Matt Hare, Partner at Carter Jonas (Cambridge), discusses the consequences of an absence of housing targets on levelling up and regeneration.
Under its many guises — three Prime Ministers and three Secretaries of State for Levelling Up, Housing and Communities — the current Government has been resolutely committed to growth. But to varying degrees, those responsible for housing delivery have edged away from the 2019 manifesto pledge to deliver 300,000 homes per annum. Liz Truss set out to remove so-called ‘Stalinist’ housing targets; whilst until recently, Michael Gove, as the re-appointed Secretary of State, has been more acquiescent, suggesting that that the target remained but the calculation and implementation would be ‘rebased.’
Housing need
We now know that Gove’s proposition is in fact not to tinker with the Standard Method for calculating housing need just yet. Instead his proposals (as set out in the draft revisions to the National Planning Policy Framework) are potentially more extreme. To recap, the key proposed changes regarding housing targets 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 clear evidence of past over-delivery in terms of the number of homes permitted compared to the housing requirement in the existing Local Plan. In such cases this over-delivery may be deducted from the provision required in the new Plan.
- Green Belt boundaries would not be required to be reviewed and altered if this would be the only means of meeting the objectively assessed need for housing over the Plan period. It will be a matter for the individual local planning authority (LPA) as to whether such a review takes place.
- The duty to co-operate would be replaced by a future ‘alignment policy’, and plans will no longer be required to be ‘justified’.
- 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 four years’ housing land supply instead of five years for a period of two years from the point that the proposed changes to the Framework take effect.
Potential impact
The stated purpose of these proposed changes is to provide more certainty that authorities can propose a plan with a housing requirement that is below their local housing need figure. So, in effect, planning for fewer homes. The consequence being that these deliberate steps will allow the needs of future generations to go unmet.
Whilst some may welcome these proposals, many will lose out. Unfortunately, it is more likely to be the more vulnerable, by which I mean those a) looking to get on the housing ladder, b) looking to find a reasonably priced rental property, c) on waiting lists for affordable housing or d) in need of other forms of specialist accommodation.
For example, consider the ‘Green Belt’ authorities in Oxfordshire, Cambridgeshire and the Home Counties. These are areas where housing pressures are some of the most acute in the country. In many instances the key cities and settlements in these areas are surrounded by Green Belt meaning that one of the primary ways of meeting needs is to review Green Belt boundaries. In other instances, reviewing Green Belt boundaries is necessary for the delivery of a sustainable growth strategy.
Such is the nature of many people’s misconception of what the Green Belt actually is, and the way this often transposes into political pressure from a vocal minority, the danger is that some local authorities will take the easy route and seek to duck a Green Belt boundary review.
The same can equally be said of housing delivery generally. So often the protestations of a vocal minority distract local politicians from the important task of actually delivering for the more vulnerable groups within their constituencies. These potential changes to the NPPF offer some new, helpfully nebulous reasons to local politicians to justify a failure to meet local needs.
Of course, not all local authorities are looking for reasons to suppress housing delivery. The reality of the situation is more complex — it is rare to find a local planning department that is not grappling with the almost unresolvable twin issues of heavily squeezed budgets and staff shortages. In this regard it’s fair to say that many local authorities simply don’t have the resource to critically assess difficult strategic planning issues and effectively promote growth strategies to the local population.
Housing shortfall
The need and demand for new housing, affordable housing and specialist accommodation does not dissipate, however. Young people will still be drawn to economically successful parts of the country. If the homes are not available for them to occupy then we risk either perpetuating unsustainable travel patterns or the continued success of those areas, by cutting off the supply of new talent to the local industries.
Likewise, those on the waiting lists for social housing do not disappear simply because the door may allow authorities to plan for less. Such people still need places to live, often urgently. Older people still need specialist accommodation with
care, something that we are already failing to deliver in anything close to the levels needed.
Regardless, we are already beginning to see some paralysis of plan making in the wake of the consultation on the proposed changes to the NPPF. This follows the similar effect that the last few years of government messaging has yielded, leading some commentators to the speculate that England will see a shortfall of up to 100,000 new homes over the next five years. Given all the other challenges facing the country at present, this is precisely the sort of own goal we could desperately do without.
Matt is a Partner in the Carter Jonas Cambridge Planning and Development team and has been a planning practitioner since the early 2000s, working in both the public and private sectors.
