Response - New Planning Policy Statement 3

There is much to welcome in draft PPS3. However, Shelter has a number of concerns which we believe will need to be addressed through the consultation process:

1. The emphasis on satisfying demand for housing risks exacerbating the problems the planning system is already facing in encouraging housing development in the places where it can do the most good for the whole of society;

2. The proposals address only the supply of sites identifiable at the time planning documents are prepared, neglecting the potential contributions to housing supply from within the existing built environment, even though these are often well-suited to meeting the needs for affordable housing; in particular, we are concerned that 'windfall' sites will be neglected in plan-making and that urban housing capacity studies are to be scrapped in favour of assessments just of housing land supplies;

3. The proposals do not seem to pay sufficient regard to the relationship between housing and many other aspects of planning: this is of critical importance when considering the supply of affordable housing, which should be close to jobs, shops and services both in support of sustainable development and so that poorer people are not further disadvantaged by greater travels costs and inconvenience when meeting their basic needs;

4. Despite an aspiration to a variety of housing types being available in the market sector, the types of dwelling most needed in the private sector can be insisted on only at 'larger sites', which is likely to increase the pressures of overcrowding at the bottom end of the private housing market, in the rented sector and at the top end of the affordable housing sector;

5. The preference for brownfield site development will be more difficult to implement under PPS 3;

6. It is also unfortunate that other socially beneficial objectives in PPG 3 such as the relationship with urban development as a whole, the travel consequences associated with housing location and the environmental consequences of different supply patterns have been omitted.