The Government consultation on Planning for the Future (Build, Build, Build) ran until 29thOctober last year and proposed sweeping reforms of the planning system “to streamline and modernise the planning process.” The proposed reforms have been widely criticised by many as undemocratic, having the potential impact of largely removing the voice of the community on planning matters. I believe that the community voice should be at the heart of planning decisions. You can read the “Planning for the Future” White Paper here:
Some of the most shocking proposals (at the time of writing, still just proposals) included:
· Imposing a 30 month statutory timescale for producing a Local Plan (rather than c. 5 years).
· Removing the public examination stage of the Local Plan and replacing it by inspectors’ discretion, or self-assessment by the Local Authority (marking their own homework)!
· A word count limit for public responses on Local Plans.
· Delegation of detailed planning applications to planning officers with no public comment allowed.
· A zonal system of planning. “Protected” Areas would be subject to “restricted” development – but how “restricted” is “restricted?” The devil will be in the detail.
· Automatic outline planning permission for areas for substantial development, so called “growth areas.”
· Continuation of the outdated “Standard Methodology” for calculating housing need (see more below).
· Watering down of environmental protections, replacing EU directive assessments such as SA, SEA and HRA with an unspecified consolidated test of “sustainable development.”
· Discontinuation of site planning notices (e.g. lamppost notices). We've seen this proposal mirrored in Bucks Council's proposed Statement of (non!) Community Involvement, along with possible discontinuation of neighbour planning notification letters.
As you can see above, there were some very concerning proposals contained in the Planning White Paper, designed to strip away democratic input and these are now reflected in proposed planning changes which Bucks Council consulted on recently, namely:
· How biodiversity will be treated on development sites.
· How communities will be involved (or not) in planning matters, from planning applications to the Local Plan process.
I've written earlier blogs on both of these consultations.
While we wait to see the full outcome of the Planning White Paper consultation and its many spin-off planning policy consultations (possibly leading to legislation in the Autumn), I explain below how the Government’s “Standard Methodology” for calculating “housing need” works.
According to one of the top planning and development consultancies, Lichfields, for most authorities “it’s as you were” in terms of housing need figures:
According to an indicative Government spreadsheet (16thDec 2020), Chiltern District’s indicative Local Housing Need figure is 343, and South Bucks is 431 (NB the Government says these figures are not verified or definitive). An affordability uplift (and possible additional buffer) must then be applied to these figures, raising them substantially..
Aitchison Raffety consultants commented: “When applying the new standard methodology, for most local authorities outside of the 20 largest urban areas there is little change as the method remains as it was when first introduced in 2017 (which was based on applying the 2014 household projections, with a percentage uplift reflecting the price-income affordability of housing, subject to the 40% cap). The numbers are expected to change slightly due variations in affordability, although the ten-year period in which it is calculated and the plan related cap ensures a level of stability.”
This is how “housing need” is calculated according to the Standard Methodology:
Step 1 – set the baseline using national household growth projections (ONS figures) - these are out of date 2014 figures (housing projections have been falling steadily according to ONS but Government is ignoring this).
Step 2 – adjust the average annual projected growth figure based on affordability (add c 73% increase in S Bucks).
Step 3 - apply a 40% cap (how this is calculated depends on current status of relevant strategic policies for housing).
For 20 listed cities and urban centres uplift also add an additional 35%.
The Government responded to the consultation response (there were many critics). In particular, this Government response to the affordability uplift replies is interesting. The final bullet point hits the nail on the head. Additional dwellings built due to the “affordability uplift” allowing more house building, would not result in more affordable housing. Despite this, you will see below that the Government have retained the Standard Method for calculating hugely uplifted so-called housing "need" in its current form.
Conclusion - the housing "need" figures are not based in reality and the affordability crisis cannot be solved by the Government's failed affordable housing policy (the topic of a blog coming soon).
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