A Presentation to the Conservative Rural Affairs Group,
6 February 2018
SUMMARY OF MAIN POINTS
Part I: Difficulties Faced by New Entrants
Although there is consolidation in the farming industry as larger arms expand, there is also a degree of fragmentation of ownership when medium sized farms are broken up. A proportion of these smaller plots are bought by new entrants aiming to make a living from farming and/or woodland management.
Most of these people make a living by adding value through on-farm processing and direct sales. This enables them to employ more people per hectare than larger farms, while productivity per hectare is broadly similar.
Problems Faced by New Entrants
A number of factors including the high price of land and agricultural buildings, and insecurity of tenure on rented properties, means that new entrants often buy plots of land with few or no agricultural buildings and so have to embark on a process of building their farm infrastructure. It will normally be more practical and efficient to live on site, and the cost of rural residential accommodation is much higher than can often be afforded by an otherwise viable farming enterprise. However the planning system is resistant to development in the open countryside, especially residential development; trying to break through that resistance engages the farmer in a process that is mystifying, stressful and timeconsuming.
There is a dearth of national policy relating to agricultural buildings and dwellings. The National Planning Policy Framework (NPPF) states only that rural worker’s dwellings are allowable if there is an “essential need for a rural worker to live permanently at or near their place of work”. The National Planning Practice Guidance (NPPG) has nothing to say about agricultural development. Most local development plans contain policies on agricultural dwellings which echo advice previously given in PPS7, requiring that applicants should demonstrate an essential need to live on site and that the enterprise should be viable. There is nothing intrinsically wrong with these criteria but they are poorly defined and there is variation in interpretation, particularly as regards essential need. The recommended occupancy condition is weak, since it does not tie the dwelling to the land that justified it, leading to abuse.
Examples of New Entrants Experiencing Planning Difficulties.
Over the years Chapter 7 has documented many cases where planning officers’ resistance to agricultural development is unhelpful, and sometimes unreasonable. These include cases where officers refuse to acknowledge permitted development rights, turn down proposals for modest yet necessary agricultural buildings, or reject applications for dwellings on weak grounds. The high proportion of permissions that are granted at appeal, often after more than one application, suggests that many local authority planning officers are unduly biased against agricultural development on new holdings.
Why New Entrants Meet Resistance.
The main reason is that planning consent for agricultural buildings is notoriously susceptible to abuse from people who pretend or aspire to be farmers but who eventually convert farm buildings to another use, or agricultural dwellings to market housing. This is a genuine concern, inadequately addressed by the current model occupancy condition. Another reason may be that many planning officers have scant understanding of or sympathy for agriculture and forestry.
Part II: Some Recommendations and Suggestions
To remedy the situation, policies concerning agricultural development on new and bareland holdings need to be clarified. In particular:
• Paragraph 28 of the NPPF should be explicit about the benefits of local food;
• The NPPG should advise LPAs that when assessing “essential need” they should give weight to all relevant factors including the need to deal with emergencies, to manage the enterprise efficiently, to work unsociable hours, to reduce car use, to secure affordable accommodation, and to protect the enterprise from theft
• The NPPG should remind LPAs that the viability and labour requirements of small-scale enterprises cannot necessarily be assessed using formulae derived from farm management manuals;
• The role of temporary permission should be clarified, noting that: it serves as a trial period when there is some uncertainty about viability; that five years is often a better period than three on bareland holdings; and that an easily dismantled wooden dwelling may be more appropriate than a caravan.
Securing New Farming Enterprises and Preventing Abuse
Instead of the weak occupancy condition currently used, new agricultural dwellings should be secured with a condition or Section 106 agreement that ties the dwelling to the land and farming enterprise that justified it; or sometimes a personal condition is more appropriate There are also a number of schemes to provide small-scale farming opportunities under the umbrella management of a social organization, such as a co-operative or a charity, the most notable in the UK being the Ecological Land Co-op. These deserve more recognition and support from the planning system than they have so far received,
Local Food Provision in the Green Belt
With a massive market at hand, there is no more convenient place to produce local food than the green belt around London and other cities; and there would be benefits to urban schools and community groups from having farms producing local foods on their doorstep. A majority of urban residents say they would like to buy food grown nearby, while substantial areas of green belt land are “neglected.”
Yet it is doubly difficult for producers of local food to establish themselves in the green belt, owing to the hope value attached to the land and to stringent planning policies. The NPPF should be revised so as to encourage local food production and provision in the green belt, and allow that an agricultural worker’s dwelling may be appropriate.
Existing farms sometimes confront much the same problems as new entrants, when succession can only be satisfactorily resolved by introducing an extra dwelling. The DHCLG should consider whether a second dwelling policy similar to that in Welsh Technical Advice 6 could be introduced in England.
Simon Fairlie, Chapter 7