Response from Arts Council England:
Consultation on proposed changes to planning policy – DCLG Dec 2015
Introduction
Arts Council England’s mission is 'great art and culture for everyone', which we deliver through
investment and the development of strategic partnerships at local and regional level in a
sustainable national ecology. As the national development agency for the arts, museums and
libraries, we support a range of activities from theatre, music, reading, dance, visual arts,
photography, digital art, exhibitions, collections, carnival, and the crafts. The arts and cultural
sector plays a vital role in the economic and social success of our cities, towns, and villages. We
support and invest in high quality arts and cultural practice and the best emerging practitioners
that represent the backbone of our cultural infrastructure and contribute to the future of the UK’s
dynamic creative economy.
National Planning Policy Framework(NPPF) - Building on the role of Arts & Culture
We have engaged with DCLG over a number of years on issues relating to planning and the
potential for the arts and culture to help build vibrant, prosperous and sustainable communities.
We were fully supportive of the NPPF and its identification of arts and culture as a key determinant
of social and economic value. We want to build on previous collaborative work with the DCLG to
foster the role of arts and culture in the built environment and to assistant in the growth of stronger
communities.
We broadly support the approach of the National Planning Policy Framework in its presumption in
favour of sustainable development and the important role of Local Plans to ensure appropriate
planned development in local areas. We welcome the DCLG’s proposal to strengthen policy to
support Local Plans which will assist local communities in meeting housing demands, and
because it will provide opportunities for us to work more closely with local authority partners to
strengthen arts and cultural provision.
The proposed re-designation and re-use of land, coupled with the facilitation of targets in housing
plans, has the potential to make a step change towards meeting the needs of first time buyers,
young families, and others aspiring to home ownership.
We work in partnership with local authorities and, arts and cultural organisations to support the
development of arts and culture within Local Plans, PPGs, use of the Community Investment
Levy(CIL), and 106 agreements. This work, in turn, supports the aspirations of local communities
in place shaping and local distinctiveness.
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Place Making through Arts & Culture strengthens local communities
These changes to national planning policy also have the potential to further the government’s
ambitions for Place Making and to facilitate the place of arts and culture in regeneration schemes.
Place Making strategies through the application of arts and culture build and strengthen local
communities. Our work in this area over many years with the DCLG, the Town & Country
Planning Association(TCPA), and other professional partners, has included building capacity
amongst planning and cultural professionals through the development of best practice guidance,
and the development of standard charge approaches to secure developers' contributions under
S106. In addition, we have increasingly adopted place focused approaches to our investment and
development work. Our Creative people and places1 programme, is a successful nationwide
programme of investment which enables local communities to work together to shape local
provision.
The consultation document mentions the need to open up to new development partners to achieve
the changes proposed and unlock opportunities for housing. The arts and cultural sector are
strong partners in development, offering new perspectives and key resources to facilitate new
developments in local areas. We are happy to sign-post local authority partners and other
developers to local arts and cultural partners and routes to funding.
New development opportunities should also take as part of their brief the need to achieve a good
marriage between affordable build and fit for purpose spaces, that contribute to the
distinctiveness of local places. If small development sites produce bland or impractical housing,
unconnected to local facilities, then community social problems and unemployment may persist.
Our overall objective in responding to this consultation is to ensure that local communities and
planning authorities are fully able to use the planning system, and strengthen policy framework, to
realise the potential of arts and culture to contribute to building successful and sustainable places.
Any barriers to this approach should be tackled and collaborative working at local level should be
enabled. We are able to support developers by advising on funding and providing advice to
maximise the benefits of including arts and culture in new housing developments.
We support the Prime Minister’s new design advisory panel whose remit will be to offer targeted
advice to developers to ensure that good design is embedded in the delivery of new housing. The
lessons learned from design reviews should inform the national rollout of these changes to
planning policy. This will complement the Government's approach to devolution deals which are
so far taking place in over 30 local authority areas as well as wider tourism growth proposals.
Taking a practical approach to the inclusion of arts and culture in new developments, we advocate
the use of strategies by developers which may include, but are not limited to:
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http://www.artscouncil.org.uk/funding/apply-funding/funding-programmes/creative-people-and-places-fund/
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consideration of housing sites in proximity to local cultural provision specifically to arts,
museums and libraries, and the provision of public space for entertainment, outdoor arts,
and play;
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effective use of the Community Impact Levy(CIL) 123 schedules, and Percent for Art under
106 agreements, at an early stage of planning application to ensure local distinctiveness
and connectivity to local cultural services ie library(to meet statutory duties), museum, and
arts infrastructure;
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consider the specific contribution of artists to provide art in public places, including creative
approaches to signage and way marking, undertaking community engagement in the
development, providing local distinctiveness to the development, creation of unique selling
points for the development, and to foster a sense of local pride;
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consideration of live/work accommodation and mixed developments for SMEs including
creative and media business start-ups, especially where there is proximity to community
hubs, unoccupied industrial units, transport links, enterprise zones, and business
improvement districts.
Current examples of live/work and mixed housing development:
 Brent Council and studio provider ACAVA have formed a partnership as a result of a
section 106 agreement, on ex-light-industrial land, to provide basement and ground floor
live/work units and 7 floors of affordable housing close to Queensbury and Kingsbury tube
stations on the Jubilee line in London. Such mixed development involving a cultural
organisation as a partner, provides opportunities for communities to work and live close to
commuter hubs.

The Meridian Water development site in Edmonton, North London includes plans for retail
units, light industrial and storage facilities, public facilities, 8,000 houses, and the aim to
provide 3,000 jobs. This is a major regeneration project involving the local authority,
regeneration agencies, private sector developers, funding from the London Regeneration
Fund, and two arts and culture partners. Building Bloqs and ACAVA are creative industries
partners who are working with the local authority and developers to provide studio spaces
for artists and makers in old industrial buildings near to Angel Road station and transport
hub. The studios will be developed and come into use for artists and makers to work in as
part of the first phase of development, and housing is to be built around the studio buildings
over a number of years.

Further examples of studio spaces being developed around London include Clapton next to
the old tram depot in Hackney, London; and an ex-industrial site in Southall where housing,
hotel, and studio spaces will link together near to the transport hub.
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
In Stoke on Trent the local authority is working with cultural partners on the old Spode
ceramics factory site, of some 11acres near to Stoke on Trent train station, to provide
studio spaces, student housing, and a new museum.

On a broader point, local housing can be further supported by connecting to the co-location
of community facilities and deals through planning gain can provide opportunities alongside
public/private housing or mixed use developments, eg Downham Leisure Centre in
Lewisham. Our fund called, Enterprising Libraries can provide additional resources and
support for developments and here is a summary:- Enterprising Libraries is a commissioned
grant to bring together and develop existing practice in business and Intellectual Property
support as a basis for local innovation, enabling public libraries to be incubators for local
enterprise and entrepreneurship. This is a £1.3 million partnership programme with the
British Library and the Department for Communities and Local Government, with £300,000
from the Arts Council, £600,000 from DCLG and £367,000 from the British Library. What
are we investing in? Supporting local economic growth; Fostering entrepreneurship in the
local community for people who are interested in becoming self-employed; Helping more
people access the same kind of services across the country.
References:
This study from the Mayor of London provides case studies of artist’s workspaces.
Artists’ Workspaces study, GLA Sept2014
Examples of good practice can be found in –
‘Improving culture, arts and sporting opportunities through planning –
a good practice guide’, by Arts Council England, CLOA, Culture and Sport Planning Toolkit,
The National Archives, SECIF, the Theatre Trust, and with the TCPA.
Ixia is the national association for Public Art , their archive and publications provide many
examples of good practice and tool-kits for art in public places.
The latest DCMS Creative Industries Economic estimates provide up to date data on the scale
employment and productivity in the sector at
https://www.gov.uk/government/statistics/creative-industries-economic-estimates-january-2016
The DCMS press release on the creative industries can be found at
https://www.gov.uk/government/news/creative-industries-worth-almost-10-million-an-hour-toeconomy
Summary of the estimates of the contribution of the Creative Industries to UK gross value added
(GVA) up to 2014. It also includes revised estimates for 2012 and 2013.
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Key trends:
Creative industries growth rates:
 GVA of the Creative Industries was £84.1bn in 2014 and accounted for 5.2 per cent of the
UK economy
 For four years running the Creative Industries have grown as a proportion of the total UK
GVA
 GVA of the Creative Industries increased by 8.9 per cent between 2013 and 2014. This
compares to 4.6 per cent for the whole of the UK
 Between 1997 and 2014, GVA of the Creative Industries increased by 6.0 per cent each
year compared to 4.3 per cent for the UK economy.

Total employment in the Creative Industries across England increased by 6.2% between 2013 and
2014 (1.4 million to 1.6 million jobs) and by 17.6% between 2011 and 2014.

In England Creative Industry jobs in music, performing arts and visual arts have seen a greater
proportional increase in the number of jobs than the Creative Industry overall: 19.5% between 2013
and 2014 and 40.6% between 2011 and 2014.
Sub-sectors within the creative industries:
 “IT, software and computer services” continued to be the largest constituent part of the
Creative Industries, accounting for 43.5 per cent of the Creative Industries GVA
 The ‘Design: product, graphic and fashion design’ sector had the largest increase in GVA
between 2013 and 2014 (16.6 per cent)
 The ‘music, performing and visual arts’ sector had a 5.4 per cent increase in GVA between
2013 and 2014.
The creative industries compared to other Blue Book sectors:
 Between 2013 and 2014 GVA of the Creative Industries increased by a larger percentage
than any of the Blue Book sectors, with the exceptions of Construction. Between these two
years the GVA of the Creative Industries increased by 8.9 per cent, while Construction grew
by 10.2 per cent.
 GVA of the Creative Industries increased by 37.5 per cent between 2008 and 2014, which
was greater than any Blue Book sector over the same period. ‘Real Estate Activities’ had
the next highest increase at 34.7 per cent.
Summary of Questions
a) Affordable Housing
Question responses
Q1. Do you have any comments or suggestions about the proposal to amend the
definition of affordable housing in national planning policy to include a wider range
of low cost home ownership options?
We welcome the proposal to broaden the definition of affordable housing. Artists and craftspeople
who are developing their creative work, contributing to the local economy through the
development, production, and sale of their work and services, may aspire to home ownership on
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brownfield sites and small sites, and close to commuter hubs. They will also be interested in
work/live units on mixed rent and ownership sites both in rural and urban areas, providing a
greater range of options to buy and to put down roots in local communities. Please refer to
creative industries statistics above.
Q2. Do you have any views on the implications of the proposed change to the
definition of affordable housing on people with protected characteristics as defined
in the Equalities Act 2010? What evidence do you have on this matter?
We are committed to Equalities and diversity through all of our work to develop and sustain the
arts and culture economy in urban and rural areas. Whilst the impact of these policy changes are
likely to be beneficial to people under 40yr including people with protected characteristics, as the
document states, people of ethnic background are likely to be adversely affected. People with
disabilities and people from ethnic backgrounds receive lower salaries (Equalities and Human
Rights Commission (EHRC) – How Fair is Britain? Report 2010). On page 7 of consultation
document, the Equalities statement includes reasoning that people from ethnic minorities may be
disadvantaged economically but advantaged by aspiration to home ownership. This argument
appears weak. The costs of deposits and mortgage rates can and do prohibit home ownership
amongst low income households, of which disabled people and people from ethnic backgrounds
are disproportionately represented in comparison with other members of the population.
b) Increasing residential density around commuter hubs
Artists and craftspeople will be interested in working and living near to commuter hubs which
connect them and their work to wider markets, audiences, professional networks and suppliers.
Please refer to creative industries statistics above.
Q3. Do you agree with the Government’s definition of commuter hub? If not, what
changes do you consider are required?
We welcome the emphasis on use of public transport in terms of convenience for
communities and the potential reduction in carbon footprint.
Q4. Do you have any further suggestions for proposals to support higher density
development around commuter hubs through the planning system?
Some Local Plans will provide references to local distinctiveness, quality of design, and
community requirements in terms of density. We would like to be assured that quality of
design will have weight in these proposals and in planning guidelines. In the design of
high density housing we would like to see consideration given to the needs of families ie to
have space to relate to one another, and to contribute to community in which they live and
or work. This will be important whether people are to join an existing community or if they
are moving into a new community settlement.
We support Architect and Artist collaborative practice as such partnerships do think out of
the box, and innovative design will be of paramount importance in bringing disused rail
sites, other brownfield sites, and small sites into use through the effective use of space and
orientation of buildings. Innovative design to a budget, through Architect and Artist
collaborations can and do provide affordable, workable, liveable spaces, that also
contribute to community cohesion, and community safety. Such collaborations can also
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provide visual motifs which add value to the skyline and streetscape, in turn contributing to
the vibrancy and desirability of a local area (whether small scale, rural, or urban in nature).
The Prime Minister’s design advisory panel should have oversight of design guidelines for
inclusion in Local Plans to ensure effective implementation of design considerations in
small housing or work/live or mixed used developments.
Q5. Do you agree that the Government should not introduce a minimum level of
residential densities in national policy for areas around commuter hubs? If not, why
not?
c) Supporting new settlements, development on brownfield land and small sites, and delivery of
housing agrees in Local Plans
N/A
Q6. Do you consider that national planning policy should provide greater policy
support for new settlements in meeting development needs? If not, why not?
Yes, we agree that national planning policy should provide greater policy support for new
settlements in meeting development needs. It is important to ensure that Local Planning
Authorities have at their disposal greater policy support to underpin their Local Plans and
Area Development Plans. This then provides a stronger policy framework from which to
develop the role of arts and culture in regeneration and the revitalisation of local
communities.
We are able to provide advice and guidance on arts and cultural planning, access to
resources, best practice, and formation of new partnerships. We will encourage local
authority partners to work with arts and cultural partners in the review of their Local Plans
in the implementation of these proposed changes to the NPPF.
Q7. Do you consider that it would be beneficial to strengthen policy on development
of brownfield land for housing? If not, why not and are there any unintended
impacts that we should take into account?
Yes, we support the strengthening of policy on development of brownfield land for housing.
We also support the provision of work/live accommodation especially around commuter
hubs and unused rail land in rural and urban areas for use by Artists, arts organisations,
creative media and creative industries professionals, and their families, who will add value
to the local economy and contribute to community services.
Q8. Do you consider that it would be beneficial to strengthen policy on development
of small sites for housing? If not, why not? How could the change impact on the
calculation of the local planning authorities’ five-year land supply?
We support policy development that would assist local authorities in managing land supply
and Local Plans.
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Q9. Do you agree with the Government proposal to define a small site as a site of
less than 10 units? If not, what other definition do you consider is appropriate, and
why?
We agree with the definition. Such small sites have the potential to provide many
opportunities for the arts and cultural sector to contribute to the development of new
housing, the provision of employment opportunities in the sector, and provision of new
community services.
Q10. Do you consider that national planning policy should set out that local
planning authorities should put in place a specific positive local policy for
assessing applications for development on small sites not allocated in the Local
Plan?
Yes, and with particular reference to innovative quality design to maximise space and to
ensure beneficial orientation of buildings to meet the needs of local people in terms of their
health, social and cultural well-being. We will encourage and advise local authority
partners to engage with arts and cultural organisations in the review of their Local Plans
and in the development of policy guidance for assessing applications for development on
small sites not allocated in the Local Plan.
The NPPF(Achieving sustainable development section) states the importance of health, social and
cultural well-being:
There are three dimensions to sustainable development: economic, social and
environmental. These dimensions give rise to the need for the planning
system to perform a number of roles:
● an economic role – contributing to building a strong, responsive and
competitive economy, by ensuring that sufficient land of the right type is
available in the right places and at the right time to support growth and
innovation; and by identifying and coordinating development
requirements, including the provision of infrastructure;
● a social role – supporting strong, vibrant and healthy communities, by
providing the supply of housing required to meet the needs of present and
future generations; and by creating a high quality built environment, with
accessible local services that reflect the community’s needs and support its
health, social and cultural well-being; and
● an environmental role – contributing to protecting and enhancing our
natural, built and historic environment; and, as part of this, helping to
improve biodiversity, use natural resources prudently, minimise waste and
pollution, and mitigate and adapt to climate change including moving to
a low carbon economy.
The use of supplementary planning documents to reinforce the need for good design is set out in
the NPPF also:
Supplementary planning documents: Documents which add further detail to
the policies in the Local Plan. They can be used to provide further guidance for
development on specific sites, or on particular issues, such as design.
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Supplementary planning documents are capable of being a material consideration
in planning decisions but are not part of the development plan.
From the NPPF the ministerial forward states the importance of cherishing local places and using
good design to ensure standards are developed:
‘Our historic environment – buildings, landscapes, towns and villages – can better
be cherished if their spirit of place thrives, rather than withers.
Our standards of design can be so much higher. We are a nation renowned
worldwide for creative excellence, yet, at home, confidence in development itself
has been eroded by the too frequent experience of mediocrity.
So sustainable development is about positive growth – making economic,
environmental and social progress for this and future generations’.
In pursuance of the policy set out in the NPPF, we would welcome the opportunity to work
with government to develop advice and guidance around the role of the arts and culture in
housing developments, and to work with other professional partners such as the RIBA on
design quality guidance.
Q11. We would welcome your views on how best to implement the housing delivery
test, and in particular:
• What do you consider should be the baseline against which to monitor delivery of
new housing?
• What should constitute significant under-delivery, and over what time period?
• What steps do you think should be taken in response to significant under-delivery?
• How do you see this approach working when the housing policies in the Local Plan
are not up-to-date?
N/A
Q12. What would be the impact of a housing delivery test on development activity?
d) Supporting delivery of starter homes
N/A.
Q13. What evidence would you suggest could be used to justify retention of land for
commercial or similar use? Should there be a fixed time limit on land retention for
commercial use?
N/A
Q14. Do you consider that the starter homes exception site policy should be
extended to unviable or underused retail, leisure and non-residential institutional
brownfield land?
N/A
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Q15. Do you support the proposal to strengthen the starter homes exception site
policy? If not, why not?
N/A
Q16. Should starter homes form a significant element of any housing component
within mixed use developments and converted unlet commercial units?
These sites will be of particular interest as live/work units for Artists, craftspeople, digital
artists, designers, creative media start-ups including those making objects for the market,
and arts organisations requiring rehearsal and production spaces prior to touring eg
theatre and circus companies, and dance companies. There is a shortage of live/work units
and studio spaces in the London region in particular (source Mayor of London, and London
authorities). Mixed use developments are also of considerable interest to creative people
who aspire to home ownership and who would like to work in proximity to living space and
transport links.
Q17. Should rural exception sites be used to deliver starter homes in rural areas? If
so, should local planning authorities have the flexibility to require local connection
tests?
N/A
Q18. Are there any other policy approaches to delivering starter homes in rural
areas that you would support?
For rural areas in particular we recommend the development of economically and environmentally
sustainable work/live units that will encourage micro businesses and SMEs, and this will be of
particular interest to social media, technology start-ups, and create industries.
Rural communities are successful when those living there are able to access a full range of
services, economic opportunities and opportunities for engagement. Arts and culture is as
important to realising success in rural areas as much as in urban areas. The public library network
is vital in building strong rural communities, and community facilities such as libraries, village halls,
co-located public service hubs and pubs are crucial elements in providing opportunities for people
to engage with culture. Cultural tourism is increasingly important in rural areas such as Cumbria,
Cornwall and Kent, and central to economic vitality. Full consideration of the potential of the arts
and culture through planning policy in rural areas will provide positive opportunities for growth.
Q19. Should local communities have the opportunity to allocate sites for small scale
starter home developments in their Green Belt through neighbourhood plans?
Local government should be further consulted on this.
Q20. Should planning policy be amended to allow redevelopment of brownfield sites
for starter homes through a more flexible approach to assessing the impact on
openness?
e) Transitional arrangements
N/A
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Q21. We would welcome your views on our proposed transitional arrangements.
f) General questions
We would like to see the review of Local Plans and or the addition of Area Action Plans include
consideration of micro businesses, SMEs and start-ups in the creative and media sector.
Q22. What are your views on the assumptions and data sources set out in this
document to estimate the impact of the proposed changes? Is there any other
evidence which you think we need to consider?
Consider the growth of the creative and media sector, and the families and communities
who are/will be looking for housing and live/work units in both rural and urban settings.
Please refer to creative industries data provided above.
Q23. Have you any other views on the implications of our proposed changes to
national planning policy on people with protected characteristics as defined in the
Equalities Act 2010? What evidence do you have on this matter?
The impact of these policy changes are likely to be beneficial to people under 40yr including
people with protected characteristics. There is negligible impact, beneficial or otherwise, for
people with disabilities.
People with disabilities and people from ethnic backgrounds receive lower salaries (Equalities and
Human Rights Commission (EHRC) – How Fair is Britain? Report 2010). On page 7 of the
Equalities statement the reasoning that people from ethnic minorities may be disadvantaged
economically but advantaged by aspiration to home ownership appears weak. The costs of
deposits and mortgage rates can and do prohibit home ownership amongst low income
households, of which disabled people and people from ethnic backgrounds are disproportionately
represented in comparison with other members of the population.
Lorraine Cox
Senior Policy Officer, Policy & Research
Arts Council England
2nd Floor
21 Bloomsbury Street
London WC1B 3HF
Tel: 020 72689628
NB-Work days: Monday, Tuesday, & Thursday only.
Alternative contacts: Jennifer Ngyou 020 7268 9609 or Nicole McNeilly 0207 2680506
Arts Council England’s office in London has moved to Bloomsbury Street
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