GOMM VALLEY AND THE NEW GOVERNMENT PLANNING POLICY
It is to be expected that recent changes in the government’s planning policy will in some way affect the future of Gomm Valley. In order to appreciate what the impact might be, it is important to understand the relevant parts of the draft Planning and Infrastructure Bill which is due to be enacted by parliament in the coming months. The purpose of this present assessment is to raise awareness amongst the Penn & Tylers Green community of the implications of building over precious parts of Gomm Valley, and whether there is anything in the proposed new planning legislation which will cause additional irreversible harm to our local environment, or indeed create improvements to what is currently proposed by Taylor Wimpey and under consideration by the Planning Inspector.
Gomm Valley and Ashwells were earmarked by the old Wycombe District Council to contribute to a rolling five-year supply of land for housing, in response to targets set by the policies of the previous Conservative government. Whether the resultant development of the valley is to be by Taylor Wimpey, or by another housebuilder, there is no going back, no matter how much we feel that this is a flawed decision because of the detrimental effect of building on land of outstanding natural beauty, or because the existing infrastructure, particularly roads, is incapable of supporting it. All we can do now is strive for the best possible outcome – outstanding design and a relevance to the needs of the community.
Gomm Valley Appeal Inquiry
At the end of the Gomm Valley public inquiry on 21 May, the Inspector advised that we should expect his decision on Taylor Wimpey’s appeal ‘”at the end of summer”, which is now approaching. Since the conclusion of the Inquiry, we have had a General Election, and a new government installed at Westminster. One of the first policy announcements made by the Labour Government was on planning reform. At the core of this policy is a plan to increase the annual volume of new builds. This government’s overarching ambition is to deliver 1.5 million homes during this parliament, of which 370,000 are to be built in the first year, raising the annual target set by the previous government by 120,000. How might this impact on Gomm Valley? And is there any possibility that the Inspector might be persuaded that the need for more houses gives him a mandate to accept Taylor Wimpey’s appeal?
Proposed planning reform
The previous Conservative government had cancelled its original requirement for local authorities to achieve specific housebuilding targets, but it is to be noted also, that Wycombe had already met the relevant criteria for the 5-year housing land supply. The new Labour government has announced fundamental changes to the way in which housing numbers are to be allocated across England. As demanded by Angela Rayner in her capacity as Secretary of State for Housing, Communities and Local Government, and Deputy Prime Minister, these are in fact not ‘targets’, but ‘mandates’, and she has said that failure to achieve these will be met with Government intervention. What is not clear is whether any account will be taken of the 1.4 million homes already with planning consents.
By changing the way local housing need is calculated, the distribution of 370,000 homes across England and Wales in the first year has been arrived at by Labour’s restoration of the so-called ‘mutant algorithm’, which they appear to have tweaked, apparently to push homes into areas that simply don’t need them, of which Buckinghamshire Council’s share is 4,122 homes, an increase of 1,210 over and above the number of new-builds previously proposed, amounting to an increase of 42%. Martin Tett has said in his response to this (as reported in the Bucks Free Press on 9 August), “it is no exaggeration to say that the changes to the planning system are cataclysmic for Buckinghamshire. The ‘top-down targets’ that have been set are mandatory and non-negotiable.” Unless these targets are met, Rayner has threatened that central government will intervene and impose a structure on local councils to achieve the numbers required, but it is unclear at the moment how this would be done. She has stated that this will form part of the Planning and Infrastructure Bill when it is brought before parliament.
Politically motivated distribution?
The government appears to be dictating from the centre, implicating a shift from building in cities where demand is high, to the countryside where demand is less. Conservative controlled councils will see their house building targets increased by more than in Labour councils. Analysis shows that as a result, the 55 Conservative controlled councils in England with planning powers, will have targets increased by 43%. Yet across the councils run by Labour, many of which are in the biggest cities, the upward revision will be just 7%. This means that the number of new homes to be built in Conservative areas will go up by almost 23,500, but in Labour controlled areas the new targets add up to only 11,000 houses. In effect, this spread of new homes has disadvantaged rural areas by increasing in the number to be accommodated, compared with a reduction in the number of homes to be built in cities. It’s hard not to resist thinking that this is politically motivated, with Conservative voters made to bear the costs of policies they voted against in the general election. Or is it just a coincidence that 9 out of 22 members of cabinet have had their targets reduced, while the constituencies of shadow cabinet members, including Rishi Sunak and Jeremy hunt, have been handed some of the biggest increases in England?
In a joint letter to the editor of The Telegraph on 5 August, Martin Tett, along with five leaders of other councils, said “as leaders of the county councils bordering London, we seek a mutually beneficial relationship with the capital. However, the government has seen fit to reduce London’s housing targets while increasing those for the surrounding area, reinforcing a pattern of our towns and villages because London is unable to meet its housing needs.”
Role of local community
The role of local councils and local people in deciding where these houses are to be built is also likely to be substantially reduced. This policy runs the risk of marginalising rural areas by placing restrictions on community engagement, but the government appears to have gone out of its way to minimise the ability of local people to exercise their democratic control over housing development, by stripping locals of their say in the planning process while failing to build homes where they are most needed. Critics warn that these changes will hit Conservative heartlands in southern England the hardest, putting pressure on rural areas to make space for hundreds of new homes whilst at the same time reducing local ability to affect their nature and location. In the opinion of the CPRE, these changes will lead to an unacceptable loss of local democracy, scrutiny, and accountability, and lead to worse outcomes. Other proposals include removing the automatic right to appear in person at hearings to discuss local plans. It is claimed that these reforms are designed to streamline the system to make it easier for national housing targets to be met, but critics say that they unfairly exclude local people from having influence over what happens in their area
Infrastructure
The increase in number of houses will need to be met with appropriate improvements in essential infrastructure, such as roads, schools, GP surgeries, energy, water and wastewater, digital networks, etc. However, it is unclear how all of these will be funded and delivered in the timescale set for the building of new homes. Chancellor Rachel Reeves has already begun to cut infrastructure funding to councils, as part of her efforts to offset her fictitious £22bn ‘black hole left by the Conservatives’. Failure to provide supportive infrastructure to serve the increase in housebuilding will no doubt have an adverse impact on community life.
National Planning Policy Framework 2024
Previously, the NPPF assessed future housing needs on population changes and local affordability. Instead, the new government will change these affordability assessments to take account of how many people might move into an area if housing were cheaper. There are many other proposed changes to the NPPF, which have been already been comprehensively described and commented on by Zack Simons (a planning barrister practising at Landmark Chambers in London and Birmingham) in his paper dated 31 July 2024 (issued on 1 August to interested local parties by Nicole Webster, Clerk to Penn Parish Council). Consultation on a draft revised NPPF is currently in progress, and this will run until 24 September 2024, inviting responses to 106 questions on the changes, concluding in a revised NPPF to be issued before the end of 2024. At the conclusion of Zack Simons comprehensive analysis, he responds positively to what he broadly believes to be serious changes in planning policy, which in his words are ambitious, but thorough and deeply considered.
However, the revised NPPF, is not about setting targets per se, but about process and delivery. Personally, I’m happy that someone has had the presence of mind to drop the references to the elusive concept of ‘beauty’, and the rather spurious notion that this could be effectively applied to decision-making on design, as the use of this term is subjective and difficult to define. ‘Well-designed places’ ought to be a perfectly acceptable way of judging quality of design. I’m also relieved that there has been no change in the policy that “Development that is not well designed should be refused, especially where it fails to reflect local design policies and government guidance on design”. And one cannot argue with Reyner’s stated ambition of creating a vision “for places to be designed so well that you, me, anyone and everyone would want to live there”.
There are indeed many changes to the NPPF which are to be welcomed. These include changes to promote mixed tenure development, community development, small sites, and design typologies.
The Government says that it believes that local areas are best placed to decide the right mix of affordable housing for their communities, including a mix of affordable homes for ownership and rent. The NPPF already sets the expectation that when establishing housing requirements, local planning authorities must consider the needs of different groups in the community. But how to reconcile this in practice with the top-down housing numbers now required? Greater emphasis on affordability is to be welcomed, although further detail on how this is to be delivered will come later, as will investment in social housing which Labour is set to announce ‘later in the year’. The government has indicated that it also sees a role for councils themselves to deliver some of the additional homes, but few councils currently have the resources in both people and financing to take on social housing projects.
Local Plan
Then there is the question of the status of the Buckinghamshire Local Plan, which is already underway. Currently it is scheduled for completion in April 2026, following a public consultation exercise, and is scheduled to be submitted for examination by the Planning Inspectorate by August 2026, with adoption sometime in early 2027. This will then replace the Wycombe Local Plan which was adopted in August 2019. Transitional arrangements may be introduced for emerging plans in preparation, but the detail of how this might be introduced is yet to be worked out. The Government says that further details of its intentions around plan-making reform will be published in due course.
Aerial Photo of Gomm Valley
Taylor Wimpey’s original planning application was for a hybrid of (a) full consent to a comparatively small (83 homes) development of the south-east corner with access from Hammersley Lane, and (b) outline consent to the main part of the valley (461 homes), reaching up to a point 200 metres south of the Ashwells fields. These two parts of the application cannot be separated by consenting one and refusing the other. Consent to (a) – Phase 1 – will allow Tayor Wimpey to build the houses according to the designs as submitted, linked to consent (b) which will be subject to future ‘Reserved Matters’ applications, requiring a full public consultation exercise, which in theory could result in house designs different from (and hopefully better than), those which might be approved for Phase 1. What is unknown is whether there is anything in the new planning policy which will influence its outcome. What is certain is that, notwithstanding any new planning rules, if the Inspector is minded to accept Taylor Wimpey’s appeal, his planning consent will be subject to many conditions, which will set the agenda for the local planning authority to apply in the inevitable negotiations which will follow.
Impact on Gomm Valley
So what are the implications for Buckinghamshire, and how might this affect the Inspector’s decision on Gomm Valley? In essence, this should not affect his decision at all. It is a matter of speculation as to how the Inspector may articulate his decision-making in order to include Gomm Valley as part of the new housing development in our area, thereby contributing to the additional numbers required by government policy. Will the Inspector be in any way influenced by this additional provision, and will it sway him to allow Taylor Wimpey’s appeal? In reality, it is academic whether or not the Inspector may be influenced by the new Government’s policy to reinstate mandatory housing targets, as his reasons to accept or refuse the appeal will of course remain private. But whatever decision he reaches, it ought to be based exclusively on the strength of arguments provided in statements recorded prior to, or presented during, the Inquiry – by the Council and Taylor Wimpey, and by their KC’s, and critically in my view, by the local community. If he were to observe this obligation and his decision is to refuse the appeal, then might it be possible for Taylor Wimpey to seek a judicial review, if it could be demonstrated that without the Gomm Valley development, Buckinghamshire Council would be unable to meet their new housing targets? It is this potential inter-dependence between the determination of the appeal and the new government’s housing targets, which worries me.
In Zack Simons paper, he says that targets do not equate to completions, but to achieve 370,00 in the first year, “we need more planning permissions. Lots of them. ie. More consents will lead to more completions”. But will Gomm Valley fall into this category in the eyes of the Inspector?
In conclusion, what I am attempting to achieve is a village-wide participation in the process, by raising awareness of events which are about to unfold as a result of the coincidental timing of the Inspector’s decision and the planning reforms soon to be in force. This is by far the largest development impacting on the Penn & Tylers Green community since the development of the Manor Farm estate, and we need to ensure that Gomm Valley does not finish up as just another estate on the outskirts of High Wycombe.
Ken Cooke
23 August 2024