Predicting the Future by Planning Applications

There's only so many reality TV and talent contests I can stomach on a weekend before my mind is stupefied into a mush reminiscent of runny guacamole and I begin to rock in my chair dribbling.   

So to maintain some semblance of sanity I thought I would do a little devilling back into planning application history to see if some sort of pattern might inform the future. 

Yep, I really need to get a life. 

Anyway, the chart below plots applications submitted in England since 1989 and appears to offer some perspective of where we might be going over the next few years in development terms. 

The late 1980's was a boom time in property development with land values soaring and applications at an all time high. And then 1987 happened. Black Monday in October 1987 saw a stock market collapse of unprecedented size and caused the Dow Jones Industrial Average to fall by 22.6%. This collapse, larger than that of 1929, was initially handled well by the economy, and the stock market began to  recover. It soon turned out that the quick recovery was illusory, and by 1990, economic malaise had returned with the beginning of the Gulf War and the resulting 1990 spike in the price of oil, which increased inflation. Subsequent years saw high unemployment, massive government budgetary deficits, and slow Gross Domestic Product (GDP).

You see where I'm going with this? 

2005 was the peak in applications at the same level as the late 1980's. 2007 saw the beginnings of the bank crisis and by 2010 unemployment was accelerating away, Government spending was yet to be brought under control and GDP was dropping. 

And here we are in 2012 at pretty much the same planning application levels as those being experienced in 1992. 

OK. So this is by no means an incisive analysis based on a rigorous data analysis and use of heavy duty algorithms. I'm still suffering from post  traumatic 'Britain's Got Talent' disorder to go that far. Nope, I just looked at the graph and remembered what happened when. 

And you know what, the phrase 'Life has a habit of repeating itself' didn't come about by accident.

So, are there any common trends that could be extrapolated from the past?   On the same basis there will be a small rise in applications between 2012 and 2015 followed by another dip before the economy begins to support a steady rise up to another peak in around 2025, after which the roller-coaster will start on down again. 

The bored musings of a sad old planner perhaps. But the DCLG published their  latest quarterly Statistics on Friday and, guess what, there was a 1% increase in the number of applications submitted against the same quarter in 2010. Spooky or what?

If you’re as sad as me, the latest statistics can be found here:

http://www.communities.gov.uk/publications/corporate/statistics/planningapplicationsq42011

An Open Letter to Government Concerning Tax, Tourism & The Rural Economy

THE IMPACT OF THE BUDGET PROPOSAL TO IMPOSE VAT ON THE SALE OF

STATIC CARAVANS IN OCTOBER 2012

  

28^th April 2012

Dear Member of Parliament 

In his March statement the Chancellor introduced the proposition of applying 20% VAT to the sale of holiday caravans.

This will impact significantly not only on the holiday parks industry, but UK tourism as a whole.

Initial independent economic assessment indicates that this action will result in:

• 52.2% slump in demand for static caravans
• 3,810 people losing their jobs across UK holiday parks alone [[1]]

Added to this will be the knock-on impact into the British manufacturing industry as well as tourism marketing, transport and the plethora of support services.

As the majority of holiday parks are naturally located on the coast and in the countryside, the impact upon rural Britain and hard pressed seaside resorts will be devastating.

This apparently minor addition to the tax portfolio will have dramatic and long-lasting impacts upon a vital sector of the UK holiday market.

The net benefits in tax income will be far outweighed by the losses to the tourism sector in terms of jobs and revenue and the knock-on effects into manufacturing and sustaining the rural economy.

You are respectfully invited to vote against this proposal accordingly.

Background

There are some 335,000 caravan holiday homes (210,000 privately owned) on 4,000 holiday parks in Britain, generating an annual £3.06 billion of tourism spending - that's 14% of Britain's entire tourism economy - and accounts for 22% of all holiday bed nights. [[2]]

Holidaying in caravans is a peculiarly British form of holiday-taking, second only to hotels in the provision of tourist accommodation. In many places caravans are the ONLY form of holiday accommodation available. 50% of the British population will take a holiday at a holiday caravan park in their lifetime.

The majority of parks are small family-owned businesses, some with farming histories stretching back over generations, and for which tourism is now a much more realistic alternative to the declining agricultural industry.

The sector has held up well during the economic downturn, with holidaymakers taking more holidays at home; encouraged by the Government’s Tourism Strategy (March 2011) and current TV advertising campaigns. This has been a direct benefit to rural Britain. However, this does not imply that parks are immune from the recession. Careful management and discounting have helped to sustain the industry.

Local Economy

Holiday caravan parks are extraordinarily valuable to their local economies, generating 7-8 times the tourism revenue per trip from an overnight stay than a day visitor. They sustain much of rural Britain through their revenue and job generation in ways that could not be delivered by other types of development.

• Independent economic research ^[[3]^] shows the direct and indirect spend for each 15 holiday caravan pitches support one Full Time Equivalent Job.

The knock-on benefits from holiday parks are considerable. Their revenues sustain a raft of local shops, services and associated businesses (both within and outside the tourism market) that feed off and support the holiday park operation throughout an extended season. For example, if visitor levels drop then this will directly affect tourist attractions, pubs, restaurants and souvenir shops.

Holiday parks are integral to local economies. Many provide the local shop, the pub and even the post office; facilities that would otherwise have been lost entirely to the locale. Larger parks with swimming pools and activity facilities make these available to their local community in common with their holidaymakers.

“It can be easy to underestimate the importance of holiday parks to rural regions - not least because parks are generally far less visible than hotels and guest houses. But collectively, their contribution to local economies is both substantial and irreplaceable”. - BHHPA

The Impacts

HMRC anticipates ‘Up to around 750 manufacturers, retailers and holiday parks selling static caravans will be affected by this measure’. This underestimates the impact of the measure. The BHHPA database shows that members manage 1,156 businesses selling holiday caravans directly onto 1,627 holiday parks. Since, the BHHPA membership comprises some 75% of the industry total, this would imply the measure will impact on over 1,500 holiday park businesses alone (with over 2,150 holiday parks selling holiday caravans) across the UK.

HMRC’s impact assessment anticipates, ‘a fall in demand of about 30 per cent, if the VAT change is fully passed on’. This is bad enough in itself, but underestimates the position. There are some 600 British businesses in the industry’s supply chain – for example, distributors (27), hauliers (60), manufacturers (34) and the manufacturers/suppliers of parts (494) (furniture, carpets, curtains, chassis, windows, heating, plumbing etc., etc.). The unintended consequences of losing a third of the business in this way will inevitably result in business closure and loss of jobs throughout the extended supply chain.

In particular, the impact of any decrease in demand, of ‘about 30 per cent’ suggested by HMRC, will be felt more acutely by the 34 companies manufacturing holiday caravans.

Park Operation and Effects

Owner-occupied caravans are purchased for personal use, but when not in private use, more often than not the caravan owner has contracted with the Park operator to rent their caravan out as part of the wider tourism offer on the Park. This is encouraged by the park operator in order to help sustain the holiday park and its various facilities.

This business model is very valuable in securing a sustainable holiday business, importantly providing commercial certainty at the start of each year with a known level of annual pitch fee income. In particular this format helps reduce the risk of bad weather deterring UK holiday-taking decisions at the last minute, which has become a very evident and commercially damaging feature of our home market of recent years.

Business investment plans are also made more certain and secure, allowing regular upgrading and improvement works to keep pace with the ever increasing expectations of a demanding tourism market.

Money to make discretionary spending of this kind on a holiday caravan is hard enough to come by at the best of times, let alone in the midst of a recession. Adding 20% in this economic climate is likely to tip the balance between making that investment or keeping the cash in the bank and spending it elsewhere; i.e. on overseas holidays.

The imposition of VAT on static caravans could literally Tax people away from taking holidays in this country and that is not a good thing.

This very traditional and UK-centric market is not immune to being attracted away by other opportunities. 

People thinking of upgrading and renewing their caravan will be discouraged (or at best delayed) and this will begin to affect the quality of the park. Perceptions in tourism are everything and maintaining high standards is a key requirement. Park operators unable to support their business through caravan sales will have less to re-invest and cannot then sustain pitch fees that reflect their investment. Slowly but surely a spiral of decline will commence that could be very hard to recover from.

The government really cannot afford to let a highly valuable tourism asset wither away for want of short-term tax revenues that are unlikely to cover a fraction of the potential losses in jobs and revenue that will be occasioned by this action.

Thank you for taking time to consider this submission.

Ian P Butter BSc (Hons) FRICS MRTPI

07860 684604

ianbutter@ruralurbanplanning.co.uk

Ian Butter BSc (Hons) FRICS MRTPI

Ian Butter has been providing professional advice to the Holiday and Home Parks Industry throughout Britain for over 34 years and has been instrumental in evolving Development Plan Policy concerning tourism, leisure and rural initiatives.

Ian was involved with the Matthew Taylor MP report (Living Working Countryside) for the Prime Minister in 2008 and co-wrote ‘Holiday Caravan Parks – Caring for the Environment’ which is now embodied in the Good Practice Guide on Planning for Tourism (2006).

His expertise extends further into the wider remit of rural regeneration, where he has been particularly involved with the heritage and landed estates sector in the restoration and re-use of redundant land and buildings. He was recently invited to Denmark to speak on his UK experiences.

Further information is available from www.ruralurbanplanning.co.uk

BHHPA Membership No. - NAM701

---

[1] British Holiday & Home Parks Association – The Holiday Parks national representative body

[2] UKTS – Visit Britain

[3] UK Holiday Parks – Economic Impact’, Peter Brett Associates LLP, January 2012

Lack of Development Leads to Double Dip Recession

Today's announcement that Britain is technically back in recession is not good news for anyone, least of all those hard pressed developers whose fault it all seems to be. The construction sector saw a collapse in output of 3% after a 0.2% fall in the last quarter.

Well, I wonder why that is? Perchance something to do with the monumental farce that is the revisions to the planning system! Not helped one iota by 'Prematurity Pickles' (who seems to be working counter-intuitively to the aims of the Government in causing development NOT to happen) and aided and abetted by the woeful inability of the financial institutions to stump up at realistic lending rates and without punitive repayment penalty clauses for their original mess in the first place. Go figure.

Anyway I think I have the mathematical equation that explains this situation:

Development Proposals 'P' (in £bn's) + NPPF - (Localism 'L' x N (where N is the unknown variable of Nimbyism) + Community Infrastructure Levy 'CIL' x U (the unreasonable expectations of councils)) / FA (where FA refers to bank lending) = double-dip-recession

Einstein, eat your heart out.

"Self Build if you want to.....And Not a Planner in Sight"

For those of you who do not regularly scan the pages of the Communities and Local Government website you may have missed this very useful statement on Self Building houses. I set out below the full article – with due credit to CLG - however, there are one or two fundamental issues arising from this statement which bear consideration. 

Firstly, the predicted rise (by 141% no less) in mortgage availability for self-build projects is marvellous, but 141 times a very low number is not that many in reality. Certainly the demand is there, but the banks are not handing money out that freely for secured mortgages, so the much more risky self-builder is going to need a lot of collateral and/or very deep pockets: especially as the average build price is apparently around £150,000. In my street well improved classic 1930’s 3-bed semi’s (the bedrock of UK housing stock) with decent gardens, garages and an established neighbourhood, are selling for less than that. Or, rather, they would be selling if people could secure sufficient funds from the mortgage lenders to afford to buy them.

We’ve all seen the ‘Grand Designs’ type programmes. I don’t think I’ve viewed an episode yet where the budget wasn’t blown sky high, financial crisis loomed and the house took three times longer to build than planned; and the occupants had to sell their first born to get the kitchen fitted. I exaggerate of course, and probably so too the TV companies for effect. But anyone of a DIY inclination knows that apparently simple, straightforward and well costed exercises can result in drama and more cost and a great deal of angst from 'her indoors' – or is that just me?

From a strategic standpoint I also doubt that this is really going to add significantly to the overall UK housing stock. Most self-build plots are either located on already allocated and consented housing sites, or are replacements for existing property. A good way to upgrade perhaps, and not to be discounted for all that, but it isn’t really adding significantly to the overall supply.

Wholly new, green-field planning permissions are rarer than hens teeth, for very obvious reasons. Most people want to put their self-build in a location that the planners do not. I am contacted regularly about building on plots of land in the green belt, or the countryside in general, and more commonly the request follows a rebuff from the local authority who –quite rightly – has applied normal policy considerations to the proposal.

There are ‘windfall’ sites out there and these are valuable additions to the pot. But the individual is often pitting his bank loan against local builders who may have greater buying power and are generally more adept at sniffing out the workable sites from those which appear sound, but have fatal flaws.

PUBLIC WARNING

And this brings me to a key issue. Back in the early 2000’s there were a spate of self-build deals involving parcels of land – often around London – where off-the-plan sales of plots was encouraged in return for delivering planning consent. They were all scams, and they’re back. I have recently been advising overseas lawyers on one such and their many clients parted with huge sums in return for a building plot - on an admittedly idyllic site - that wasn’t even owned by the company and was so constrained by planning policy, technical and environmental limitations that I couldn’t find a single aspect of the property that could even conceivably be considered in a positive light. Needless to say there was never any prospect of planning permission and their cash is long gone. You have been warned.

Interestingly the launch line-up of the great and good didn’t involve a planner. Perhaps because following the NPPF (see earlier blogs) planning is now so straightforward that really there is no need for such people, right?

A quick look at the newly launched Self Build Portal – ‘The Gateway to More Custom Build Homes’ – revealed the following in its ‘Red Tape’ section:

“You need planning permission if you are building a new home. You may well need it if you are renovating or extending. Planning matters are dealt with by your local authority planning department. There are fees”.

                                          

Succinct and to the point perhaps, but that simple phrase hides a whole mess of action right down to neighbourhood planning issues and the delights of ecological assessment. Legal stuff it may be, but planning permission is the biggest single hurdle you will face after raising the cash and to dismiss it as merely ‘red tape’ is to overlook just how important it is to the whole process.

Don’t get me wrong. I’d love to be one of those grand-designers, putting up my timber decked, New England style 5-bed detached, with triple garage, and stables in the adjoining paddock, enjoying uninhibited outlooks over the rolling Shropshire countryside, being just a short walk from that quaint old English pub serving real ale and Mrs Miggins pie shop selling freshly baked loaves, with the sound of the church bells wafting across the sunlit morning landscape as I exercise the spaniel to get the Sunday papers and a pint of unpasteurised milk, before the kids go off to the gymkhana. No. I would. Really I would. Call me an old fuddy duddy if you will but quite frankly this just ain’t going to happen in my lifetime – admittedly not that long now, but even so.

Topical Tips

As a self-builder you will have a lot to think about, but for goodness sake take time at an early stage to really check out the intended plot. You can search the planning history of the site online or in the council planning department records. Forensic planning I call it. If it has a history at all, read the officers reports and interrogate any submitted documents.

That rough old plot of land you have your eye on is likely as not to have gone and got itself some ecology. It may be a haven for lesser spotted, great crested, badger newts or some such, and that delightful, tinkly, little stream with the stickle-backs and the crack willows will doubtless be a major thoroughfare for otters and become a raging torrent that floods the site if it rains for more than 15 minutes in the hills 10 miles away. DO YOUR HOMEWORK.

'Read' the site. For example, if there is a wiggly worn path across the land it may just be an old cow track. Equally it could be the local wildlife motorway or even a public right of way. I did have to act once for a builder who unwittingly extended his lounge over an unmarked public footpath. All was OK, until the local ramblers association set up camp in his living room. If there’s a slope to the land, what is uphill that might end up down hill in due course. If there are bullrushes growing across the site it may just be a tad damp!

Never buy on the prospect of planning permission being granted – agree a deal subject to planning by all means but take entreaties of simple planning permissions with a very large pinch of salt. The bank is going to want to see a bit of paper with ‘granted’ on it as security in any event. And if permission has already been given, check and re-check the consent and any associated conditions. The latter could be just as costly to comply with as putting up the house in the first place. And don’t forget to satisfy those conditions before you start building. If you don't it could put a serious crimp in your day!

It’s always about the drains. Whatever you are attempting to do, consult the Environment Agency at an early stage on matters relating to foul and surface water drainage. If there is no mains connection you will need to deal with these matters very carefully. Just sticking in a septic tank or cesspool may not cut it.

I could go on. But you get the picture.

If you are thinking of self-building then have a look at the new self build portal [http://www.selfbuildportal.org.uk] and do take some advice. If you’re uncertain and want an initial desktop opinion of a potential location then see below for a low-cost planning audit.

In the meantime. ‘Dream on’ as they say…in the nicest possible way, of course!

Grant Shapps: Downing Street hosting the self-build boom

Published 19th April 2012

New help for self home builders launched at most famous address in the country.

A package of new support to give as many people as possible the opportunity to build their own homes was announced today at England's most famous address by Housing Minister Grant Shapps.

It comes as a new report predicts a 141 per cent rise in the mortgages available for those building their own homes over the next three years.

The Minister said that going down the self-build route was an affordable option for aspiring homeowners and shouldn't be seen as the preserve of those with deep pockets and grand designs.

A budget of £150,000 is adequate, in most instances, to get a three to four bedroom home built. The average cost of a ready-made home is now over £232,000.

Pledging to double the size of the self-build sector, Mr Shapps was joined by a glittering cast list of TV house-building experts at 10 Downing Street - assembled to offer advice to aspiring self builders on issues ranging from setting a budget and finding a site to practical tips on designing and building their own home.

A growing number of Britons are laying their own foundations with almost 14,000 new homes self-built last year - more than many individual volume housebuilders are building.

However, the self-builder's share of the market - one in ten of all new homes - is still very small by international standards.

Launching a package of measures today designed to turn this into a mass market opportunity, Mr Shapps said that for the first time, anyone wanting to don a hard hat and build their own home from scratch - whatever their budget - will have the help, advice and support they need to get started.

Help to get started

The pros on hand at the Downing Street reception today to offer advice included:

• Architecture Expert, Green Developer and Presenter of Grand Designs Kevin McCloud
• Architect, presenter and independent advisor to the Government on empty homes George Clarke
• TV builder and handyman Tommy Walsh
• Architecture expert Dan Cruickshank
• Writer and broadcaster on architecture Tom Dyckhoff
• Property expert and presenter Michael Holmes, and
• Architectural designer and sustainability expert Charlie Luxton.

Housing Minister Grant Shapps said:

"Last year, self-builders accounted for about 14,000 new homes in this country, more than many large commercial builders. Yet our self-build industry still lags behind much of the rest of the world, with the opportunity to build your own home seen as something only for a select few.

"That's why today, I'm pledging to back the self-build boom and support the industry to double in size over the next few years. As well as a new website giving help and advice, we're working hard to identify more land for development and have reformed the planning rules to stop people's aspirations getting tangled in red tape.

"This package of measures is designed to ensure anyone looking to build their own home gets the support they need and with the numbers of mortgages available set to rise by a massive 141 per cent, there's never been a better time for people to lay their own foundations."

Supporting a growing industry

Today's website is just one of a number of measures the industry is driving forward with the support of the Government. Today the National Self Build Association reported to Government on achievements since the launch of its Action Plan last year. In particular the report highlights:

• Improved access to finance - Better engagement with lenders, leading to a predicted 141 per cent rise in mortgage availability for people looking to build their own homes
• Making more land available - The Government is continuing to identify more surplus land for self build projects
• More builders offering self build housing - there is increasing interest from builders, developers, landowners and local authorities to support self home building across the country
• Cutting red tape - such as the new support for people wanting to build their own homes in the revised National Planning Policy Framework' and
• Access to better information - More information on prospective sites for projects is now available, and more accessible through the new web portal launched today.

Ted Stevens, the Chairman of the National Self Build Association (NaSBA) said:

"More than half the UK population would like to one day build their own homes, and around two million families are keen to get their projects off the ground in the very near future. The new self build portal will help them figure out what, realistically, they can afford to build; it will explain how their budgets can go further if they team up with other would-be self builders or do a portion of the work themselves, and it highlights the parts of the UK where it can be cheaper to find a site and construct a home.

"The site has lots of great examples, and is crammed with practical advice and tips. We have also worked hard to ensure the information is as authoritative and independent as possible, in may ways it's like a Which Guide to Self Build, so people using it can really rely on the information that's provided."

Kevin McCloud said:

"Self build is sometimes seen as a long, difficult and self-sacrificing process. But with the right planning, help and support it can be enjoyable and on collective schemes empowering. I believe we can become a nation of self builders. With the right support I believe we'd see more customised homes that reflect where they are, built to higher standards and to a better quality. We'd see people sharing skills and saving money. We'd see neighbours working together on community self build schemes and local construction economies thriving. And we'd certainly see more energy efficient buildings and a wider embracing of green technologies."

George Clarke said:

"Id like it to be made much easier for a new generation of younger people to get their self build projects off the ground. Few people realise that it is possible to build a very affordable, custom-designed home for quite a modest amount. And if young people team up with others, it's possible to make even bigger savings - perhaps reducing the cost of a new home by 30 per cent or more. So self build really can be a route to affordable housing. This new portal explains in depth how group self build schemes can be delivered and I'm sure it will help to increase the number of innovative low cost self build projects that are completed in the UK."

Kate Coutts and Alex White, both 30, are one of the would-be self build couples attending the Masterclass. Kate said:

"Currently it's really difficult to find good independent information about how to best get a self build project underway. We're currently renting, and are very keen on self build as a way of getting ourselves on the first step of the housing ladder. When we looked at the portal we found it very helpful - by checking out the interactive guide we've been able to get a much clearer idea of what we might be able to afford, and how to get the most from our limited budget. Before the portal there wasn't a good independent site with all the necessary information and guidelines. The site is really useful especially with so many links to external sites, contractors, etc, and it has hugely cut down the amount of time spent researching."

The link to this article is: http://www.communities.gov.uk/news/corporate/2132907

Desktop Planning Audit:

If you have your sights set on a plot of land or rebuilding opportunity for a self-build project why not have an initial planning audit undertaken so that you know whether it is worth proceeding.

www.ruralurbanplanning.co.uk is pleased to offer a low cost desktop service to provide the following:

• An overview and guide to the current town planning regime
• An initial assessment of the local planning framework for the proposed location
• An outline of and links to relevant planning policies and supplementary planning guidance
• Investigation of and comment upon the planning history of the site (if any) Summary report of planning issues and an opinion of prospects
• Checklist of further actions, investigations and next steps

• Full written report by a qualified and experienced Town Planner / Chartered Planning and Development Surveyor
• UK–wide coverage 

Just send us your name and contact details, together with any location plans, property particulars, grid reference or a Google Earth Lattitude/Longitude and a brief description of your intended development to: 

ianbutter@ruralurbanplanning.co.uk or the address on the website.

The Planning Audit costs £100 plus VAT

For more information go to:

http://www.ruralurbanplanning.co.uk/selfbuilderaudit.htm

It's Official - Premature Applications Are Now Confirmed

At the beginning of March I blogged about the apparent volte-face exhibited by the illustrious Eric Pickles MP in objecting to planning appeals on the grounds of any decision being premature pending adoption of emerging Core Strategies and the like.

http://theplannerman.blogspot.co.uk/2012/03/will-premature-objection-lead-to-poor.html

This self evidently flies in the face of a Government which has - up to now - positively strived to avoid any delay in getting Britain back into development mode ASAP and blamed the time consuming planning system and all its minions for all the ills of the world as a result.

However, despite previous decisions to the contrary, Mr Justice Beatson has now supported Mr Pickles stance in a case brought by Wainhomes; who sought to get Pickles’ dismissal of its planning appeal overturned for a 1,300-home project in St Austell.

The judge upheld the secretary of state's decision that the scheme would be premature, as it would detrimentally affect the Core Strategy in Cornwall contrary to the government's localism agenda.

The new National Planning Policy Framework (which sets out the localism agenda as far as I can see) makes it clear that in determining planning applications:

Local Plans are the key to delivering sustainable development that reflects the vision and aspirations of local communities. Planning decisions must be taken in accordance with the development plan unless material considerations indicate otherwise. ( para150)

The planning system is plan-led. Planning law requires that applications for planning permission must be determined in accordance with the development plan, unless material considerations indicate otherwise. This Framework is a material consideration in planning decisions. (196)

And there are a raft of other references about positive planning, giving weight to existing plans and so forth.

The point is, an adopted 'development plan' already exists in most places and is operational in determining applications right now. So what Pickles is really getting at in the NPPF is the following:

Planning law requires that applications for planning permission must be determined in accordance with the development plan [no, not the currently approved one, the one that's coming out some time in the foreseeable future, we hope, if seriously underfunded and understaffed local authority planning policy teams get their finger out and we don't have too much delay at public consultations and hearings and neighbourhood planning tea parties and every other damn thing that has to happen before a Core Strategy is adopted, finally, if there is no legal challenge], unless material considerations indicate otherwise. This Framework is a material consideration in planning decisions.

So throw all that NPPF nonsense out of the window then and apply the emergency brakes to potentially all and every type of development (prematurity is not just for Christmas it's until the LDF is approved), whilst we await the outcome of yet another round of development plan consultations and enquiries.

Brilliant. Just what we needed. Delay, delay and more delay.

Well Mr Cameron. You only have one person to blame now for planning delays and it ain't us planners. 

Tax Me if You Can – UK Home Tourism and Rural Britain on the Rack

Amidst all the hype of the Chancellors recent annual budget statement were a number of additional government proposals that didn't rate a mention at the dispatch box, but have appeared from the written word. One of these is potentially so damaging that it will (I have no doubt about this at all) impact very badly upon the UK tourism market, just at a time when the government is in dire need of us all spending more on holidays at home.

I speak here of none other than the imposition of value added tax (VAT) upon the humble static holiday caravan!

This isn’t about taxing those who book a week in a caravan (they’re being taxed to the hilt elsewhere) it’s about the 80% or so of all holiday caravans that are "owner-occupied". That is to say they are owned privately for holiday purposes. The government intends adding 20% VAT to the purchase price of a new one.

So what, I hear you saying? Now he’s whingeing on about the government fleecing all those tax-dodging, charity-giving rich people with second homes in the Dordogne access to the first class lounge at airports and downstairs toilets and all.

Nope. I'm talking about an industry worth £2.6billion (yes, billion) per annum to the exchequer (representing 12.3% of total UK tourism spending[1]), together with a bunch of hard-working people who choose to invest in a holiday caravan so that they can vacation in this country, with their family, on a regular basis, year after year, making their tourism contribution to the national economy in exactly the way this government desires.

And thank goodness for them, because this peculiarly British form of holiday-taking is second only to hotels in the tourist accommodation stakes and generates about 74 million bednights per annum; mostly in rural areas.

Holiday caravan parks are extraordinarily valuable to their local economies too, generating 7-8 times the tourism revenue per trip than a day visitor. In many places they are the ONLY form of holiday accommodation to be had and they sustain much of rural Britain through their revenue and job generation in a way that could not be delivered by other types of development; even if that were achievable in planning and development terms in the first place.

The knock-on benefits from holiday parks are considerable, with their revenues sustaining a raft of local shops, services and associated businesses that support the holiday park operation throughout the year. Some parks even host the local shop and the pub, facilities that would otherwise have been lost altogether. Many of the larger parks with swimming pools and activity facilities make these available to their local community as well as holidaymakers. And let’s not forget that holiday parks pay considerable sums in business rates and employ lots of local people too.

True. Owner-occupied caravans are purchased for personal use, but when they're not using their caravan themselves, more often than not the caravan owner has contracted with the Park operator to rent their caravan out as part of the wider tourism offer on the Park. This is encouraged in order to help sustain the holiday park and its facilities, whilst providing commercial certainty at the start of each year with a known level of annual pitch fee income. If nothing else this business format reduces the risk of bad weather deterring UK holiday-taking decisions at the last minute, which has become a very evident and commercially damaging feature of our home market.

The issue is this. Money to make discretionary spending of this kind is hard enough to come by at the best of times, let alone in the midst of a world recession. Adding 20% in this economic climate is likely to tip the balance between making that investment or keeping the cash in the bank and spending it elsewhere; i.e. on overseas holidays.

The imposition of VAT on static caravans could literally Tax people away from taking holidays in this country and that is not a good thing.

The initial impact will be on caravan sales, which of course knocks-on directly into our caravan manufacturing industry. Employment and revenues in that sector will immediately be affected. That knocks-on further into such things as steel production and the wide range of ancillary businesses, from fittings to fire blankets.

People thinking of upgrading and renewing their caravan will be discouraged (or at best delayed) and this will begin to affect the quality of the park. Perceptions in tourism are everything and maintaining high standards is key. Park operators unable to support their business through caravan sales will have less to re-invest and cannot sustain pitch fees that reflect their investment. Slowly but surely a spiral of decline will commence that could be very hard to recover from. We've seen the same thing in other industries over the years and lessons just don’t seem to have been learnt.  

The other real worry is that this very traditional and UK-centric market is not immune to being attracted away by other opportunities. 

The government really cannot afford to let a highly valuable tourism asset wither away for want of short-term tax revenues that are unlikely to cover a fraction of the potential loss in jobs and revenue that will be occasioned by this action.

I know this industry well and have argued long and hard over 30 years to keep it alive in the interests of both the UK and particularly our rural economies. I may be biased, but I know what can and will happen if this apparently slight change in stance is allowed to proceed.

The industry body the British Holiday and Home Parks Association (BHHPA) are preparing their response. www.bhhpa.org.uk

There has been much promotion of "staycations" and encouragement to support UK plc by taking a break in this country; much to the disappointment of U.K.'s budget airline industry perhaps, but anyway. I blogged about the Governments new Tourism Policy last March (2011)

[http://theplannerman.blogspot.co.uk/2011/03/government-launches-new-tourism.html]

[1] Figures from BHHPA and NCC

New Planning Guidance for Traveller Sites

Amidst all the fuss and bother over the launch of the National Planning Policy Framework (NPPF) last week, the Government also published new guidance for traveller sites on the same day. Hiding bad news perchance?

Anyway, this document sets out the Government’s new planning policy and should be read in conjunction with the National Planning Policy Framework.

The Government’s overarching aim is to ensure fair and equal treatment for travellers, in a way that facilitates the traditional and nomadic way of life of travellers while respecting the interests of the settled community. The inclusion of facilities for travellers should be included in any emerging Local Plans.

Some of the key points are as follows:

“Local planning authorities should set pitch targets for gypsies and travellers and plot targets for travelling show people which address the likely permanent and transit site accommodation needs of travellers in their area, working collaboratively with neighbouring local planning authorities”.

“When assessing the suitability of sites in rural or semi-rural settings, local planning authorities should ensure that the scale of such sites does not dominate the nearest settled community”.

“If there is a lack of affordable land to meet local traveller needs, local planning authorities in rural areas, where viable and practical, should consider allocating and releasing sites solely for affordable traveller sites, including using a rural exception site policy for traveller sites that should also be used to manage applications. A rural exception site policy enables small sites to be used, specifically for affordable traveller sites, in small rural communities, that would not normally be used for traveller sites”.

“Inappropriate development is harmful to the Green Belt and should not be approved, except in very special circumstances. Traveller sites (temporary or permanent) in the Green Belt are inappropriate development”.

“Local planning authorities should strictly limit new traveller site development in open countryside that is away from existing settlements or outside areas allocated in the development plan. Local planning authorities should ensure that sites in rural areas respect the scale of, and do not dominate the nearest settled community, and avoid placing an undue pressure on the local infrastructure”.

The document can be accessed here:

http://www.communities.gov.uk/documents/planningandbuilding/pdf/2113371.pdf

THE NPPF – Tourism & Leisure Development

I have considered the broad principles of the NPPF in my BLOG at:

http://theplannerman.blogspot.co.uk/2012/04/national-planning-policy-framework-10.html 

Although the Framework should be read as a whole, I now consider the document in a more specific manner related to various subject areas. I look here at issues related to tourism and leisure development.

The full NPPF document can be found at the link below. The numbers in brackets refer to the relevant paragraph in the NPPF.

The biggest single benefit that the NPPF delivers is that (to date) it has NOT revoked the “Good Practice Guide on Planning for Tourism” published in 2006. This does not appear in the schedule of now defunct policy guidance documents in Annex 3 to the Framework. As such it remains active as material planning guidance for all kinds of tourism and leisure development.

TOURISM

Often referred to in the same breath in planning policy text tourism and leisure are distinct elements, even though there can be substantial cross-cut in development terms. The NPPF refers to tourism only three times in the document; once in relation to town centres, once in relation to the rural economy and lastly within the definition of main town centre uses.

Starting with the latter a main town centre use includes:

Main town centre uses: Retail development (including warehouse clubs and factory outlet centres); leisure, entertainment facilities the more intensive sport and recreation uses (including cinemas, restaurants, drive-through restaurants, bars and pubs, night-clubs, casinos, health and fitness centres, indoor bowling centres, and bingo halls); offices; and arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities).

The importance of this is that the focus in the NPPF is upon a ‘town centre first’ approach, with sequential testing of main town centre uses. Paragraph 24 states:

Local planning authorities should apply a sequential test to planning applications for main town centre uses that are not in an existing centre and are not in accordance with an up-to-date Local Plan. They should require applications for main town centre uses to be located in town centres, then in edge of centre locations and only if suitable sites are not available should out of centre sites be considered. When considering edge of centre and out of centre proposals, preference should be given to accessible sites that are well connected to the town centre. Applicants and local planning authorities should demonstrate flexibility on issues such as format and scale.

So, a proposal for a new hotel for example will clearly need to fulfill this sequential requirement. But what of a proposal for an extension to an existing hotel that is not in the town centre? Depending upon the scale of the proposal perhaps, there may be an argument to suggest that the applicant will need to provide a sequential test to demonstrate that the additional bedspaces/facilities could not be provided closer in to the centre. The phrase “…only if suitable sites are not available…” gives credence to this proposition.

Paragraph 25 goes on:

This sequential approach should not be applied to applications for small scale rural offices or other small scale rural development.  (25)

Helpful perhaps for those schemes in rural areas (but unhelpful as there is no reference to any thresholds defining what ‘small scale’ might be). Paragraph 26 does refer to a default threshold of 2,500 sq m (some 27,000 sq ft) but this depends upon whether local thresholds have already been set in existing Local Plans.

This is something to watch out for in forthcoming Local Plans because authorities may set ludicrously low thresholds as a means of excluding development potential.

Much of our tourism industry is located beyond the confines of settlements in the countryside and the NPPF deals with tourism development in its rural policy paragraph 28 which notes:

To promote a strong rural economy, local and neighbourhood plans should: (inter alia)

• support sustainable rural tourism and leisure developments that benefit businesses in rural areas, communities and visitors, and which respect the character of the countryside. This should include supporting the provision and expansion of tourist and visitor facilities in appropriate locations where identified needs are not met by existing facilities in rural service centres; (28)

Here again sustainable rural tourism goes undefined but is assumed to coincide with the wider aspirations of the NPPF in paragraph 14 that establish the presumption in favour of sustainable development. Essentially development that accords with the development plan (Local Plan etc) should be approved. It is essential therefore that one engages with the plan making process at an early stage to ensure your particular tourism business and any future proposals are taken account of in the adopted plan.

LEISURE

The provision of leisure facilities is to be treated as a strategic priority for which authorities are required to establish specific policies (156).

Here again leisure development is absorbed within the definition of a main town centre uses and there are relaxations for development in rural areas in the same way as for tourism proposals.

As far as ensuring the vitality of town centres is concerned the NPPF requires that:

In drawing up Local Plans, local planning authorities should: (inter alia)

• allocate a range of suitable sites to meet the scale and type of retail, leisure, commercial, office, tourism, cultural, community and residential development needed in town centres. It is important that needs for retail, leisure, office and other main town centre uses are met in full and are not compromised by limited site availability. Local planning authorities should therefore undertake an assessment of the need to expand town centres to ensure a sufficient supply of suitable sites; (23)

This requirement of the NPPF places the burden upon the authority to assess need and make suitable provision through a supply of suitable sites allocated in the Local Plan. The word ‘suitable’ is important as not just any old land allocation will suffice. You should therefore ensure that the authority is acquainted with your leisure sector and its development needs so that it can take proper account of future requirements in the Plan.

As noted above, in the absence of any particular local thresholds, a default position of 2,500 sq m is set as a trigger for requiring impact assessments. (26)

The overall aim of the Framework is to encourage sustainable development and this includes reducing the need to travel.

Planning policies should aim for a balance of land uses within their area so that people can be encouraged to minimise journey lengths for employment, shopping, leisure, education and other activities. (37)

This reinforces the ‘town centres first’ approach where transport links and accessibility are assumed to be at their greatest.  

SUMMARY

Even reduced to 49 pages the Framework contains a network of inter-related policy statements, all of which have some bearing upon any particular proposal and I can do no more than highlight some of the key issues.

The bigger issue will be ensuring engagement at the local level. You have to be active in the Plan-Making process, or risk finding that once the Plan is formalized and adopted there may be no room for maneuver, however pro-active the Framework might like to appear.

I've been here before however during the 1990’s; appearing at over 40 Local Plan Inquiries and making written representations for many more. My most recent appearance was in relation to the Isle of Wight Core Strategy, where the Inspector accepted my submissions and made significant beneficial alterations to the finally adopted Plan. This has ensured that significant sectors of the tourism and leisure industry now have scope to achieve future planning approvals, from a potential position of stagnation and limitation.

If you require further information in relation to the NPPF and its implications for your business then please contact me at:

ianbutter@ruralurbanplanning.co.uk 

www.ruralurbanplanning.co.uk 

The full NPPF document can be found at:

http://www.communities.gov.uk/documents/planningandbuilding/pdf/2116950.pdf