Headlines from the Government’s consultation on ‘Planning for the right homes in the right places’
DCLG has launched the ’Right Homes Right Places’ consultation seeking views from the development industry on a number of changes to the planning system. Some of these changes are intended to be brought into effect through a revision to the National Planning Policy Framework in March 2018, others may come into effect through legislation changes.
We discuss and comment on the ‘hot topics’ stemming from the consultation.
Approach to calculating local housing need
A new standardised approach for calculating local housing need is proposed. This aims to simplify the current process which is considered costly and time consuming. The new approach will link housing delivery targets with the relative affordability of housing within the Local Authority Area. A three step approach is proposed:
- Step 1: Setting the Baseline – the starting point will continue to be a demographic baseline taken from ONS projections for household growth;
- Step 2: Adjustment to take account of market signals – affordability ratios (provided by the ONS) will be applied to the baseline figure. LPAs with particular housing affordability challenges will have their housing delivery target adjusted upwards, and
- Step 3: Capping the level of any increase – to ensure the method is deliverable a cap will be applied to the overall figure. The nature of the cap will depend on the age of the adopted Development Plan.
Is this really the end to debates on OAN? The objective is to ensure there are enough homes available in each area which the average person, earning an average salary, can afford to buy. But will this actually result in more homes being built in areas where affordability is low? In our opinion, the proposed methodology has similar limitations to existing SHMA’s in that it is just one part of the plan-making process. The Framework currently states that Local Plans should be evidence-based, and take account of local economic, social and environmental characteristics and it seems unlikely that this principle will change. This means that uplifts and adjustments are still likely to be required to take account of local circumstances, leaving much scope for debate on landscape and environmental issues when it comes to Examination.
Transitional arrangements will be brought forward for the introduction of the new methodology from March 2018. The arrangements will vary depending on what stage the LPA has reached in the plan-making process. However, at a recent Inquiry in Durham the LPA suggested that it could demonstrate a 5yr HLS using the new methodology. This was given little weight by the Inspector who ruled that it was subject to consultation and could conceivably change. Leeds Council has also announced a delay to its Local Plan Examination to mull over the implications of the proposed methodology which, if carried forward, could see a reduction in requirement of 28,000 homes.
The standardised methodology will only provide a housing requirement for a 10 year period, and so we may therefore see a change to the current 15 year timeframe of Local Plans. This may also lead to early reviews of Local Plans in areas that are currently committed to delivering higher numbers than would be the case under this standard methodology.
Strengthening Duty to Cooperate
It is proposed that all LPAs will need to agree Statements of Common Ground with their neighbours about key Local Plan issues such as delivery of housing and key infrastructure. We welcome this requirement, which appears to be a form of regional planning, and promoting joined up working on a regional/sub-regional scale.
Planning for a mix of housing needs
This proposes to update existing guidance on planning for the different sizes, types, tenures and range of housing required, seeking to disaggregate the total housing need into the overall need for each type of housing as part of the plan-making process. This will mean that as a Plan develops, plan-makers will have to make evidence-based planning judgements on the different types of housing that are required in their area, to ensure that the Plan is both effective and positively prepared. We are interested to see how this will impact planning for all forms of housing, including homes for the elderly in the form of assisted living and care homes.
Neighbourhood Planning changes
Where neighbourhood planning groups are not provided with an up to date housing need figure by the LPA the Government is proposing a new formula based approach. This would calculate the population of the neighbourhood planning area as a percentage of local authority area population and then effectively allow pro rata calculation of the district’s overall housing requirement. This is an interesting development and appears to recognise that NDP’s can be prepared in advance of Local Plans.
Viability assessments overhaul
To address concerns about ‘gaming’ and complexity associated with viability assessments, the Government is suggesting that the viability of delivering affordable housing and local infrastructure is better addressed by LPAs in their Local Plans, reducing the scope for viability to be considered at the application stage. Simplifying viability assessments and making them more transparent for the general public is also suggested, including better publicity about how and where developer contributions are delivering community benefits. We are concerned at how accurate and reasonable assessments of site specific viability can be done at plan-making stage when there are a number of variables to be taken into account which can change overtime.
Application fees up 20%
It is anticipated that a 20% rise in fees for all application types will come in by the end of this year. However, the consultation is seeking views on a possible further 20% increase for those LPAs who are delivering the homes their communities need i.e. rewarding top performing Authorities. The rise in planning fees by the end of the year will be of interest to many with schemes in the pipeline.
Improving Build Out rates
Proposed measures to close the gap between the number of homes approved and build out rates include tools to hold both LPAs and developers to account for delivery of new homes. LPAs could see policy changes which enable an applicants’ track record to be taken into account in determining applications for large sites; potential to shorten timescales for implementation to 2 years; and simplification and speeding up of the completion notice procedure. For developers, the introduction of the Housing Delivery Test could open more doors for development in areas where the LPA is under-delivering. We support the delivery of good development and so in principle these changes are welcomed, but how will an applicant’s track record be measured particularly when some have been grappling with complex sites and or periods of economic downturn?
The consultation runs until 9 November 2017 and further details can be found HERE
Get in touch?
This is intended as a general overview only so if you would like to know more on any of the hot topics, or you want to talk through with us how these changes might affect your specific project, please contact us on: 01794 368 698 or firstname.lastname@example.org