We have reviewed in detail the Department for Communities and Local Government’s ‘Planning For the Right Homes In The Right Places’ consultation document and are now giving our views.
Bidwells has said that whilst it wholeheartedly supports the objectives of the consultation to simplify, speed up and make more transparent the plan-making process, it feels that the proposals are unlikely to be successful in a number of respects.
In particular it has considerable reservations over the proposed new standard methodology for calculating the full objectively assessed needs for housing which it feels will fail to boost the supply in line with the aims of the Housing White Paper.
It is concerned about the absence of consideration of economic objectives which means that the proposed methodology is inconsistent with the Government’s aim to boost growth in the Northern Powerhouse and Midlands Growth Engine, stifling growth in these areas. Given the extent of the increase in the housing requirement in and around London, with the proposed methodology there is also a risk of delivery falling short of the need in London and to a lesser extent, the South East.
As a result the standard methodology is unlikely to significantly boost housing supply and could have the opposite effect.
Another of Bidwells’ concerns is the arbitrary use of a single test for housing market signals based on a single year’s data which has the potential to skew results from one year to the next. This, taken together with the underlying Subnational Population Projections and Household Projections changing every two years, will result in data volatility, leading to greater uncertainty and making plan-making more difficult.
Because of the use of limited market signals information and single year data sets, along with the imposition of the cap, it will not in many cases provide a realistic and objective assessment of housing needs.
David Bainbridge, Divisional Partner Planning said:
Our team has reviewed the DCLG Consultation in depth and has a number of serious concerns about the way it is proposing to tackle the assessed need for housing. The standard approach is too simple and ignores fundamental variables that influence local housing markets including geographical factors. The proposed approach might exacerbate regional disparities and be detrimental to delivery.Several elements are excluded, such as the analysis on employment trends in relation to the assessment of housing need which is likely to see many areas in the north of England having a significant reduction in the calculation of their housing need figures, reducing requirement and delivery. Neither is there any consideration of affordable housing need in the new methodology or allowance for vacant or second homes.
In summary we have grave reservations about the new methodology proposed by DCLG and do not believe it will increase delivery, if at all. It does not fit within the definition of ‘full objectively assessed needs for housing’ as it does not consider need and is not objective.
As a result of our concerns, we have produced our own outline of a different methodology that we believe is in keeping with the overall objectives of the assessment and would welcome the opportunity to work with the DCLG and others to arrive at a definitive methodology that can be implemented with minimal further delay.
- Neil Waterson, Partner, Planning
- Simon Elliott, Associate, Planning
- David Bainbridge, Partner, Planning