Finally the long awaited Housing White Paper (HWP) has arrived. The planning world has met it with the usual mix of disappointment and relief. Disappointment that it didn't go far enough and relief that it didn't worsen an already difficult situation. 1.Plan-making In terms of plan-making, we can look forward to a standardised approach to assessing housing requirement. Unfortunately for those of us trying to get a plan produced, this will need to undergo its own consultation but our plans will need to be based on this standardised calculation if adopted after April 2018. Here's hoping that the consultation is soon and swift. Annual five year housing land supply sign offs have been proposed to assist those areas that have marginal land supply situations and a new definition of 'sound' and 'presumption in favour of sustainable development' have emerged.
Councils would always have been expected to review their plans every 5 - 10 years but the requirement to do so on a 5 yearly cycle is helpful. A requirement to have an up to date plan meeting the housing requirements of an area is not new but the means of doing this is now to be more flexible and designed to provide the best way of accelerating housing delivery. The core principle for a plan will be that it clearly sets out how the strategic objectives for the area will be met. The means of producing this plan can be by individual authorities or a group of authorities but where there is unmet housing need in an area there will need to be a statement of common ground (SOCG) that clearly stipulates how the need will be accommodated. By all accounts the SOCG should really be a joint strategic plan.
In accepting that Neighbourhood Plans could be the local level of the development plan in some areas, it is encouraging that the HWP expects them to set out how they will meet a housing requirement. The housing requirement would be set out either in a joint strategic plan or a local plan and would presumably be subject to the same housing delivery test including the expectation to work with the developer to agree timescales and delivery rates.
2. Land availability and delivery There is a renewed ambition to find land in the right places. This means that Councils need to find even better reasons to release green belt land, the principle of minimum densities in urban areas and brownfield first is strengthened and there is a requirement for 10% of allocations to be on sites of 0.5ha or less. This has the combined effect of trying to make all local planning authorities fill the spaces in their administrative boundaries first and also encouraging the diversification of the housebuilding market.
Knowing who owns or has control over land is seen as a way of freeing up land. There will be a move to improve the transparency of land registry entries and also the nature of options over land. With this knowledge LPAs will be expected to be innovative and ambitious in the way in which they produce plans and assemble land to deliver them.
Of significance is the return to the ability to form locally led development corporations charged with the responsibility for delivering development across a planned area. The funding of such an arrangement and the means of delivering the necessary infrastructure are not likely to appear until a decision has been taken about CIL and S.106. Aligned to this clear support for a place making approach to planning is the emphasis on design. There will be capacity funding to match a requirement for improved design policies from the strategic plan through to the neighbourhood plan.
3. Build out For local government, the increase of fees by 20% from this July will help to alleviate some of the unintended effects of wider austerity measures. The possibility of further increases for areas with higher housing delivery is also a sign that the government realises the additional resource that is necessary to make this happen. As always the devil is in the detail. Will higher housing delivery relate to housing trajectories or will it be based on a comparison model of numbers delivered overall. Delivering over the targets in your development plan is commendable but only if your targets are ambitious to start with.
LPAs will be encouraged to use the default two year timescales for permissions possibly using the anticipated delivery rate as a material consideration. This, together with the use of simplified completion notices and the expectation of agreed delivery rates and timescales could give Councils more control over their land supply. This only really works, however, if the Council has sufficient flexibility within their development plan to release other sites on the basis of under delivery. As with everything in planning, it has to be understood as an end to end system rather than as individual parts.
The housing delivery test will be introduced and where the number of homes being delivered is under the expected number there will be a mechanism for establishing why there is an under delivery, the introduction of an action plan to remedy the under delivery and also a strengthened 'presumption in favour' definition to ensure that further land is released. If this had been introduced as a replacement for the 5YHLS test then I could understand how this might operate.
To have the housing delivery test layered on top of the 5YHLS test seems to work against the principles of a plan-led system. For me, the housing delivery test promotes the plan-led system in terms of encouraging Councils to allocate more land then they need to allow for plan-led flexibility. The 5YHLS test works against this by punishing under delivery with unplanned sites.
4. Affordable housing One of the best aspects of this HWP for me is the realisation that rental properties have a significant role to play in terms of housing our communities. The wider array of tenancies that are now being promoted for inclusion within the revised affordable housing definition will help both the private and public sector to find the appropriate mix for each available site.
With all of these measures comes a package of £25m capacity funding, the Housing Infrastructure Fund and the accelerated construction fund to help us all work together to achieve growth.
Whilst there are unanswered questions in the HWP about how a lot of this will work, it is encouraging to see how much the thinking has moved on and a recognition that delivering for our communities is a joint responsibility between public and private, rather than public bureaucracy being seen to hold back private aspirations.
The POS have valued the opportunity to engage with our colleagues at DCLG in the writing of this HWP. I look forward to our future discussions as some of the detail emerges. I will be looking for feedback from our members to inform our response to this consultation over the coming weeks. Anna Rose, President 2016/17