Consultation on the draft PPS3: Housing is in full swing. PPG3 has had a dramatic impact on the ground and expectations for the new guidance are high.
But the draft omits some key passages of PPG3, particularly regarding design, and these will be missed if not reinstated in the final version, notwithstanding the strengthening of PPS1 on design issues.
The other key areas are density and parking, and there are also concerns about the emphasis on new development, and the relative neglect of planning for changes in the existing stock of homes. The draft introduces the idea of ranges of densities which could usefully be applied to both.
As CABE says in its initial response: 'At the heart of PPG3 has been a debate about density. Policies on density fundamentally influence what gets built and where. But we must remember that density is just a numerical tool. Good planning is not about number crunching, and there is no necessary correlation between density and design quality.' It is widely accepted that there is a need to make better use of land and that the minimum-density policies of PPG3 have been helpful, but we need a more pragmatic application through local framework plans. Discussion immediately turns to the measure of density and we need to make it more sophisticated on two levels.
First, at the level of the neighbourhood we need a measure of gross site density, difficult though this can be: the land taken not just by surrounding roads but also by community facilities and infrastructure. This would balance the advantage of net site measurements, which for small sites largely ignore all this, while large estates have to embrace at least their own road circulation. Even net site density needs to encourage tighter road designs and more dual use of land by people and vehicles.
On this, CABE says pointedly: 'We need to fast track the Manual for Streets. Every extra month that we have to live with Design Bulletin 32 means more new homes and neighbourhoods that fail the people who live in them.' Second is residential density.
The negotiation of section 106 agreements for affordable housing has exaggerated the importance of units-perhectare, which has tended to reduce the average dwelling size. Further, the absence of minimum floorspace standards for private-sector dwellings will lead to tiny flats becoming less valuable than RSL-driven 'affordable' homes as they age.
This may all change with the introduction next year of the Home Information Packs which will describe properties' floor area.
Thus policy needs to consider density in terms of dwellings per hectare, floor area per hectare and dwelling mix together. But policies need to be sensitive to 'market signals' and should not be so rigid as to force the building of dwelling types and sizes for which there is little demand.
CABE's position has moved on from having a national minimum density to allowing authorities to make their own decisions on density levels: 'We also need to deal with density in detail at the regional and local level. This could be achieved through target ranges embedded in sub-regional spatial plans and through specific thresholds defined in local development frameworks.' The ghost at the party is form, the variable that mediates between density and quality. By Design is the companion guide to PPS1 and sets out national design objectives. It should now be updated to reflect the new planning system and deal better with density and parking issues.
Brian Waters is principal of the Boisot Waters Cohen partnership, see www. bwcp. co. uk