March 2021
Planet Purbeck stands with anyone who is ready to take action to protect and improve the community, landscape and wildlife here on the unique Purbeck peninsula.
Planet Purbeck is a movement that gathers together individuals, groups and organisations who understand that climate change and loss of biodiversity jeopardise everything we hold dear – and want to do something about it.
In January 2021, Planet Purbeck submitted a strong collective response to the Climate and Ecological Emergency Strategy and Action Plan (C&EE) published by Dorset Council. In that response, Planet Purbeck offered support to the Council in shaping and implementing the Strategy and Action Plan. Planet Purbeck expressed its wish to be both a friendly critic and a creative partner with Dorset Council, particularly on those parts of the initiative which relate to action by the citizens and the civil organisations and local authorities of the county.
The Dorset Local Plan (DLP)
Planet Purbeck regard the Dorset Local Plan as a powerful tool for promoting the well-being of the people, the economy and the environment of the county. Crucially, the DLP and the active planning process that it embodies, can and should be used by the Council to pursue many of the purposes and actions set out in the Climate and Ecological Emergency Strategy and Action Plan.
Planet Purbeck shares and endorses the questions the Dorset Climate Action Network has raised concerning the DLP, namely:
1. Are the DLP proposals consistent with the overarching need to prioritise addressing the Climate and Ecological Emergencies, in order:
2. Will the proposals ensure the health and wellbeing of all residents by guaranteeing :
4. Will the Plan empower communities by devolving decision-making to the lowest possible levels in the community ?
Planet Purbeck agrees strongly that climate change and threats to our fragile environment should be major factors in drafting a plan and are pleased to see this initial emphasis in part 1.3 of the DLP.
However, Planet Purbeck express concern that the DLP does not reflect a genuine acceptance of or response to the Climate and Ecological Crisis (C&EE) declared by Dorset Council.
Planet Purbeck argues that the DLP consultation period and procedure is wholly inadequate for the range of issues raised. Planet Purbeck is concerned that there has been no wide consultation on the Statement of Community Involvement, and no early consultation on an “Issues and Options” stage.
There has been a notable lack of public engagement with the DLP. The only genuine public engagement has been provided through four People’s Assemblies. Planet Purbeck argue that Dorset Council should have facilitated opportunities for virtual public engagement events at which residents could have genuine engagement with the Council with live Q&A sessions.
Unfortunately the webinars offered no capacity to interact other than by questions sent in before the presentation and were selected by the presenters. To respond required participants to commit hours of time reading the extensive documentation and considerable further time to negotiate any of the response options.
The DLP documentation is extensive and although well laid out, is many and multi layered, with a wide range of issues covered. Maps included are not always easily readable, either online or as paper copies. Response to the plan is a time consuming undertaking and Planet Purbeck argue that the short consultation period at a time of pandemic and full lockdown is wholly inadequate.
The online response process has proved to be faulty, with no working ‘save’ button to allow for staged inputting and links were broken, leading to frustration and disengagement. There were only limited hard copies of the DLP documentation available in Libraries, disenfranchising a considerable number of Dorset residents..
As referenced above, the Ecological and Climate Emergency receives little attention in the overall plan, with the exception of the Environment Section, where good words are largely undermined by the planned actions in the Development Sections. Planet Purbeck argues that the Dorset Ecological Network (existing and potential) Maps should be added to the ‘main environmental constraints’ map at Figure 1.2. Note that this map needs to be improved to make it more visible and readable. The spatial allocation for Nature Recovery land use should be made implicit at the same time as land-use for housing and workspace, in line with the Dasgupta Review and the Prime Minister’s commitment to protect 30% of UK land for biodiversity by 2030.
Planet Purbeck fully endorses the priority identified by Dorset Climate Action Network for the addition of a third strategic priority in the Housing section viz:
“Contribution to combat Climate Change and to strengthen biodiversity. We will work to ensure that all new housing is energy-efficient, designed to be carbon negative so that it is compatible with the imperative to eliminate net greenhouse gas emissions, to ensure resilience in the face of climate change and to produce net gain in biodiversity.”
Paragraph 1.1.6 in the draft plan contends that all former district plans were reviewed by the new Dorset Council. Planet Purbeck asks whether that review was undertaken with the declaration of a Climate and Ecological Emergency in mind? Planet Purbeck cannot find any further information about this ‘review’ in the DLP document. Planet Purbeck seeks to ascertain who carried out this review work. Where are the reports about this? What has been deemed relevant and not relevant? Where is the transparency in this process?
Planet Purbeck argues that there is an urgent need for a rethink of the Plan to reflect the need for genuine sustainable development within the Dorset. The vision embedded in the current document does not adequately steer the County towards a low carbon future of energy efficient housing, ‘green economic development’ or carbon free energy generation and use. The current plan appears as a collection of the old district plans drawn up before the above priorities and ‘stitched’ together.
Planet Purbeck is concerned that the proposal included in the DLP fail to adequately appreciate or protect the unique environment of Dorset.
The plan is predicated on land being available for 39,000 dwellings, so that unmet needs from neighbouring authorities can be met. It is important that this 'unmet' need is quantified. In Dorset Council area there were (April 2020) over 4000 empty houses and a further 5200 in the BCP area. It would be good to see if and how these could be brought into use. The heavy focus on building despite the potential cost to the climate and environmental crises is a cause of concern.
The DLP gives insufficient consideration to repurposing existing vacant buildings. The premise of the plan seems to only count a home as ‘new’ if it is being newly built. Re-using existing buildings and underused housing is by far the most environmentally sustainable way to deliver more housing capacity. The impact of Covid19 on our town centres will have a long lasting influence, and human behaviour will have changed irreversibly, meaning many public service buildings are likely to be sold in the coming months and years. Diverting resources and attention into large green field developments will make meeting these emerging issues even more difficult. The plan should offer radical options to meet future housing needs, especially for the young and elderly residents, in a sustainable and effective way using our current built environment wherever possible.
The plan speaks of the creation of 21,000 new jobs and 30,000 new homes by the year 2038. It is not clear where these jobs might come from. Employers already note a lack of local young recruits as young people are forced out of the area by high house prices and low salaries.
Specifically Planet Purbeck fears that much of the building in the next few years would be completed with out-dated technologies. The new Building Regulations requiring high standards of environmental performance will not come into force until 2025. The Plan should insist on the highest standards of quality, sustainability and energy-efficiency in the design of all new buildings.
The DLP acknowledges that house builders may challenge the demands of new technologies. Planet Purbeck would want to see the DLP place stronger emphasis on the reduction of carbon emissions and house builders’ intentions in this regard. Dorset Council’s commitment to carbon neutrality should be made obvious.
Planet Purbeck argues for immediate proposals to adopt green energy technology. The Plan holds that sustained growth must not come at the expense of the environment – Planet Purbeck wishes to understand more clearly how Dorset Council is preparing to achieve this balance. The DLP needs to be based on a strategy or roadmap to achieve net zero greenhouse gas emissions by 2050, as required by Section 1 of the Climate Change Act 2008, as amended in 2019, and include intermediate targets of a 50% and 75% reduction by 2030 and 2040 respectively.
The decision to construct the 39,000 houses in Dorset is essentially subjugated to Housing Targets provided by the Central Government Standard Method. However the DLP offers no evidence to justify this adherence to national Housing Targets. It also offers no update to reflect societal and population changes in Dorset post Covid, post Brexit and in relation to the climate and ecological emergency. These changes are either ignored or inadequately addressed. A recent news article published in both The Guardian and The Independent (8/3/21) quoting figures from the ONS, reported that approximately a million people have left the UK since following the pandemic and as an unforeseen consequence of UK’s exit from the EU. Planet Purbeck considers this good cause for a revision of the central government housing targets, which should then be reflected in reduced targets for the Dorset area. The DLP needs a coherent, optimistic and inspirational vision where housing is based on local need rather than generalised National Housing Targets.
Ref Paragraph 2.2.3 – 2.2.8, Planet Purbeck argues that the plan should address and decline to accept the housing targets provided by the Standard Method which is out of date and independent estimates suggest are grossly in excess of the actual local need. The Government response below (December 2020, to the local housing need proposals in the “Changes to the current Planning System”) and the National Planning Policy Framework (NPPF) guidelines indicate how this can be done:
“Within the current planning system the standard method does not present a ‘target’ in plan-making, but instead provides a starting point for determining the level of need for the area, and it is only after consideration of this, alongside what constraints areas face, such as the Green Belt, and the land that is actually available for development, that the decision on how many homes should be planned for is made. It does not override other planning policies, including the protections set out in Paragraph 11b of the NPPF or our strong protections for the Green Belt. It is for local authorities to determine precisely how many homes to plan for and where those homes are most appropriately located. In doing this they should take into account their local circumstances and constraints.”
Dorset is a very special county, as comments in the introduction of the plan concede. Many areas in Dorset are precluded from development and tourism plays a large part in our economy. There is thus a need to protect landscapes, habitats, heritage and wildlife. Planet Purbeck is concerned that theThe DLP undermines all this with default urbanisation of significant areas. Planet purbeck argues that what is needed is a robust defence of Dorset’s smaller housing needs (probably around 20,000, as suggested by other assessments - distributed where needed) and an equally robust vision for a low carbon Dorset, offering a beacon of sustainable agriculture, fisheries, industry, transport and tourism. The DLP is really “business as usual” with marginal only concessions to the climate and ecological emergency.
If the housing numbers were reduced to the actual need then they could be dispersed amongst areas where Neighbourhood Plans would indicate suitable numbers and location. Any subsequent shortfall could be addressed by construction of new communities where infrastructure could be created as needed, with climate and environmental concerns given adequate consideration.
Possibly the only concessions to this should be allocations of land adjacent to existing settlements dedicated to providing social and genuinely affordable housing that the current plan with its reliance on developer-led, market-led housing will simply not provide. The current plan will, despite all the housing allocations, fail to provide the housing most needed in the county. Dorset will have many more houses bought by those retiring into the area, commuting from the area, acquiring second homes and investing to let and yet still leave many families living in inadequate accommodation, with its raft of associated costs in health, support and education - with no reduction in carbon emissions.
There is also a focus on large developments adjacent to existing towns or large villages. This ignores the needs of smaller villages, frequently noted in their Neighbourhood Plans, which need provision for local ‘low cost’ housing needs and to maintain their existing infrastructure and services.
Neighbourhood Plans were prepared in the belief that all subsequent planning applications would have to conform to them. Planet Purbeck understand that they are now to “sit alongside” the Local Plan. Planet Purbeck note that Neighbourhood Plans cannot offer to build fewer houses than the Dorset Local Plan requires. More weight needs to be given to local perceptions, knowledge and opinions contained in Neighbourhood Plans.
The Neighbourhood Plans would be a better placed to indicate the local requirement. A major residential development should consult the local Public Health Officer to establish the needs of the less able in the neighbourhood, rather than adopt the arbitrary figures contained within the DLP.
The mix of homes to meet the needs of the elderly and less mobile could be expanded to include alternative living arrangements, such as group living or co-housing; alternatives that can also address wellbeing and health objectives. We are after all in an epidemic of loneliness (1.3.20).
There is inadequate vision within the DLP to address the need for social and genuinely affordable housing. The Government’s definition of affordable at 80% of market rate does not make housing affordable with the low incomes in the county where the average house price is 10 – 14 times the average annual income. ‘Low cost’ housing, to rent or buy, is a preferable term to use to describe the genuinely affordable housing needed by many local individuals and families.
Reliance on developer-led and market-led provision is highly unlikely, in fact many planning experts would maintain impossible, to supply low cost housing. It is the cost of the land that has prevented genuinely affordable homes being built in Dorset and undermines the progress of community led housing projects such as Community Land Trust and Ecological Land Coperatives and other community led housing projects to move forward.
Without adequate planning controls developers will promise too little low cost housing and probably renege on those planned claiming they make the development financially ‘unviable’. Only the imposition of planning controls will force down the price of land sufficiently for any developer to provide sufficient ‘low cost’ housing. Developers should not be allowed to appeal against supply of affordable housing on ‘viability grounds’ which essentially means they paid too much for the land. If the developer cannot supply as promised on acquiring planning consent then the consent should be withdrawn. This stance would ensure developers pay realistic sums for the land.
Other planning controls are needed to ensure that developments are constructed appropriately achieving low carbon construction and zero carbon operation.
Consideration should be given to building not-for-profit ‘low cost’ housing on Council owned land and to persuading landowners to provide lower cost land at certain sites to provide for local needs.
Affordable rent should be defined as a multiple of the hourly minimum wage.
Affordable homes are consistently much smaller and built to a lower standard than other parts of the development. This policy should require affordable housing to be built to the same type, size and mix as the remainder of the site.
This issue is a challenge but one which Neighbourhood Plans have addressed successfully for new builds in Cornwall and Devon. A policy of Rural Exception Sites dedicated to providing only ‘low cost’ housing would provide accommodation for local families in areas of high demand for second homes.
It should be recognised that ‘second homes’ means both second homes and holiday lets.
Second homes have driven local house prices up, which in turn has inflated prices of homes in the rental market; making homes unaffordable for local people on average incomes to rent. Many people are thus living in poverty, without secure tenancies and can be given two months notice to move by a private landlord.
There should be controls of second homes in Dorset given that the County has such disparity between high property prices and low incomes.
Second homes not only inflate house prices but also create ‘ghost villages’ where a significant proportion of the houses are not lived in for substantial periods of the year having a negative effect on the community.
Planet Purbeck is concerned that the plan will facilitate the creation of more second homes in Purbeck. Planet Purbeck would want all new-builds to be available only to those who work locally or will have the property as their principal residence - qualifications to be protected by covenant. In winter some villages show few lights - Planet Purbeck wishes to see a return to viable vibrant communities.
Planet Purbeck look by way of example to the ruling of the High Court judge at a judicial review in Cornwall, when developers challenged the St Ives’ Principal Residency Policy. The High Court ruled to support the use of the Principle Residency Policy, with the judge referencing the NPPF (Sustainable Development) guidance and concluding that “To do nothing would lead to unsustainable development.” It follows that if Dorset Council does nothing to control the second Homes issue, it will lead to unsustainable development and the Council would be acting in direct contradiction with the overarching aims of their own Plan. NPPF states that "sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs."
The recommendation of Planet Purbeck is that Dorset Council should adopt a Principle Residency Policy similar to that of St Ives. The restriction of buying new homes to being used exclusively for permanent residential use and not for Second Homes and Holiday lets, is vital. Planet Purbeck argue that it should be implemented across the whole plan area to prevent the issue moving to the areas where there are no controls
It is true that a Principle Residency Policy on its own does not control all second homes; that is why a 2-pronged approach is needed; Principle Residency Policy (for new homes) and further substantially higher taxation which will require the council to lobby central government.
There is an assumption that economic growth will be provided from existing and expanded ‘Employment Sites’. Planet Purbeck argues that this is 20th century thinking and therefore outdated. Employment now is becoming far more diverse, being based at home or in small units. Planet Purbeck would be interested to see evidence of existing usage data at the business parks already established in Dorset.
The plan tends to focus on business parks, which in turn skews housing planning. Planet Purbeck do not agree with the concept of creating business parks, believing them to be out of tune with modern working practices and a post-pandemic workforce. Dorset requires ventures developing all aspects of green energy. Post Covid, more people will want to work from home – more data will be needed about this new economy.
Planet Purbeck is concerned about the struggles of town centres. Planet Purbeck wish to see proposals regarding the increasing number of commercial buildings and shops that stand empty over long periods, seeing these as potentially windfall or brownfield sites.
Locating businesses in town centres brings considerable benefits as employees of one business become customers of other enterprises. It creates business-to-business opportunities, promotes innovation and facilitates the creation of mutual support networks. By contrast, edge of town business sites tend to have few local facilities and can promote the use of cars for travel to work and travel by car to out of town shopping centres for after-work shopping and socialising with colleagues. This idea does not chime with the community based, small town nature of our county.
The DLP states that “Transport is the biggest carbon-emitting sector in Dorset” but then fails to address this issue. The aim should be to reduce automobile use, rather than to avoid “significant additional” trips. The current, inadequate ambition is one example of a general failure in the DLP to recognise the severity of the climate emergency. The Dorset Local Plan should be complemented by a Transport Strategy to drive delivery of more sustainable solutions. Planet Purbeck argues that Dorset needs a more comprehensive, strategic plan for a public-transport network to mitigate the climate emergency by radically reducing dependence on private vehicles; to enable employment and learning and training opportunities for young people; economic advantages for shops, pubs and restaurants; and to enable key-workers.
The roll out of electric vehicles requires adequate charging points in public areas. Consideration should be given to the payment arrangements for the service – the current plethora of companies and particular payment methods makes moving around a challenge of planning when compared to refuelling by credit card at carbon fuel centres.
Electric cars are not carbon or materials free in production or maintenance. Personal transport needs to be provided more readily by public transport and active transport. Greater provision for these is also a priority.
Planet Purbeck is in broad support of the principle of allocating all of the areas for wind turbines.
The need for decarbonising Dorset’s energy requirements cannot be met only by onshore wind turbines or PV arrays. Both can play a part but land is much needed in Dorset for farming, amenity, health and wellbeing, landscape, biodiversity and the important tourism industry. Priority thus needs to be also given to reducing energy consumption by improving buildings, reducing travel, decarbonising agriculture , etc.
Offshore wind farms are barely mentioned in the plan; yet a Poole Bay wind farm 10-20km offshore could provide all the electricity for the households of Dorset and BCP at lower cost than new fossil fuel or nuclear generation. With increasing burden on power supply to charge electric vehicles and heat homes and an increasing awareness of the need to decarbonise, developments such as that in Poole Bay should be welcomed.
The World Heritage coast and its fossil record would not be greatly impacted by an offshore wind farm 10-20 miles from the coast. The view of the wind farm, far from adversely affecting enjoyment, would give many residents, especially the younger generation, hope for the future.
The plan for substantial offshore wind generation off the coast of Dorset and BCP areas needs to be revisited now the Climate Emergency has been more widely recognised. It could generate the quantities of energy required.
Dorset council has to have at the forefront of its revised Local Plan the needs of the Climate and Ecological Emergency. The current offering merely makes vague statements and will affect little change in the activities or behaviour of its citizens or those who act on the Dorset environment. It really is a document supporting ‘business as usual’ with just a few concessions to the Council’s own C&EE Strategy.
The carbon footprint of the developments indicated by the plan grossly outweigh any planned reductions.
The review of NPPF guidelines and Building Regulations needs to be undertaken with the Climate and Ecological Emergency leading the changes. Until this happens no further development should acquire planning permission and, if possible, current permissions reviewed.
East Dorset has the highest number of workers commuting by car or van – 79.5%. Dorset’s roads are frequently congested and Planet Purbeck oppose adding to the quantity of carbon emissions. The DLP needs an integrated transport plan to link all Dorset communities, avoid unnecessary private car journeys, promote public transport and encourage walking and cycling.
Sites for Nature Recovery and Ecological Networks should be allocated at the same priority as land allocated for housing and jobs. Ecological Networks and sites designated for their biodiversity and Nature Recovery should be included on all the Plan ‘Proposal Maps’.
Whilst the Dorset Local Plan has policies for renewable energy, it says nothing about fossil fuel developments. The DLP needs to include a strategic policy statement opposing the further development of hydrocarbon resources which is then detailed in any new Minerals Plan. The proposed extensions of Wytch Farm and drilling in Puddletown are incompatible with Dorset’s aim of carbon zero.
Planet Purbeck "Stronger Together"
