APPENDIX A - Discussion Paper: Core Strategy Policies HO9 and EC2
Background to Core Strategy Policies HO9 and EC2
Nationally over the past couple of decades there has been an increasing demand to convert non-residential rural buildings, primarily barns and
other attractive agricultural buildings that are either redundant or of limited use, to permanent dwellings. In North Norfolk, this demand has been
strong as a result of the attractiveness of the countryside, the large number of traditionally-built agricultural buildings and until more recently a
generally buoyant housing market.
Previous Government policy in relation to the countryside (in particular PPS7 and PPS4) stated that ‘the re-use of buildings in the countryside
for economic purposes will usually be preferable, but that residential conversions may be more appropriate in some locations and for some
types of building’. This approach sought to support the rural economy and promote sustainable patterns of development, by giving preference
to employment generating uses and avoiding the creation of isolated dwellings in the countryside. This national advice along with the strategic
objectives of the Core Strategy informed the formulation of Policy HO9 and Policy EC2. These two policies in tandem allow for the economic
use of rural buildings across the countryside and residential uses of good quality buildings in certain locations, subject to compliance with a
range of detailed criteria.
TABLE 1 – Summary of adopted policy approach.
Core Strategy Policy
EC2 – Allows the Reuse of Buildings in the
Countryside for
economic purposes
(including holiday)
HO9 – Allows
Conversion and Reuse of Rural Buildings
as Dwellings
Applies to structurally sound
rural buildings of no particular
merit
Rural buildings worthy of retention due to
their historic, architectural or landscape
value
Rural buildings of significant heritage value
which are either nationally Listed or capable of
being included on a local list when assessed
against published criteria.
YES
YES
YES
NO- To be considered suitable
for residential use buildings
must be both structurally sound
and have intrinsic quality.
YES – but only in defined locations based
on a measure of sustainability (defined
zones on the Proposals Map)
YES - Where it is demonstrated that a
residential use is the best use to secure the
future of the building
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Adopted policies allow the potential for the following objectives to be achieved:
Ensures a supply of buildings for uses that support and benefit the rural and or/ tourist economy
Allows a modest number of new dwellings to be delivered in locations where residents have access to and help support, existing local
facilities and services
Secures the future of traditional rural buildings that positively contribute to the local distinctiveness of North Norfolk
May help address rural housing need by seeking where it is viable to do so an affordable housing contribution.
Safeguarding sites in economic uses where they support rural employment
National Planning Policy Framework (NPPF)
Previous government advice in PPS4 regarding rural buildings has now been cancelled. The NPPF contains no specific section setting out a
policy approach to rural buildings although there are a number of references throughout the document relevant to the consideration of this
policy area.
1. Para. 6: Central to the NPPF is that planning policies should contribute to the achievement of sustainable development, defined as
having three dimensions: economic, social and environmental.
2. Para. 17: The Core Planning Principles set out in the NPPF, with the exception of the introduction of the neighbourhood planning
process , largely reiterate the key land-use principles that have directed plan making and decision taking over recent decades - in
particular the role of the planning system in driving and supporting economic development to deliver homes, and employment growth.
Actively managing patterns of such growth remains a core principle, reference being made to the need to ‘focus significant development
in locations which are or can be made sustainable’. Within the Core Principles the role of converting existing buildings to new uses is
recognised, as supporting the transition to a low carbon future.
3. Para. 28: The NPPF states that planning policies should support the sustainable growth and expansion of all types of business and
enterprise (including tourism) in rural areas through policies that allow for the conversion of existing buildings and well designed new
buildings for such purposes.
4. Para. 47-55: It is perhaps however within the housing section of the NPPF that a shift in policy position is apparent. Section 6 of the
NPPF sets out advice to ‘boost significantly the supply of housing’. In relation to housing in the countryside the advice remains that
isolated homes in the countryside should be avoided and only allowed in special circumstances. These special circumstances include
dwellings previously referred to in Government advice eg agricultural workers dwellings, but significantly now also included is ‘ where
the development would re-use redundant or disused buildings and lead to an enhancement to the immediate setting.
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5. Para 55: ‘where such development would represent the optimal viable use of a heritage asset or would be appropriate enabling
development to secure the future of heritage assets’ is included as a further circumstance when new isolated homes in the countryside
may be allowed.
Interpretation:
In the context of the NPPF, government advice relating to rural buildings indicates:
Re-use for residential or economic purposes are equally beneficial to sustainable rural communities – no longer are economic uses
being cited as preferable.
Recycling benefits of re-using and improving a disused or redundant building, seen as offsetting sustainability concerns regarding
isolated rural location.
DISCUSSION - Core Strategy Polices HO9/EC2 and degree of consistency with NPPF
It was very clear in the previous government advice (PPSs and PPGs) that existing buildings should be re-used for alternative purposes and
that there should be a preference for economic uses. This preference did not rule out residential re-use which was to be considered acceptable
for some buildings in some locations. Through the development of the Core Strategy this Council defined both the type of building (a quality
test) and the locations (the defined zones) where residential proposals would be supported. As outlined above, the NPPF continues to support
the re-use of buildings for a range of uses but no longer states a preference for employment uses, neither does it appear to seek to limit the
locations were residential uses should be considered acceptable. On the contrary, the NPPF states that isolated dwellings in the Countryside
should be avoided unless the proposal is for re-use of a disused or redundant building. Whilst the content of the NPPF is open to interpretation,
and departures from it can be justified at a local level, it seems clear to officers that the government does not anticipate the need to control the
residential re-use of redundant buildings to particular locations. Furthermore the NPPF seems to be less concerned with the quality of the
building to be converted, as it refers only to existing use i.e. redundant or disused states and that the immediate setting of the building would be
enhanced. This raises a number of questions, not least:
1. To what extent should the Council seek to limit the locations where residential re-use of buildings should be allowed? What would be
the consequences of allowing residential uses in all parts of the District? Would such an approach result in sustainable or unsustainable
development’ in North Norfolk, a key requirement of the NPPF?
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2. Are there locally applicable circumstances which would justify retaining a preference for employment uses rather than a residential use?
Would a permissive approach to residential result in sustainable rural communities, taking into account the three dimensions of
sustainable development economic/social and environmental?
3. Should buildings need to comply with some sort of quality test before they will be considered suitable candidates for residential use?
4. Should disused buildings and those in an existing economic use be treated in the same way?
1. LOCATION?
At the centre of the debate about location is the question of sustainability. In its broadest sense it is clear from the NPPF that local authorities
should be exercising control over the location of development and that significant developments should be focussed around the larger, more
sustainable communities. Hence the adopted Core Strategy which includes a strategic policy objective and a settlement hierarchy that aims to
distribute development on the basis that most development will occur in and around towns, with smaller proportions in smaller settlements, and
less in the Countryside policy area, is NPPF consistent. However some argue that this ‘narrow’ distribution of development does not address
rural sustainability or social needs and that it will result in the further decline of village life. Others have argued that the quantum of
development that would be required to make any genuine contribution to rural sustainability (addressing housing needs, providing jobs,
providing services and so on) would be so substantial so as to seriously undermine the rural character of smaller communities.
At an individual community level the number of buildings that might be converted to residential use is likely to be small and would have no
perceptible impact, either negative or positive, on the sustainability of any given settlement. However at a District wide level it is known that
there is substantial capacity for residential re-use of buildings (perhaps as many as 1500+ units) which if allowed would result in a different
distribution of residential development than proposed in the Core Strategy.
2. PREFERENCE FOR ECONOMIC USES?
One of the successes of the existing policy approach has been to retain a preference for economic, including holiday, uses in many locations in
the District. This has resulted in the provision of high numbers of holiday units, either in use as holiday homes or holiday lets, with varying
degrees of spin off benefits to the tourism economy. It might be argued that a good stock of commercial holiday accommodation already exists
and that a slowdown of new conversions would not detract from the tourist offer. However, if planning controls were changed to allow the lifting
of occupancy restrictions on converted buildings the loss of bed spaces may be substantial in both quantitative and qualitative terms. In
addition there are also a number of fairly significant commercial uses in former barns (Bayfield Becks, Wroxham Barns, Roughton Fruit Farm
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and numerous smaller businesses and visitor attractions) which might well have preferred residential uses had this option been available and if
pursued these sites would not have provided the economic benefits they have.
3. BUILDING QUALITY TESTS?
Some of the underlying justifications for allowing the re-use of buildings are that they exist, they are often not suitable for their former use, and
they can be put to an alternative useful purpose without a great deal of alteration. This may in turn reduce some of the pressure for new
building. For a number of years a common feature of policy approaches has been an expectation that buildings should be structurally sound to
the extent that proposals are genuinely for conversion rather than reconstruction and, particularly in relation to residential proposals, that the
building has some inherent value that makes it worthy of retention. The Council has sought to resist the conversion of poor quality buildings or
the re-building of structures where insufficient remains to genuinely describe the proposal as a conversion. Once it has been agreed that there
is an existing building which is worth keeping the Council has sought to limit the extent of alteration. Hence the quality of the building, both
before and after the conversion, are important considerations.
Policy HO9 in particular, seeks to prevent residential conversion of buildings which are either poorly constructed or not worthy of retention.
Criteria 2 of the policy requires that as well as being structurally suitable a building must be ‘worthy of retention for its architectural, historic or
landscape value. This building quality test was supported by the Inspector previously at the Core Strategy examination and is included to
positively assist in the safeguarding of buildings that contribute to the rural built heritage of the district. This approach has the advantage of
allowing the better quality buildings to be converted to residential use and maintaining a stock of other buildings, not meeting the quality test, for
re-use for economic uses under policy EC2. This allows the potential for rural buildings to be used for a mix of uses of benefit to the rural
community.
4. CHANGES OF USE /LIFTING OF OCCUPANCY CONDITIONS?
The NPPF in introducing a new circumstance where isolated rural dwellings may be allowed in existing buildings, includes two qualifications 1)
the building is redundant or disused and 2) the development would lead to an enhancement to the immediate setting. There are many other
buildings in the countryside in non-residential uses, not falling into the redundant or disused category, where the owner may consider a
residential use to be preferable. Such buildings would include those in employment and holiday uses and buildings previously associated with
defence establishments. How should applications for the change use of these building or the lifting of restrictive occupancy conditions be
considered, particularly as in many cases the development (e.g. lifting of a holiday restriction) would not result in an enhancement of the setting
of the building? In particular should the implications of losing an economic use be assessed before a residential use is permitted? Sustainable
rural communities rely not only on access to housing but also a prosperous rural economy. Policy HO9 already offers some protection
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regarding this matter by indicating that ‘ Proposals that would result in the loss of a significant number of jobs will not normally be supported’
and Policies EC8 (Retaining an Adequate Supply and Mix of Tourist Accommodation) and CT3 (Provision and Retention of Local Facilities and
Services) offer a degree of further protection. There is however, the risk that a large number of applications for the change of use of individual
and small scale groups of buildings could cumulatively have a significant impact on the rural /tourism economies.
The NPPF in para. 51 recognises the value of economic uses in the statement:
‘Local planning authorities ….should normally approve planning applications for change to residential…from commercial uses (currently in the
B use class) where there is an identified housing need for additional housing in that area, provided that there are not strong economic reasons
why such development would be inappropriate.’
Options for Discussion.
Current adopted Policy H09, and in particular the limitations it imposes in relation to building location do not, on face value, appear to comply
with the NPPF which allows for the provision of isolated dwellings in the countryside where they comprise the re-use of existing buildings. This
does not mean that the current policy approach is unacceptable as locally specific and evidenced based policies which are not aligned with the
NPPF may be justified.
The following table highlights a number of potential options for discussion.
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Options
Option 1
Potential approach
Allow economic use of
any structurally sound
rural building
Allow residential use of
traditional buildings of
merit, in sustainable
locations
Allow residential use of
buildings of significant
heritage value, where that
use best secures its
future.
Justification
planning objectives
Delivers new housing in the
countryside
Conformity
with Core
Strategy?
Comment / Risk
YES
Degree of conflict with NPPF because of preference given
to economic uses and locational/building quality controls
imposed on residential uses.
Supports the rural/tourism
economies
Requires justification on the basis of locally applicable
circumstances.
Retains buildings that positively
contribute to the local
distinctiveness of North Norfolk
In North Norfolk is there sound justification to:
Restrict number of dwellings in countryside?
Potential to assist in the delivery
of affordable housing in the
countryside
Safeguard existing economic uses in the countryside?
Have regard to the merit of the building so to protect
the local distinctiveness of the rural landscape.
Continue with Policies
HO9 and EC2
Option 2
Allow any disused rural
building to be used for
either residential or
economic purposes,
provided setting of
building is enhanced
Allow buildings in existing
economic use to be
reused as dwellings
provided no economic
Boost supply of new housing in
the district
Supports the rural/tourism
economies
Potential to assist in the delivery
of affordable housing in the
countryside
NO
NPPF consistent but does not comply with Core Strategy
Scale of development - North Norfolk is a rural district with a
large supply of agricultural buildings. Potential to deliver a
significant number of dwellings in the countryside. SS2
anticipates that around 10% of new homes (2001 – 2021) will
be developed in the countryside. This proportion is likely to be
exceeded and depart from the pattern of growth as set out in
the Spatial Strategy. ie larger proportion of new housing than
planned for being developed in the countryside.
Retains buildings that positively
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reasons why such
development would be
inappropriate.
contribute to the local
distinctiveness of North Norfolk
Would result in the conversion of a large number of poor
quality buildings to dwellings and have a negative impact on
the character and appearance of the countryside.
Could militate against economic uses. Given residential
values this policy approach could discourage proposals for
less profitable economic uses and community uses utilising
disused/redundant buildings
Could result in the reduction in the supply of holiday
accommodation in the rural area - impact on tourism offer of
the District (choice and location of accommodation,
quantitative and quantitative impacts)
Option 3
Allow any building to
convert to residential use
if economic uses have
been shown not to be
viable
Increased supply of new
housing in the district
NO
Supports the rural/tourism
economies
Allows for an increase in the supply of new homes through the
conversion of any building not in a viable use. Potential to
deliver a significant number of dwellings in the countryside numbers likely to exceed those planned in the Core Strategy.
Retains traditional buildings that
positively contribute to the local
distinctiveness of North Norfolk
Buildings in viable uses supporting the rural and tourist
economy would be safeguarded
Potential to assist in the delivery
of affordable housing in the
countryside
Option 4
Allow economic use of
any structurally sound
rural building
Allow residential use of
Increased supply of new
housing
Supports the rural/tourism
economies
In part NPPF consistent - contrary to para. 55, approach sets
economic as preferable uses of disused/redundant buildings .
NO
Building quality test justified in North Norfolk given Core
Strategy objectives for the countryside - balancing the
benefits of new housing, the rural/tourist economy and
landscape quality/appearance
Supports broad objectives of NPPF - possible conflict
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traditional buildings of
merit
regarding the re-use of buildings in existing economic use
Retains buildings that positively
contribute to the local
distinctiveness of North Norfolk
Allows for an increase in the supply new homes but only
through the conversion/re-use of the better quality buildings –
Fewer homes would be created compared to Option 2 but still
a significant number given the potential number of buildings in
economic uses that may come forward for residential use.
Degree of conflict with Spatial Strategy.
Potential to assist in the delivery
of affordable housing in the
countryside
Modern agricultural buildings plus those of sub-standard
construction would remain available for economic uses
including holiday
Could result in the reduction in the supply of holiday
accommodation in rural area - impact on tourism offer of the
District (range of accommodation, quantitative and quantitative
impact)
Option 5
Allow economic use of
any structurally sound
rural building
Allow residential use of
disused traditional
buildings of merit
Allow residential use of
buildings currently in
economic use, where the
building is of merit and
that use is no longer
viable
Increased supply of new
housing
Support the rural/tourist
economies
Retains buildings that positively
contribute to the local
distinctiveness of North Norfolk
Potential to assist in the delivery
of affordable housing in the
countryside
YES
Justified in North Norfolk given Core Strategy objectives
for the countryside - balancing the benefits of new
housing, the rural/tourist economy and landscape
quality/appearance
Supports broad objectives of NPPF
Allows for an increase in the supply of new homes but only
through the conversion of the better quality redundant
buildings and where such buildings in existing economic use
become unviable. Fewer homes would be created compared to
Option 2, less conflict with Spatial Strategy.
Modern agricultural buildings plus those of sub-standard
construction would remain available for economic uses
including holiday .Buildings in viable uses, supporting the rural
and tourist economy, would be safeguarded.
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-
Social
New housing
Support rural facilities/services
Contribute and support rural communities
2
4
3
5
Economic
Support growth of new rural
enterprise
Support growth of rural
employment opportunities
Support the North Norfolk tourist
economy
1
Environmental
Safeguarding of traditional rural
buildings – built heritage
Protection of landscape character
Re-using existing buildings
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