Missing the target
Far from delivering the 300,000 homes per year target, proposed national planning policy changes weaken the link between housing need and housing targets, with significant downsides. Pete Canavan, partner, Carter Jonas (Oxford), reports.
Following the general election in 2019, the Government promised a radical shake-up of the planning system. However, three Prime Ministers and three Secretaries of State for Levelling Up, Housing and Communities later – little about the proposed changes to date could be considered ‘radical’.
This is exemplified in the long-awaited prospectus for revising the National Planning Policy Framework (NPPF) which was published on 22 December 2022.
The stated purpose of these proposed changes is to provide more certainty to enable local planning authorities (LPAs) to propose a plan with a housing requirement that is below their local housing need figure. So, in effect, planning for fewer homes.
The Government’s proposals regarding housing targets, as set out in the draft revisions to the NPPF are:
- Proposed additional caveats would allow for lower levels of housing to be planned in situations in which meeting full needs would result in “adverse impacts,” such as building at densities “significantly out of character” with the existing area, or where there is “evidence of past over-delivery.”
- Green Belt boundaries would not be required to be reviewed and altered if this would be the only means of meeting housing need.
- Where the housing requirement is less than five years old, LPAs would no longer have to demonstrate a five-year housing land supply.
- Some LPAs with well advanced Local Plans will only need to demonstrate 4 years’ housing land supply instead of 5 years’.
No specific changes are proposed to the standard method for calculating housing need yet, but it will be reviewed to take into account the standard method of new household projections data (based on the 2021 Census), which is due to be published in 2024.
Confusing need and housing targets
Far from radical, these proposals are contradictory. The Government target of 300,000 houses per year remains, but with no pressure on LPAs to commit to targets, it cannot be met.
It appears that housing needs, and the fundamental human right to shelter, are being confused with housing targets. The standard method for assessing local housing need – poorly conceived as it is – is a route to identifying a minimum need figure necessary to prevent a rise in homelessness, rather than a growth aspiration. When I see ‘need’ and ‘targets’ used interchangeably in Government I am concerned that strategic planning was not fully understood in the drafting of these important documents.
Gove has been quoted as saying that the Government will consult on the standard method for calculating local housing need and that the derived figure will be an advisory starting point. Failure to meet need is not a failure to meet an aspirational objective: it is a failure to provide for the underprivileged. Providing for need should not be a matter of choice.
This directly contradicts the current NPPF, which states that Plans are ‘sound’ if they provide a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs.
Paralysis in the planning system
The impact of the possible removal of housing need figures has already been felt throughout the country: there are many examples of progress on Local Plans having been stalled.
Furthermore, last October the Home Builders Federation wrote to the Office for Budget Responsibility expressing concern that abolishing targets would lead to 100,000 fewer new homes each year, a £17 billion reduction in economic activity and a fall in the funding available for affordable housing of £2.8 billion. Its research demonstrates the number of new homes to be delivered in coming years would be the lowest since the years following the global financial crisis.
Lack of encouragement to meet targets
This stalling of strategic planning is inevitable as politically, as well as at a community level, ‘carrot and stick’ comes into play. Without the ‘stick’ of penalties if housing targets are not met, only the ‘carrot’ of planning gain remains. This will not be enough to incentivise development in those areas which resist new homes. In carrying out public consultations – on Local Plan allocations or planning applications – we always face questions about whether new housing is necessary. Currently, mandated targets provided the answer; in the absence of a target, it will be harder to demonstrate housing need.
Conclusion
As most planning professionals would agree, strategic planning is crucial to delivery. Failure to plan is to plan to fail. And the only target that is likely to be met by these reforms is the political target of appeasing local councillors and NIMBYs.
Unfortunately, the consequence of this change will be a lack of homes for the more vulnerable, those looking to get on the housing ladder, looking to find a reasonably priced rental property, on waiting lists for affordable housing or in need of other forms of specialist accommodation.
For more information on Carter Jonas, please visit www.rdr.link/xxx
