Housing targets
built on shifting sand Housing targets are a core part of local authority housing strategies, but confusing messages from central government have created uncertainty and left local authorities vulnerable to appeal from landowners and developers. On 24th July 2018 the government released the latest version of the National Planning Policy Framework (NPPF). The changes were vast but the topic which caused the greatest level of debate was how local authorities calculate their housing targets. The NPPF 2018 was supposed to create a greater level of certainty of how much housing was required. Unfortunately, it failed to deliver this certainty in the way we had hoped. The advice on the housing calculation failed to provide core definitions and details. Minor changes were introduced in February 2019 to help clarify the situation. This has resulted in further delays for authorities in the early stages of preparing their local plans.
What does this mean for local plans? The good news for authorities in the advanced stages of drafting their local plans was they were allowed to use the former NPPF guidance, if their plans were submitted to the Secretary of State by 24th January 2019. However this ‘grace period’ produced its own complications as many local plans were rushed through the system.
What does this mean for house builders and landowners? Unfortunately, these rushed plans are likely to require review almost as soon as they have been adopted. Therefore more local authority resources will be pumped into plan making and data collection, rather than focusing on delivering the large scale planning applications and infrastructure projects required. This may mean continued delays for developers. Also authorities are unlikely to be in a stronger position against speculative applications. Although there are clear downsides to this, it does provide continued opportunities for our clients who are looking to make speculative applications in broadly sustainable locations that may otherwise not be supported by the council. If you would like to know if these changes impact your land please contact our team for more information.
All local plans submitted by 24th January 2019 will be considered at examination against the March 2012 NPPF policies, which are now considerably out of date. Anything post 24th January 2019 will be assessed against the NPPF 2019 and must include the standardised methodology. Our main concern is that this has resulted in authorities rushing their plans through the statutory preparation process. This means their plans will either be found unsound at examination or, if adopted, they will only truly be sound and robust in terms of housing delivery for a number of months rather than years. These plans will either fail the examination process or will be too short term in relation to housing targets (with the promise of early reviews) to be truly effective. In the South East we witnessed Wealden, Tonbridge and Malling, Rother, Tandridge and Thanet all submit their local plans just in time for the January 24th deadline. Our planning team will be attending the majority of the examinations, representing a range of private landowners and developers. The sites we are currently representing in these areas could cumulatively deliver well over 1,000 new homes in highly sustainable locations.
LOCAL PLAN PROGRESS MAP MARCH 2019
Local Plan adopted pre August 2018 Local Plan submitted between August 2018 and 25th Jan 2019
Local Plan submitted pre August 2018 This map demonstrates the progress of Local Plan Local Plan under review but not yet submitted submissions in our core market area. It shows that a significant percentage of local plans were suddenly submitted between August 2018 and January 2019 to avoid authorities’ from having to reassess their housing targets to reflect the standardised methodology.
Harriet Richardson • harriet.richardson@batchellermonkhouse.com • 01892 509287 Rural Outlook 2019
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