Help Stop PPS14

A Review of the Impact of PPS14 on Northern Ireland

Overview

The Department for Regional Development (DRD) formulated "Shaping our Future - The Regional Development Strategy for Northern Ireland 2025 (RDS)" in September 2001. This was followed in June 2004 by an Issues paper to interested parties which produced an almost 50/50 spilt on the issue of retaining or removing the presumption in favour of building in the open countryside. Notwithstanding this response, PPS14 removes the presumption in favour.

The RDS threat of tighter planning controls and the slow roll-out of Area Plans, extending green belt and countryside policy areas, generated increasing numbers of 'get- in- first' outline planning applications. The message to farmers was to 'bank' a Planning Permission before it is too late. The present situation is therefore an artificial crisis of the DRDs and DoEs own making.

Even if PPS14 remains in force and unchanged, the number of planning approvals already granted should provide some years of normal housing completions at current levels before numbers will be significantly affected.

The Minister and the DRD make much use of the word 'sustainability' in justifying these swingeing changes to what is already a fragile rural economy. We believe that sustainability can be better achieved in many ways overlooked by the proposed legislation and PPS14 contains numerous omissions and questionable assumptions.

The following is a list of the key points which we have identified. We ask for your support in providing further detailed information and additions to this list. Other interested and affected parties will, no doubt, be making their own views known during the consultation period.

Key Points

1. The minister quotes a figure of 9,520 approvals for new rural dwellings in 2004/05. The Commercial Information Company (CIC) (a specialist provider of Planning information supplied by the Planning Service) records a figure of 8,216 Full and Outline approvals. To arrive at the Minister's figure we must assume that he has included Reserved Matters approvals which numbered 1,133. This is effectively 'double counting' because no-one with Outline Permission can start to build until they have received Reserved Matters approval at which point they appear for a second time in the statistics.

2. The Minister also states that the figure for 2005/2006 will be well over 12,000, but the CIC figures show 6,983 Full and Outline approvals to 10/3/06 which is only three weeks short of the full year. This is a FALL of at least several hundred and certainly nowhere near the 12,000 quoted.

3. The Minister states that the number of rural planning approvals here are three times the combined total of England, Scotland and Wales. Using his own figures for 2004/2005 that combined total would be 9,520 divided by 3 = 3,173 in Great Britain. There are two sources of statistics for the rest of the UK. Firstly from the Planning Authorities for single plot planning permissions which produces a figure of about 20,000 per annum. Secondly, from HM Customs who process about 12,000 selfbuild reclaims per annum. However, many selfbuilders use builders who are VAT registered so the true figure is closer to the 20,000 than 12,000. Admittedly some of these could be urban or brownfield sites but in either case they are considerably greater than 3,173.

The DRD must explain these apparent discrepancies in the statistics quoted in the Ministerial statement. They would appear to substantially undermine the primary case put forward that these draconian measures are necessary to curb an 'explosion' of planning approvals.

4. The figures do not represent the number of houses being built on the ground in the countryside. All the statistics quoted refer to 'approvals' which have been artificially stimulated by applicants trying to 'beat the legislation'. A more accurate measure of actual annual building activity is the number of Full and Reserved Matters approvals which are as follows : 00/01=3,275, 01/02=3,373, 02/03=3,492, 03/04=3,472, 04/05=4,167, 05/06=4,135. A small increase in the last two years but not amounting to the 'crisis' implied by the Minister's statement.

5. A statement on the DRD website, www.drdni.gov.uk (consultation zone) claims that "In the last 10 years over 86,000 new dwellings were approved, equivalent to building 2.5 Derry Cities in the countryside." This sensational statement is both inaccurate and misleading. The CIC figures show 59,000 Full and Outline approvals. A long way short of 86,000. More importantly, even that number could not be 'built' as the Outlines must first apply for Reserved Matters approval. These, added to the Full approvals over the last 10 years amount to 33,750 - considerably less than half of the 86,000 cited as being "2.5 Derry Cities 'Built'."

6. Farm incomes are on a falling trend. Many farmers are trying to diversify and may not meet the criteria to allow them to pass on sites to their family. PPS14 effectively disenfranchises them.

7. There are thousands of builders, tradesmen and employees of small, family owned and run manufacturing companies who live in the country and help to build the dwellings which PPS14 intends to stop. They are likely to become unemployed. Rural manufacturing companies are already under pressure from the withdrawal of the Rates holiday which they had benefited from until last year. There is no impact study on the economic consequences of PPS14.

8. Those who build in the country spend considerably more money on sustainable building products, low energy designs and heating systems than most developers of housing estates. Planning policies should encourage and give credit for the use of sustainable and 'green ' materials.

9. The water service already apply stringent rules to the installation of septic tanks and if there remain any concerns over ground water pollution, the legislation can be tightened further as there are plenty of treatment systems on the market able to produce completely non toxic waste water.

10. Members of the public usually only object to housing in the countryside if it is out of place, poorly designed or badly sited. Current legislation has already greatly improved the location and design of non intrusive rural housing and measures to improve this still further should be taken. There is a responsibility upon all those who build in the country to use experienced and properly qualified architects and to build dwellings which are in sympathy with their surroundings. Greater emphasis should be placed on the restoration and re-use of derelict and vacant traditional buildings using strictly vernacular techniques and materials. .

11. Country dwellers are accused of increasing the use of motor cars. This ignores the fact that, using modern technology, many of them can now work from home. It is also hypocritical to condemn the use of the motor car when there is no integrated transport policy in existence within Northern Ireland. Major cities have many radial public transport routes in and out but no linking circumferential services. Park and ride systems could easily be extended. There are no car sharing incentives in existence. Any one of these measures would reduce carbon dioxide emissions by a greater amount than a small number of commuting country dwellers.

12. Although intent upon stopping building in the countryside there is no mention of increasing existing settlement limits nor those for Permitted Development for existing dwellings. Such measures would help those who wish to build a new home or to extend their present one. Without them, PPS14 is simply 'damming the river' with no thought for the consequences.

13. The government cannot defy the law of supply and demand. The inevitable result of these severe restrictions on building will be to see prices of houses rising substantially in Northern Ireland from their already record levels, thus putting home ownership further out of reach for those struggling to get onto the first rung of the ladder. This is already happening since PPS14 was announced. At the very least, the DRD should have carried out a house price impact study before publishing PPS14.

14. At this time last year in the Republic of Ireland, the Minister for the Environment Heritage and local government, Mr Dick Roche, TD, issued his final planning guidelines on rural housing. "The guidelines represent a presumption in favour of quality one off housing for rural communities, provided proposals meet normal standards in relation to matters such as the proper disposal of waste water and road safety." www.pps14.com/dick_roche.pdf

Yet on this same island almost one year later, draft PPS14 states policy CT1 - Development in the Countryside - "a presumption against development would be operated throughout the countryside with the exception of a limited number of types of development which are considered in principle to be acceptable." Dick Roche would seem to have a greater awareness and understanding of the needs of a largely rural community.

We would welcome your comments and any additions to our initial assessment. We also ask for your support in putting pen to paper in particular to: PPS14 Department of Regional Development, Regional Planning and Transportation Division, Room 301, Clarence Court, 10 - 18 Adelaide Street, Belfast, BT2 8GB.

Encourage others to do the same. You must object as an individual. Do not send petitions or joint submissions. Collective objections only count as one. Copies of your submission to the consultation team of PPS14 should also be sent to your local MLA and councillors.

At all times it should be emphasised that the principle of sustainability is to be promoted and supported along with green belts, areas of outstanding natural beauty and other designated/protected areas, but that the proposed practice enshrined in PPS14, with an almost blanket ban on new housing in the countryside, will in many ways prove counterproductive in achieving this end and should be seriously reconsidered.