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Take a deep breath… and let’s talk housing targets. I know, I’m sorry.
Working in any industry even mildly associated with planning and development, you would have found it difficult to miss the raft and significance of changes proposed to the UK planning system. These would be implemented through updates to the National Planning Policy Framework (NPPF) and the Levelling Up and Regeneration Bill which is currently being examined by Parliamentary Committee. In the interim, we remain in the midst of a housing crisis where we have set up home for a number of years now. It should be no surprise, therefore, that some of the most significant of those changes proposed as part of the reforms relate to the provision, design, and delivery of housing.
One of the most striking of the proposed changes to the NPPF is the proposed removal of the five-year housing land supply position for those local authorities with an up-to-date Local Plan i.e. those which have been adopted or updated in the last 5 years. The anticipation is that this will give local authorities more flexibility in how they deliver housing in their borough and will prevent speculative applications on unallocated sites being awarded at appeal due to a lack of housing land supply. One might understand the logic but we are in a housing crisis and have as yet been unable to meet the target for 300,000 homes a year and further changes in the NPPF ask that LPA’s “meet as much housing need as possible”. Restricting development that otherwise provides, in the planning balance, an acceptable housing land use on an unallocated site is only going to be of detrimental impact on housing numbers particularly over the coming years as the new plan making regime comes into force.
The removal of five-year housing land supply (5YHLS) figures is also intended to speed up plan-making but in March 2022, only 42% of LPAs had a fully up-to-date Local Plan. This means that if those figures stayed consistent, less than half of authorities will lose the need to identify FYHLS figures and the system would fail to provide the much needed flexibility, certainty, and delivery of housing. Furthermore, what incentive is there for LPAs to speed up their plan making that is not already there? It is not a commitment to the cause but a lack of time, resources, and an ever increasing workload on a small number of professionals who simply cannot produce an overarching Local Plan for a 25-year period with the resources in front of them? Removing the pressure of proving FYHLS does not change that. We have already seen pauses or delays to Local Plan making as a result of the proposed NPPF changes and this look set to continue until there is some certainty over the proposed reforms.
Revisions to the NPPF also require that most development is focused in the 20 largest urban areas and that those locations also allow for a 20% uplift in housing numbers. Alongside this, development must be well designed, and “beautiful” and not be “out of character”. Development is expected to meet clear design standards, reflect community views, strengthen environmental outcomes and expand protections for the places people value. It is difficult to understand how any already densely populated urban area can accommodate such significant year on year growth and not become out of character or create complex socio-economic and environmental challenges. In 2021, the 20 largest urban areas provided 28,000 net additional dwellings. This equates to an average of 903 dwellings per urban area in the same period and less than 10% of the national target. The reforms appear contradictory, unrealistic, and unlikely to address the ever increasing housing crisis.
If I were a cynic I might suggest there was some political motivation in the forthcoming proposals – like eliminating the ability to change Green Belt boundaries to accommodate housing – and instead pushing all the focus into already overburdened urban areas. Isn’t there a general election quite soon?
Unless we are planning to build our own island off the coast of Portsmouth -my vote is to do it in the shape of a beautiful British bulldog – I fail to see how the proposed reforms will get us any closer to a target of 300,000 dwellings a year.
I hope I am either proved wrong or I can take out a timeshare on the Island of Churchill.