HOLIDAY HOUSES AND SUSTAINABLE COMMUNITIES IN SOUTH LAKELAND - A case for change
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HOLIDAY HOUSES AND SUSTAINABLE
COMMUNITIES IN SOUTH LAKELAND
A case for change
Holiday Houses
Holiday Houses and Sustainable Communities in South
Lakeland
‘People should not be prevented from buying second homes but we believe there
is merit in ... exploring options that may make the process either less attractive
for the second home owner or more beneficial for the rural community or both.
To reflect local circumstances implementing such options must be at the
discretion of the local authority.’
Discussion on second homes in House of Commons Environment, Food and Rural Affairs Committee Sixth Report
of Session 2013 - 14
Sustainable local communities form the heart of our countryside. Demographic and
economic shifts have, over the years, substantially changed the nature of many of these
communities, creating new pressures. Local authorities have a responsibility to support the
conditions that will enable these communities to thrive in the future.
There are many reasons for change in rural communities. It is ironic that one factor, their
attractiveness and quality of life, contributes towards a threat to future sustainability. It is
widely acknowledged that excessive levels of holiday houses and second home ownership
have the potential to undermine sustainability of rural settlements, by exacerbating some of
the social, economic and service delivery challenges that they face. This is not simply about
affordable housing, although that forms one component of the issues raised by non-
permanent residency. Rather, it is about ensuring that we retain socio-economic balance
within our communities
While we welcome the
introduction of measures by
Government that are
intended to assist in
supporting rural
communities, it is our belief
that the existing levers are
insufficient to enabling
partners to work together to
ensure the ongoing
sustainability of some of our
rural villages and towns as
vibrant social and economic
A former miners’ row in Coniston – now nearly all holiday houses communities. We are
therefore seeking to apply
an additional use class for holiday houses that can be used to target areas where this type
of property use is damaging community sustainability. Although this will not, in itself, solve
all the challenges that rural areas face, it could help some of our communities that have yet
to reach the ‘tipping point’, to retain their socio-economic balance.
Holiday Houses 1
The remainder of this paper outlines the rationale for, and aims of, our proposal. More
detailed information on the subjects under discussion can also be found in the Annexes to
the paper, which cover:
• An overview of the secondary evidence;
• A proposed impact model of holiday houses in rural communities;
• Case studies of three areas in the District;
• Consideration of the current levers available under the Localism Act; and
• A discussion of implementation issues.
Rural Change and Holiday Houses
The challenges facing rural communities have been well rehearsed. These include:
An ageing population;
Lack of affordable housing for young and low paid workers;
Reductions in locally provided services and amenities;
Restricted employment opportunities; and
Public transport disadvantages.
These challenges are recognised by
Government through the
acknowledged need to ‘rural proof’1
policies in order to ameliorate these
problems, for example the need to
travel for health services, or higher
housing and fuel costs. Annex A
summarises the secondary evidence
that impact on our concerns.
However, despite the best policy
efforts, there are additional factors
that can negatively impact on the
capacity for communities to sustain
themselves.
A significant factor is the impact of
second or ‘holiday houses’ that are
not use as a home, or year-round
residence. These occasionally
occupied properties leave ‘dark gaps’
in communities, especially outside
the main tourism season, leaving a Retail impact
rump population of year-round
residents with restricted opportunities.
1
https://www.gov.uk/rural-proofing-guidance
Holiday Houses 2
Year-round home:
Is a home, occupied continuously by the same household;
Has occupants who are reliant upon local services and amenities such as the local
doctor, dentist, local shops, post office, school, garage, hairdresser, library or pubs;
and
Where household members are in employment, this is highly likely to be within daily
commuting distance, or they may work from home
Holiday house:
Is not occupied continuously by the same household; there may be frequent
occasions when the dwelling house is unoccupied, in some instances over extended
periods of time; or it may be occupied by a large number of 'households' for short
periods of time for holiday purposes;
The occupiers are not reliant on all of the local services — they do not use some
services at all, and use other services to a lesser extent. For example, occupiers are
unlikely to be registered at the local doctor or dentist, children do not attend the
local nursery or school, and they are unlikely to use a local garage to have their car
serviced. They use local shops, post office, pubs and other services and facilities less
frequently than if it were their sole or main residence (their home); and
Unless the dwelling house is being occupied specifically by a person who needs to be
resident away from their sole or main residence due to their employment — any
place of work is likely to be beyond a daily commutable distance.
Drawn from Lake District NPA submission
Clearly, these differences impact on the local demand for services, and the capacity for local
resilience, for example through the development of volunteer-run services. Annex B
describes a model of the types of impact that arise from a prevalence of holiday houses.
This problem was acknowledged in The Taylor Review (2008), where the affordability issue
and 'sustainability trap' of communities in rural areas was investigated. This review brought
forward a series of recommendations, one of which was the suggestion that a change in
planning legislation could be implemented to give local councils greater control over second
homes - the suggestion was that this should initially be trialled in a National Park Authority
where second home concentrations are acknowledged to be at their highest2. The
Government's response to the review dismissed this as an option, suggesting a number of
alternative mechanisms for delivering affordable housing, which are (as will be seen in the
rest of this submission) flawed for a number of reasons.
2
Recommendation 21: The Government should examine the options for trialling planning rules limiting change
of use of full time homes to part time occupation (as second homes or holiday lets), in one or more of the
National Parks.
Holiday Houses 3
The Local Picture
South Lakeland District is situated in one of the most beautiful parts of England, with part of
the District falling within the Lake District National Park, and including the Arnside and
Silverdale Area of Outstanding Natural Beauty. The District’s natural advantages draw
visitors from all around the world, and contribute to a vibrant tourism economy, which has
recently led to a growth of 33% of tourists using self-catering accommodation3, although
the economic benefit of tourism to the District has dropped overall.
The importance of tourism to the District cannot be underestimated, and the provision of
holiday accommodation, both serviced and non-serviced, plays an important role in
sustaining the local economy. However, there is a need to ensure that the development of
facilities targeted on tourists do not undermine the very communities that sustain the local
environment – on official figures (which are reckoned to be an underestimate) 33% of
parishes in the National Park have more than 20% of their housing stock used as holiday
houses.
Ensuring the integrity of the National Park requires a balanced view of development,
accommodating both the needs of sustainable communities and protected landscapes. For
this reason, the National Park Authority has required all new housing development in the
Park (which is limited for environmental reasons) to be affordable for local needs.
The rural communities of South Lakeland face the same pressures as other areas of
England. To this has to be added the additional pressure of high levels of holiday houses.
In the 2011 Census, the District had the third highest proportion of people with second
addresses for holiday purposes in England (45 per 1,000 residents)4. Six of the 45 Wards in
the District have over 20% of their housing stock with no usual residents, with the highest
(Ambleside & Grasmere) having 37.5%.
In turn, this affects house prices. The average house price in the Central Lakes area is
£317,458, while the average household income is £31,207, making the income: house price
ratio 10.17. The equivalent figure for Cumbria as a whole is 5.445.
As the next section will illustrate, these
changes are contributing to major demographic
shifts in our communities, with young families
leaving, to be replaced by an ageing year-
round population in communities where a
significant proportion of available housing is
not occupied on a year-round basis.
3
SLDC STEAM Report Summary 2012.
4
http://www.ons.gov.uk/ons/rel/census/2011-census/second-address-estimates-for-local-authorities-in-england-
and-wales/stb-census-2011-second-addresses-in-e-w.html#tab-Holiday-second-addresses
5
https://www.gov.uk/government/uploads/system/uploads/.../table577.xls
Holiday Houses 4
This has a number of implications, for example:
More residents will require additional care to stay at home. This is more difficult to
provide if care workers cannot live locally;
The volunteer base for local activities is ageing, leading to less activity, in turn
affecting social cohesion. For example Coniston, which still maintains a thriving civil
society, is increasingly reliant on an older group of volunteers, leading to a reduction
in some local activity; and
The maintenance of local services will become more problematic, as a smaller year
round group of residents will not create sufficient demand to justify provision.
It is difficult to assess exactly where the ‘tipping point’ is, since, as the case studies show,
micro experience is affected by a range of local factors. However, where holiday houses
represent less than 10% of housing stock, there appears to be limited impact. Once the
level goes over 20%, however, changes occur. Interestingly, this was the limit introduced as
a result of a 2012 referendum in Switzerland6, although the effects of the implementation of
this rule have yet to be seen.
The impact of this on individual localities is explored in the following section.
Localities in Focus
To illustrate the effect on local communities, it is helpful to look at the ways in which three
of our communities are changing. These settlements are:
1. Elterwater and Grasmere;
2. Coniston; and
3. Crosthwaite.
These three areas have been chosen as they represent communities at various stages,
where holiday houses:
1. Have become the dominant property form.
2. Are becoming increasingly significant.
3. Have a presence, but have yet to have a major influence.
Summaries of each community, and available data, are provided at Annex C.
The most striking factor arising from an analysis of the case study areas is that of
demographic change. For example, in Coniston, young families appear to have been leaving
the area, leading to an overall population drop, with the only group showing an increase
being the over 60s. In Crosthwaite, however, the picture is more nuanced, with some
overall population growth, but decreases in the socially and economically important 20-44
age group.
6
http://www.ft.com/cms/s/2/f47fc9fe-6d09-11e1-ab1a-00144feab49a.html#axzz2rzJDbkF9
Holiday Houses 5
While it is not possible to attribute all of these changes to holiday houses, there is clearly
some correlation between housing affordability and these changes, and the relative
proportion of holiday houses in a community have an impact on this.
The price of property is a significant issue. For example, there are currently three properties
for sale in Elterwater with a 4 bedroom detached home marketed at £770,000, a 3 bedroom
detached home at £750,000 and a two bedroom apartment at £345,000, all of which are
currently used as holiday lets. Current properties for sale in Grasmere include a one
bedroom traditional Lakeland cottage for sale at £335,000 and a two bedroom mid-terrace
at £350,000. Again both of these properties are currently holiday lets. While 15 affordable
local needs homes were recently completed in Grasmere, the level of demand for these
properties illustrates the scale of the challenge with local stakeholders suggesting that there
were more than 100 applicants for each of these properties. Similar examples can be given
for Coniston, and the high house prices in Crosthwaite clearly are not affordable to residents
on an average income.
There is also evidence from a neighbouring community where holiday home owners exerted
influence over local planning consultation to oppose the development of new affordable
homes on the grounds that it affected their amenity benefits. This type of fragmentation
has a negative impact on community life, with the potential to create division. The
community in question is also facing difficulties in maintaining the local community hall, the
future of which is coming under question.
The message over local civic society also shows
a direction of travel. Clearly, the tradition of
local rural activism means that there are strong
organisations that aim to support the local
community. Coniston, in particular, supports a
wide range of activities, although even there,
some organisations have found it difficult to
continue. However, the impact of an ageing
population is making itself felt, with some activities recently stopped, and additional
pressure being put on a declining number of activists.
For example, in Elterwater there are long term vacancies for local community positions
including the Parish Council and Board of Governors at the local school. In Grasmere the
declining and ageing local regular resident population means that the community struggles
to fill community service roles that require younger active citizens or people of working age,
such as driving the community bus or managing the local post office.
The impacts on one of the case study communities, Coniston, are summarised in the figure
overleaf. Again, many of these are symptomatic of the conditions in many rural areas, but it
is clear that holiday houses play some role in affecting the sustainability of local
communities, that require some redress.
Holiday Houses 6
Community Change in Coniston
Coniston is, on the face of it, a vibrant community with a strong civil society, represented by
a wide range of voluntary groups with in excess of 100 volunteers participating in activities
ranging from infrastructure services, such as the retained Fire Service, to a wide range of
social and sporting activities. It has an active Parish Council, and Community Land Trust.
The village has a wide range of shops catering to local needs, including a long established
local co-operative food store, and a petrol station. There are also other local businesses,
including a brewery attached to a local pub. It is a tourism centre in the Lake District, with
two youth hostels, a community-run tourism information centre, and hosts the Ruskin
Museum.
Is there an issue? According to the 2011 Census, 35.1% of houses in the Coniston and
Crake Valley Ward had no usual residents, and local knowledge suggests that the proportion
within the village itself is much higher.
This manifests itself in the community in four significant ways:
Housing: House prices are high in the village, with the average price of the 12
houses sold in 2013 being £308,167. This represents 13 times the average income
in South Lakelands District. A recent survey by the Community Land Trust identified
43 households in ‘housing need’, with the majority of those affected being young
people living with their parents;
Population: The population of the area has decreased by 15% since the 2001
Census. This overall figure disguises major structural changes, with a rise (17%) in
over 60 year olds, and major decreases in the under 15s (-48%) and 30-44 (-41%)
age groups. The socially and economically crucial young families are therefore being
hollowed out from the local community;
Economy: A successful local economy needs local spend to support it. Over 2001-11
there was a 12% reduction in people in employment, with the major declines
being in the higher earning Professional and lower earning Process and Elementary
occupational groups. The economically active population is being squeezed at both
ends, with fewer high spending professionals and fewer individuals servicing the
tourism economy; and
Services: The local primary school is only using 53% of its capacity, as a result
of the decline in numbers of young people, and there are planned significant
reductions in the NHS resources being put into the local general practitioner surgery,
again as a result of demographic shifts.
If these trends continue, the Coniston community will look significantly different over the
coming years, with few young people, a weakened economy, and a consequent impact on
service provision. This will not only affect the year-round population, but could also have an
impact on the service and employment infrastructure and consequent attractiveness of the
area to tourism.
Holiday Houses 7
Existing Levers
It is important to recognise that the issues outlined within this paper are acknowledged by
policymakers and legislators. However, it is our belief that the existing levers available are
insufficient to proactively and effectively ensure the sustainability of rural communities.
The Localism Act introduced a number of mechanisms designed to introduce rights and
powers into local communities, some of which have been aimed at solving the affordable
housing crisis and the impact on sustainable communities in rural areas. There are many
strengths within these approaches, but also limitations, which create a need for the
additional planning regulation that we are seeking.
These levers include:
Community Right to Buy;
Neighbourhood Planning;
Community Right to Build;
Local Planning Policy; and
Community land Trusts.
Annex D to this document summarises the roles of these levers, and argues why, in
themselves, they are not enough to address this pressing issue.
Our Proposal
There are real community impacts as identified in the Case Studies and
other evidence (i.e. it is not just a case of 'local feelings');
Current tools are not so far proving effective in dealing with the issue (i.e.
CLTs, Community Right to Build, NDPs and Localism);
Only specific control in certain areas, through Article 4 directions, is
sought. Not a wholesale 'ban' on second homes; and
There is no retrospective change sought, so the legitimate rights of
existing second home owners would not be affected.
To rely on the existing mechanisms instigated by the Localism Act, and other mechanisms
through the planning system, means relying on strong local communities to put together
bids, write complicated planning documents, apply for grants, give a huge amount of time
and effort. The Catch 22 scenario here is that many local communities are becoming
fragmented as a result of the high levels of second homes, and resulting loss of facilities,
availability of housing, and other impacts.
Therefore, the reliance on local communities to solve the problems created by large
numbers of holiday houses through Community Land Trusts, Community Right to Bid,
Neighbourhood Development Plans has its limitations.
Holiday Houses 8
Where these communities do exist and work together, they can still not stem the continuing loss of properties to the second home market. There is no mechanism available either in planning terms, or outside the planning system, to control this loss. The only available mechanism available to local communities and to the Local Planning Authorities, to manage the affordable housing crisis, is to build more homes. In a protected area, such as the Lake District National Park, there is a lack of sites available, and although some new affordable homes are built every year, these are equivalent to the number of properties lost to the second home market. The problem is not being solved, and the countryside that is protected through the designated status of the National Park is under pressure for more housing leading to the resultant environmental impacts. These environmental impacts will be felt all around the country, due to the fact that the very beauty of an area is what leads it to become popular for second homes. The government is intending, in April 2014, to introduce a new permitted development right which will allow the Change of Use of agricultural buildings to residential use. This offers the opportunity to boost the supply of housing in rural areas (although National Parks have requested an exemption from these PD rights). However, again, there is no control over the properties being sold as second homes as soon as they are built, as they will be dealt with through the Prior Notification procedure, rather than the normal planning application process. This could mean losing the chance of gaining more dwellings for local people in rural areas where these properties are sold off for non permanent residential use. The inset over summarises the planning implications of our proposed approach. In addition, Annex E provides details of the ways in which planning approaches have been used in the context of Houses in Multiple Occupation We fully recognise that there are many issues facing rural communities, all of which have the potential to impact on the quality of life for which rural areas in general, and the Lake District in particular, are renowned. However, we consider that there is sufficient evidence to point to the fact that, in certain communities and under certain conditions, holiday houses can have a negative impact on communities. This requires a mechanism through which that can be an additional level of control of this type of property use. We believe that the introduction of new use class to be used in fragile areas affected by holiday houses would be a significant tool to promote local sustainability, and strongly urge that this be adopted. ‘In most rural towns and villages, community has always been more important than the state.’ The Rural Challenge: Achieving sustainable rural communities for the 21st century Rural Coalition 2010 Holiday Houses 9
Planning Implications
A new Use Class would not be retrospective, and therefore would not penalise existing
second home owners and holiday let properties. The proposal would be to have an
additional use class (C5). The Local Authority would then have the flexibility to address the
second home ownership situation only in those areas where the tipping point has been
reached, or is about to be reached through an Article 4 direction restricting permitted
change of use between C3 and C5.
This has proved to be very effective in the case of the recently introduced C4 class for
Houses in Multiple Occupation. This has proved to be a flexible and fair way of dealing with
the issues associated with HMOs, some of which are not dissimilar to the types of issues
with regard to second homes. It has enabled Councils to apply specific Article 4 directions in
areas where there is an imbalance in communities between C3 and C4 housing.
Article 4 directions can be very flexible, and can apply to very specific areas. If the extra
use class were to be introduced, it would benefit other communities around the country who
suffer specific problems as a result of high level second home ownership. The result would
be to:
Stop the continuing loss of existing residential properties which cannot be prevented
by any of the other mechanisms discussed in this paper;
Potentially redress the balance of second home/full time occupancy (where
properties for sale as second homes change the use back to residential) to more
sustainable levels;
Simplify the system and provide certainty to occupiers and buyers of houses as to
what Use Class a property is;
Allow flexibility for Local Planning Authorities and Local Communities to bring in
Article 4 directions where there is a particularly high level of second home ownership
and where there is evidence that this is detrimental to community sustainability;
Reduce the likelihood of a 'two tier' housing system as suggested in this paper;
Allow more flexibility in planning policy for new housing developments, as there is
potential for a different level of control meaning that the stringent affordable housing
policy could be relaxed over a longer time frame to the economic benefit of
communities; and
Reduce pressure on Local Planning Authorities to change policy to allow current
holiday use homes to become residential, where this may not be appropriate for
amenity reasons.
Holiday Houses 10Holiday Houses 11
Annex A Secondary Evidence Overview
Contents
1. Research Evidence
1.1 Academic and Independent Research
1.1.1 Summary
1.1.2 Second Homes in Northern Ireland: Growth, impacts and policy implications (2008)
by C. Paris, Ulster University
1.1.3 York University: The Impact of Empty, Second and Holiday Homes on the
Sustainability of Rural Communities (2005)
1.1.4 Joseph Rowntree Association - "A minimum income standard for rural areas"
(November 2010)
1.1.5 England National Parks Association Policy Statement on Affordable Housing
1.2 Central Government Funded Research
1.2.1 Summary
1.2.2 Taylor Review of Rural Economy and Affordable Housing (2008)
1.2.3 The Government Response to the Taylor Review of Rural Economy and Affordable
Housing (March 2009)
1.2.4 The Rural Challenge: Achieving Sustainable Rural Communities for the 21st Century,
published in (August 2010) by The Rural Coalition
1.2.5 State of the Countryside Report - Commission for Rural Communities (2010)
1.2.6 The Town and Country Planning Association Report "A Vision for Rural England" (2010)
1.2.7 The National Housing Strategy (2011)
1.2.8 DEFRA - Guide to Rural Proofing - National Guidelines (July 2013)
2. Precedent in terms of previous changes to Use Classes Order
2.1 Circular 08/2010
2.2 House of Commons Library, Social Policy Section "Houses in multiple occupation &
the Use Classes Order Standard Note SN/SP/5414 by Wendy Wilson - 30 December
2013
2.3 Other recent changes
3. Planning Policy - Statutory Planning Documents
3.1 National Planning Policy
3.1.1 National Planning Policy Framework
3.2 Local Planning Policy
3.2.1 South Lakeland District Council (SLDC) - Core Strategy (2010)
3.2.2 Lake District National Park - Core Strategy (2010)
3.2.3 Upper Eden Neighbourhood Development Plan (March 2013)
3.2.4 Other Neighbourhood Development Plans
3.2.5 Community Right to Build Orders
3.2.6 Community Land Trusts4. Non-Statutory Plans and Documents in the Study Area 4.1 The South Lakeland District Council Plan (2014 - 2019) 4.2 Strategic Housing Land Availability Assessment (2011) 4.3 The Cumbria Housing Strategy and Investment Plan 2011 – 2015 (October 2010) 4.4 Lake District National Park Authority Management Plan (2010 - 2015)
1. Research Evidence 1.1 Academic and Independent Research 1.1.1 Summary There have been a number of documents published in recent years by central government and other bodies with an interest in rural issues. There is a general consensus that there are costs and benefits to holiday homes. The costs to local communities in terms of reducing the availability of housing are well documented in the research. There have been relatively few recent research projects looking at hard evidence on a Case Study basis. The most recent notable examples are work carried out in 2008 in Northern Ireland, and in North Devon (Exeter University) in 2011. There was also a significant amount of work done by York University on a the impact of second homes in Scotland in 2005. The Rowntree Foundation commissioned research on the extra costs of living in rural areas, and the National Parks Association has a Planning Position Statement on affordable housing which provides useful statistics and insight into the specific affordable housing issues affecting National Parks. 1.1.2 Second Homes in Northern Ireland: Growth, impacts and policy implications (2008) by C. Paris, Ulster University This study concluded that there are benefits and costs to holiday homes. The main issue it recognised, was that those areas that are restricted in development potential (i.e. National Parks), have a far more significant issue than those areas which do not, as there is less potential to mitigate the lack of affordable housing through housing schemes specific to those needs without compromise the quality of the environment. Clearly in National Parks, it is difficult to bring sites forward due to the nature of the area, and so addressing the affordability crisis through the provision of new housing is not as easy. The conclusions at the end of the document summarise recommendations, one of which was in relation to the impact of second homes on the physical and social character of the area, affordability, and implications for planning and housing policy. (It is worth bearing in mind that Northern Ireland has, over many years, had far less restrictive housing policy than England). The document concludes: "...planning cannot stop dwellings being used as second homes and tighter restrictions increase the likelihood of existing dwellings becoming used as second homes. The only possible planning recommendation relating to residents’ concerns are how best to manage development related to second homes and other demand factors. The implications for housing policy are that, combined with factors, growing second home ownership increases problems of affordability and access, especially for low income households and first time buyers." Clearly in England there are very tight restrictions on new building in National Parks, and therefore the pressure on existing housing stock is significant. Secondary Evidence Overview A.1
The document also usefully provides suggested wording for different use class types within
the second homes category, recognising that the impacts of a second home (where the
dwelling can sit empty for a number of months in a year) can be different to those of
'holiday homes' which are likely to occupied throughout most of the year, but by different
people.
1.1.3 York University: The Impact of Empty, Second and Holiday Homes on the
Sustainability of Rural Communities - A Literature Review (2005)
This document offers an extremely comprehensive review of literature on the top of second
homes, affordable housing, and associated impacts in rural area. The reports key findings
however, assert that there are potential costs and benefits to second homes in communities,
and that a one-size-fits-all approach would be flawed.
It states:
"Evidence drawing on how policy might respond highlights that the extent and impact of
second home ownership varies across locations. Therefore a national policy response to
second home ownership is not appropriate. Recent research suggests support from local
authorities for greater powers in respect of second homes. However planning controls are
not perceived as the most appropriate mechanism, rather, fiscal measures are thought to
offer a more valuable approach as they can be more sensitively applied in local contexts."
This may be true, but the proposal to introduce a new class would also offer a mechanism
for sensitive control in local contexts, which has been shown to work well in recent changes
to the GPDO Use Classes Order introducing a class for Houses in Multiple Occupation (see
later).
1.1.4 'A minimum income standard for rural areas' by the Joseph Rowntree Association
(November 2010)
This study found that families in rural areas need earnings well in excess of the minimum
wage to afford the necessities of life. Yet low pay is more common in rural than in urban
areas, creating a double disadvantage. As a consequence, while the visible swathes of
poverty in some UK cities are not evident in rural areas, the worst-off rural families are likely
to have an income well below a socially acceptable minimum, even if they have jobs.
The study concludes:
• The biggest difference is the greater access to public transport in urban areas,
whereas rural households depend more on cars. Domestic fuel costs are also higher
in some rural areas, because of older, less fuel efficient housing and lack of mains
gas;
Single, working-age adults need to earn at least £15,600 a year in rural towns,
£17,900 in villages and £18,600 in hamlets or remote countryside to reach a
minimum living standard, compared with £14,400 in urban areas;
• For couples with two children, the annual earnings requirement is much higher,
about £33,000 to £42,000, depending on whether one or both partners work and the
remoteness of the community;
Secondary Evidence Overview A.2• Among those on basic out-of-work benefits in rural areas, single people get only
about a third of the required minimum, families with children about a half, and
pensioners are typically 20 per cent short of the minimum;
• Therefore, people in rural areas generally need to work and earn well above the
minimum wage to make ends meet. But since many rural jobs are poorly paid, many
people have substantially less than they need, even if they work.
Key findings: People in rural areas typically need to spend 10–20 per cent more on everyday
requirements than those in urban areas. The more remote the area, the greater these
additional costs. The cost burden is greater on families.
The study did not go on to look at affordable housing, but the higher income to price ratio
of housing but it can be assumed that in the Lake District National Park and some areas of
South Lakeland can only exacerbate the problem.
1.1.5 England National Parks Association Policy Statement on Affordable Housing
According to ENPAA’s policy statement on affordable housing in the Lake District, 18% of all
houses are either second or holiday homes. But figures for the National Parks as a whole
can hide wide variations within them. In Coniston Parish in the Lake District the figure is
43%7. Data can be patchy and often under-estimates the total number of household
dwellings. The document estimates the average figures of second home ownership in other
National Parks: 15% in the Yorkshire Dales and Exmoor; 14% in Northumberland -
although Beadnell, a settlement on the Northumberland Coast AONB has an estimated 52.9
% second home ownership8; 12% in the North York Moors - (however, Robin Hood's Bay
has an estimated 50% second home ownership9); 4% in the Peak District; 3% in Dartmoor
and 2% in the New Forest (figures have been rounded).
For each of these National Park areas (and indeed in many AONBs) there will be individual
examples of settlements with much a much higher percentage of second home ownership
than the 'average', either in the National Park or the County area.
The position statement identifies a number of barriers to achieving affordable housing in
National Parks. On top of the reduction in housing stock as a result of second homes, the
planning controls, and lack of available land at the subsidised level needed to for housing
association projects, means that land does not come forward at the rate it can elsewhere.
The various barriers are identified:
a lack of housing finance, especially for smaller local housing associations,
traditionally with finance being skewed to the larger projects available within urban
areas;
shortage of sites for housing – not necessarily because of planning restrictions but
because land owners can be unwilling to provide at values that are required to
ensure affordability. In Yorkshire, for example, the Housing Corporation have a
7
This figure is claimed to be higher by Coniston parish - nearer 50%
8
Beadnell Parish Plan December 2007
9
Do second homes kill a community? By BBC Radio York's Fay Yeomans
Secondary Evidence Overview A.3£5,000 per unit cap on exception sites. They feel this is a suitable level to ensure
schemes are affordable, yet the majority of landowners are unwilling to sell their
land for this price. The means sites are not coming forward for affordable housing
development;
assessing Needs – there is a reliance on rural housing enablers – who are mainly
non-core, temporary funded posts;
there continues to be a lack of consistency of approach in assessing housing needs
at parish levels;
S106 Agreements – can be over complicated and problems exist in ensuring they
robustly provide affordability in perpetuity;
perpetuity is a key issue, as is ensuring the engagement of mortgage lenders. NPAs
can establish legal agreements regarding the need to keep a house affordable ‘in
perpetuity’ but many lenders insist on a mortgagee in possession clause so that it
can be sold on the open market if the owners default. It is hoped that the arrival of
Community Land Trusts may help here;
NPAs can face strong local opposition to social housing – in part because it
represents new development, and partly because of underlying assumptions that
social problems will follow. Ensuring high quality design can help, but this remains a
challenge;
extension to the right to buy in rural settlements has added to the challenges; and
there is a shortage of public land and former industrial buildings suitable for
affordable housing, and even this is shrinking.
Evidence from the Lake District National Park confirms a number of these conclusions.
1.2 Central Government Funded Research
1.2.1 Summary
This section looks at the various pieces of research that have been undertaken by the
government through both administrations, commencing with the Taylor Review in 2008,
where the affordability issue and 'sustainability trap' of communities in rural areas was
investigated. This review brought forward a series of recommendations, one of which was
the suggestion that a change in planning legislation could be implemented to give local
councils greater control over second homes - the suggestion was that this should initially be
trialled in a National Park Authority where second home concentrations are acknowledged to
be at their highest. The government's response to the review dismissed this as an option,
suggesting a number of alternative mechanisms for delivering affordable housing, which are
(as is argued in Annex D) flawed for a number of reasons.
There then followed a number of other studies and reports by various bodies, (some of
which no longer exist) documenting the affordable housing crisis in rural areas, and looking
for solutions to this. The Town and Country Planning Document - A Vision for Rural England
- recognised that the current set of tools available to planners and policy makers to address
the housing affordability crisis have not been successful.
Secondary Evidence Overview A.4Most recently, parliamentary debates have re-opened the issue of second home ownership, and the recommendations made in the original Taylor Review, and the final document in this section (The House of Commons Environment and Rural Affairs Committee debate) clearly shows a change in favour of trialling the recommendation (21) from the Taylor Review. 1.2.2 Taylor Review of Rural Economy and Affordable Housing (2008) The Taylor Review of Rural Economy and Affordable Housing (2008) was published prior to the NPPF, and contained a series of recommendations on updating the (then) PPS documents, particularly those related to housing and the rural environment. The results of this document will have fed into the NPPF, and the NPPF, although not adopting all recommendations outlined in the Taylor Review, does reflect many of the findings of this document. The Taylor Review states in paragraph 11: "The planning system has a crucial role to promote and deliver sustainable communities - ensuring development occurs in the right place at the right time and makes a positive contribution to people's lives - providing homes, jobs, opportunity and enhancing quality of life. It must simultaneously protect and enhance the natural and historic environment, and conserve the countryside and open spaces that are important to everyone." It is this balance, of providing for local communities, whilst conserving the designated countryside that makes planning for affordable housing particularly difficult in National Parks and to some extent, other nationally designated areas. This document was important in providing useful research data on what hinders growth of sustainable and vibrant communities. Paragraphs 97 to 112 provide a useful summary of the issues related to second homes/holiday homes which were identified in this document. The paragraphs finish with a recommendation to government: Recommendation 21: The Government should examine the options for trialling planning rules limiting change of use of full time homes to part time occupation (as second homes or holiday lets), in one or more of the National Parks. The document suggested in paragraph 112, that National Parks are particularly vulnerable to lack of affordable housing, since there is little option to make up the loss of full time homes by new building (compared to areas outside the National Park), and the maintenance of the beauty and landscape of the National Parks relies on people living locally doing jobs which are related to the maintenance of the landscape (such as farming) which tend to be lower paid jobs. Secondary Evidence Overview A.5
1.2.3 The Government Response to the Taylor Review of Rural Economy and Affordable
Housing (March 2009)
With regard to a response to recommendation 21, the Government stated:
"The [Taylor] Review thought the Government should examine the options, possibly with a
trial “in one or more of the communities most affected”, for changes in secondary planning
legislation to limit changes of use for full-time homes to be used instead for holiday lets, or
as second homes. The Review was particularly thinking of the National Parks, and
acknowledges the “real issues of practicality”. We well understand that the issue arouses
strong feelings, for and against, but are not persuaded that the ‘problem’, such as it is,
could be tackled effectively through the planning system, for the reasons given in the body
of this response. We think that there are more innovative ways of providing the affordable
homes rural communities need without interfering with the legitimate rights of second home
owners."
1.2.4 The Rural Challenge: Achieving Sustainable Rural Communities for the 21st Century,
August 2010 (Rural Coalition)
Following on from the Matthew Taylor Review, The Rural Coalition (a group comprising 15
member organisations from a wide range of backgrounds, including the RTPI, T&CPA, NFU,
HBF, CPRE, LCA to name a few) called for action on a number of key propositions:
• Creating and maintaining sustainable rural communities;
• Meeting the affordable housing needs of rural communities;
• Building thriving rural communities;
• Delivering great local services;
• Flourishing market towns; and
• Empowering communities.
The first two key propositions are related to issues affecting rural housing and there are
various key findings in relation to how these issues could be addressed. The
recommendations differ little from previous recommendations and can be summarised
chiefly as:
1. Creating and maintaining sustainable rural communities through guidance and support
from national and local spatial plans, and through genuine collaboration and engagement
with local communities.
2. Meeting the affordable housing needs of rural communities by augmenting existing
mechanisms and through other mechanisms such as the 'Community Right to Build', more
options for affordable housing, incentives for landowners and more freedom for local
authorities to manage their housing finances.
Clearly, in a National Park, the set of issues reaches beyond those that affect rural areas as
a whole due to limitations on building due to the inherent constraints of being in a protected
area. These particular issues are not addressed in this document and the focus is on rural
Secondary Evidence Overview A.6areas as a whole. What this report does show, is a consensus from a wide range of national bodies, from a wide range of backgrounds, that rural issues need attention. 1.2.5 State of the Countryside Report - Commission for Rural Communities - 2010 The now disbanded Commission for Rural Communities produced regular 'State of the Countryside Report' documents, the last one being produced in 2010. A number of other updates were produced, one of which was the State of the Countryside Uplands Report, which contains useful data on house prices and affordability in upland and rural areas in England. 1.2.6 The Town and Country Planning Association Report "A Vision for Rural England" 2010 Following the Taylor Review, the Town and Country Planning Association presented a paper called "A Vision for Rural England". This paper identified a number of issues related to sustainable communities from being a reality in rural areas. It re-enforced the need for 'rural proofing' of government policy and the recommendations contained in The Rural Challenge report (see 1.2.5). It identified 5 key areas of concern, the first of which was related to rural housing availability and affordability. It outlines a number of questions which it sees as key for effective 'rural proofing'. The first two are related to housing issues: "How do we meet the immediate needs of many rural people for affordable homes, well paid jobs, and access to services? These are familiar problems which have developed over many decades, partly as a consequence of planning and housing policies. The national policy response is also familiar, with a rhetoric in favour of a ‘living, working countryside’. But the delivery of this policy has largely failed. A new Rural Coalition was set up in 2009 under the chairmanship of Lord Matthew Taylor to show how successful implementation could be achieved. It published The Rural Challenge in 2010, and the TCPA – as one of the founder members of the Rural Coalition – supports its recommendations." However, as stated previously, some of the recommendations , won't work in practice, in part for many of the reasons outlined in the ENPA's Position Statement on affordable housing, which presents the most sophisticated analysis of the real 'on the ground' issues faced by Local Planning Authorities seeking to further affordable housing provision in National Park areas. 1.2.7 The Government's National Housing Strategy (Nov 2011) This document seeks to increase the supply of new homes across the country, to address housing shortage issues. Clearly the government consider the lack of housing for local people to be a significant issue affecting the country, yet there are no mechanisms in place to control use of existing residential properties. Secondary Evidence Overview A.7
1.2.8 DEFRA - Guide to Rural Proofing - National Guidelines (July 2013) The DEFRA document 'A Guide to Rural Proofing' gives advice on methodology for 'rural proofing' proposed policies designed to improve rural areas. The flow chart on page 8 of the document gives guidance on how to 'rural proof' policy aspirations, and the table on page 9 gives more detailed guidance, with the suggestion that statistical data contained in the 'Statistical Digest of Rural England' be used.10 There is local statistical data which can be used for the National Park, and this, with the specific data from the Case Studies, provides a suitably 'rural proofed' proposal. 1.2.10 Cambridge Centre for Planning and Housing Research - Rural Housing at a Time of Economic Change (May 2012) This piece of research was commissioned by the Commission for Rural Communities before its final closure in March 2013. The conclusion of the report states: "Overall, the current economic climate and policy reforms present a challenging set of circumstances to those providing or seeking housing in rural areas. Providing housing in rural areas has always encountered additional difficulties associated with planning restrictions and high costs of housing, whilst for those seeking affordable housing the shortage of available homes, resulting from the sparseness of housing, remains an issue. The Localism Act and latest planning reforms seek to give more power to local areas to determine their own priorities. It remains to be seen whether these powers will enable rural areas to improve the housing situations of residents." Key Findings: That there are two dimensions to the housing issue in rural areas - affordability and availability. Some hope rests on 'localism' and planning reforms associated with that solving the problem. High levels of second home ownership impact on both affordability and availability. 1.2.11 House of Commons Environment, Food and Rural Affairs Committee - Rural Communities - Sixth Report of Session 2013–14 The outcome of the Taylor Review and the recommendations to look into changes to the Use Classes Order were raised in the Sixth Report of Session of the House of Commons Environment, Food and Rural Affairs Committee, (Rural Communities). Among other issues affecting rural communities, Volume I of this report contains the recent debate with regard to the second homes issue, which is included as a topic in its own right. The discussions from paragraph 155 to 159 outline the debate which has been appended to this document in Annex A. It was recognised within the debate, that "second home ownership does add demonstrably to the housing crisis in rural areas" (paragraph 155). In paragraph 156 the debate recognised the specific problems faces by National Parks, stating: 10 It is considered that the data in that document does not distinguish between National Parks and other rural areas, therefore the information is not that helpful as evidence to contribute to rural proofing from a housing perspective. It is felt that other evidence held by the Local Planning Authorities would provide a more useful base against which to 'rural proof' the aspiration for a change to the Use Class Order Secondary Evidence Overview A.8
"The impact of second homes differs across the country. There is high demand for second homes in most National Parks where securing homes for local people employed in lower paid jobs is a problem, one that is particularly acute in the Lake District and Yorkshire Dales..." The debate contained some discussion over the merits of introducing another Use Class within the residential use class as follows: "158. Both Matthew Taylor’s report and Elinor Goodman’s before that suggested using planning use categories to address the problem of second homes in rural communities. Graham Biggs and Neil Sinden agreed that this option is worth exploring though, as Mr Sinden pointed out, using Use Class Orders “is not without its problems and it does need to be very carefully explored, but certainly it is something that is worth looking at”. Suggestions made that other mechanisms within the planning system would be sufficient to control the situation are flawed. Community Right to Build Orders have not been taken up by any communities in the Lake District, and this does not, in any event, prevent the gradual increase in second home ownership of existing properties which are currently in full residential use. The report concluded, within the section on second homes: "High concentrations of second homes can have a negative impact on rural communities. They add to the shortage of housing, push up prices and their owners often add little to the local economy and community." The final recommendation is outlined as follows: People should not be prevented from buying second homes but we believe there is merit in the RCPU exploring options that may make the process either less attractive for the second home owner or more beneficial for the rural community or both. To reflect local circumstances implementing such options must be at the discretion of the local authority. A Change to the Use Classes Order which meant that planning permission would only be needed in areas with an Article 4 direction would give Local Authorities control at a macro level - i.e. address localised problems. A pilot study of this in operation would be a way of 'carefully exploring' the option. Secondary Evidence Overview A.9
2. Precedent in terms of previous changes to Use Classes Order
2.1 Summary
This section looks at documents related to the recent changes to the Use Classes Order
which were introduced originally in April 2010, which provided an additional sub-
classification within the residential use class - C4. There was a need for planning permission
for a Change of Use between C3 and C4. It is argued that many of the issues that
prompted the introduction of this separate use class apply to 'second homes' also. The
issues may manifest themselves in a different way, but they still revolve around the concept
of community cohesion, amongst other things.
2.2 Circular 08/2010
It is worth looking at the motivation for the change to the Use Classes Order in 2010, when
a new residential use class was incorporated. Circular 08/2010 contains information about
the change in the use class and states in paragraph 2:
"A high concentration of shared homes can sometimes cause problems, especially if too
many properties in one area are let to short term tenants with little stake in the local
community. So changes to legislation will give councils the freedom to choose areas where
landlords must submit a planning application to rent their properties to unrelated tenants
(i.e. houses in multiple occupation). This will enable high concentrations of houses in
multiple occupation to be controlled where local authorities decide there is a problem, but
will prevent landlords across the country being driven from the rental market by high costs
and red tape."
The request being put forward by SLDC and YDNPA are for precisely the same reasons. It
was considered by the government that the letting to short term tenants led to little stake in
local communities. The same, it could be argued, applies to the scenario with holiday lets
and second homes.
2.3 House of Commons Library, Social Policy Section "Houses in multiple
occupation & the Use Classes Order Standard Note SN/SP/5414 by Wendy
Wilson - 30 December 2013
There are a number of reports related to the introduction of a new C4 Use Class in April
2010 and the subsequent changes in October 2010 to allow the change of use between C4
and C3 without planning permission. The above note provides a summary of the various
changes, and the reasoning behind them.
The findings were, that HMOs, when over a certain percentage, could had a negative impact
on local communities through:
• anti-social behaviour, noise and nuisance
• imbalanced and unsustainable communities
• negative impacts on the physical environment and streetscape
Secondary Evidence Overview A.10• pressures upon parking provision
• increased crime
• growth in private rented sector at the expenses of owner-occupation
• pressure upon local community facilities and
• restructuring of retail, commercial services and recreational facilities to suit the
lifestyles of the predominant population
Although the impacts of second homes on a local community are different to impacts of
HMOs, there are some comparatives to be drawn, particularly points 2, 3, 4, 5 (but
opposite), 6 and 7. The case studies submitted will give details of the particular impacts of
second homes.
Although the Use Classes Order was amended in October 2010 by the new government, to
allow the change of use between C3 and C4 without planning permission, the rights
available to Local Planning Authorities under Article 4 of the General Permitted Development
Order 1995 meant that the situation could be controlled locally where it was considered a
significant issue. The government felt that this allowed LPAs greater flexibility in controlling
permitted development rights, whilst not stilting the wider rented housing market.
The same method for controlling second homes is proposed by SLDC and LDNPA. It is
worth noting that the government agreed that non-legislative mechanisms for controlling
HMOs were not working to the standard needed to control the problem. The same could be
suggested in the second homes scenario. Although there are numerous mechanisms to
achieve affordable housing provision in rural communities, these are not working to the
extent that they could in other areas (particularly non-National Park areas), due to the
constraints that exist in these sensitive areas (i.e. land availability, price of land, protected
landscapes etc.)
It is also worth noting the consultation procedures that are required in drawing up an Article
4 direction, and that the GPDO 1995 could be amended to ensure that the Secretary of
State is consulted on any Article 4 direction with regard to removal of PD rights between C3
and C5.
2.4 Other recent changes
There have been a number of other recent changes to the Use Classes Order, covered under
the The Town and Country Planning (General Permitted Development) (Amendment)
(England) Order 2013 which introduced changes to permitted development rights for
residential extensions, and also introduced a new permitted change of use (Class J) between
Office (B1) and Residential (C3). The reports associated with the impacts of these proposals
are available, and it is clear that the rationale behind these changes is to increase the
number of dwellings available in line with a response to the housing shortage.
It is considered that the proposals put forward to introduce another Use Class should be
considered in line with other recent proposals, some of which are far more contentious. For
instance the recent consultation Greater Flexibilities for Change of Use (August 2013) on
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