of the housing that needs to be built than purchasers of new cars are confined to those who have not previously owned one. Something like 90 per cent of the housing market is in second-hand units. Much of the emerging need of single person households will be met by the existing housing stock—with or without structural alteration. This point also arises on the suggestions in Para 12.

  An important point is raised by the comment that:

"the Government does not accept that different types of housing and tenures make bad neighbours."—Para 11

  One consequence of the universally endorsed desire to make more use of brownfield sites for housing is that many of these will, by definition, adjoin continuing commercial, industrial or agricultural activities, which may not themselves be good neighbours for residential development. The problem is already beginning to make itself felt but under existing legislation the new residents are entitled to object to nuisance or disturbance from established users instead of being expected to accept conditions of which they must be assumed to have been aware before they moved in. As a result a number of businesses providing employment and economic activity are being threatened with closure or the need to make expensive adjustments to their pattern of operation. Examples include new housing which is affected by port operations, early morning landing and movement of fish catches, and a variety of agricultural and industrial processing operations.

  On affordable housing, the draft acknowledges the need to monitor the amount of affordable housing being provided under planning policies of local authorities, and for those plans to set out how many homes of various types need to be provided within plan areas.—Paras 18 and 14

  This needs to be expanded. It is most important that such monitoring is done in a way which distinguishes provision of affordable dwellings within the overall target figures set out in development plans. If, for any reason, such as a shortfall in financial support for affordable housing, the numbers built fail to meet the estimated need, the deficit must not simply be, in effect, added to provision allocated to the market sector. This would merely add to the risks of too many houses of the wrong kind being developed: a shortfall in the affordable sector which cannot be made good must be reflected in a corresponding reduction in the overall figure for the area concerned.

  A small point: The precise meaning of the phrase "in perpetuity" needs to be explained in the context of making provision for local needs where rural housing is concerned. Para 17 and Annex A.

  The national target of 60 per cent of additional housing provision to be on previously-developed land, or through conversions, is set out. But it is in the nature of averages that individual places will diverge from them. The facts of historical development make it inevitable that some areas will have more potential for meeting, or exceeding, that target than others. Some explicit recognition that some will necessarily fall short should be introduced, together with acknowledgment that places with high potential will not automatically be those where the pattern of demand allows it to be fully realised. Para 15.

  The discussion of the so-called "sequential test" is likely to give rise to some confusion and misunderstanding.

  As set out, what is proposed does not in fact equate to the sequential test as defined for purposes of retail and leisure development in PPG6, and the phrase "systematic approach" would be better substituted—as used in the introductory material to this subject in the draft. Para 23.

  In PPG6 preference is given to town centre sites, whether those that are both suitable and available can be identified, followed by fringe-of-centre, and only in the absence of either of these should out of centre locations be considered.

  While the draft refers to "the phasing of release of development sites" it is clear that the list of criteria which follows is not intended to be in any order of preference or priority. This leads to the ambiguity, which has been widely noted, between the statement that the Government: Para 25.

"does not expect greenfield sites to be released for development until the following options have been considered for providing additional housing . . ." Para 25.

"This approach does not mean that all previously-developed sites must be used before any greenfield site is released . . ." Para 26.

  Some guidance on what is to be understood by "realistic unrealised potential" would be highly advisable, particularly in the light of the fact that local authorities will be faced with the need to determine such matters, and an objective rather than a subjective approach will be desirable. Para 29.

  On car-parking standards, the draft PPG should distinguish between influencing the desire to own cars and decisions as to how and for what purposes they are used. While it is true that "much off-street parking, especially in garages, is under-used", this owes as much to the inadequate space within the home itself experienced by many families. Para 42.

  The objective should clearly be to "plan for people and not the car, but this requires more subtle standards than seem to be envisaged in the document. Within a housing development of any size, an overall average of one and a half to two car parking spaces per dwelling needs to be arrived at by giving some units two (or even three) spaces, others one, and a proportion none at all. Para 41.

  This should be spelled out more precisely: continued "standard" provision of a mixture of one and two off-street spaces will simply result in a maldistribution of car-parking, and frustration among those unable to park off-street. This, in turn, is likely to lead to an increase in car-usage as people are reluctant to leave their cars outside their homes when they go to work, shop, or play. A satisfactory place to park the car people will insist on owning may very well play a part in reducing the extent to which it is actually used.

  Some indications as to what is meant by "larger" and "smaller" new settlements is necessary, given the differing ways it is proposed they should be brought forward. Para 65.

  Given the importance of monitoring in the whole process of planning the future pattern of housing, it is unfortunate that the further guidance that is being prepared will not, apparently, itself be the subject of consultation before it is issued and becomes operative. Para 67.

Harvey R Cole

May 1999