In its Election Manifesto the Labour Party announced its commitment to “Planning reform to build 1.5 million new homes” by, among other things, reforming the National Planning Policy Framework (NPPF), which serves as the rule book for Local Planning Authorities (LPAs), such as Guildford Borough Council (GBC). On 30 July the Labour Government launched a public consultation on an amended NPPF, which runs until 24 September.
Many of the changes are detailed and technical and quite hard for non-professionals to understand. We do, though, recommend looking at the consultation document to get a broad understanding of what is on the table. For those interested, there are some excellent blogs and explainers to be found on the website of planning consultants Lichfields. More critical initial responses can be found on the website of the CPRE and the Community Planning Alliance. (We also recommend this podcast from ‘The Expert Factor’, recorded before the General Election: “Can the Next Government Fix the Housing Crisis?”)
We are not able to cover here all the proposed changes, but we do believe, in the light of our involvement with planning issues in Normandy over the years, that the Government’s proposals represent something of a missed opportunity, and we shall be reflecting this in our own individual responses to the consultation. To expand:
· - The housing situation in our country is a national scandal, and doing nothing about it is simply not an option. We should be ashamed that so many people are obliged to live in substandard accommodation, and that young people face such huge difficulties trying to get onto the housing ladder. So, the Government is to be applauded in putting the problem so high up its agenda. Not all these problems are the fault of the planning system, though, and the proposed reforms must be seen in the broader social, economic, and political context. It is here that we believe they fall short.
· - Rather than start with the question “what kind of communities do we want to live in, and what mix of housing (houses, flats, freehold, leasehold, social housing, etc), in what kind of places, will enable all of us to live in healthy communities and in homes we can afford?”, the approach is purely target-led: all LPAs must just build more homes, period. We believe a relentless pursuit of these targets will not only probably fail but will have serious unintended consequences for both the natural and the built environment.
· - Nor is this approach conducive to regional development and reducing inequalities, as an uplift is to be applied to housing targets where the affordability gap is greatest (mainly in the Southeast, where under the proposals the overall housing target increases by 74%), as opposed to trying to shift jobs away from where housing pressures are greatest. It also rests on the misplaced assumption that increasing supply will result in lower prices, whereas at least as important a factor is purchasing power, including subsidies. Building more homes in the Southeast will be like adding more lanes to the M25; sooner or later we will just need more, but we won’t have addressed the core of the problem.
· - More fundamentally, the Government’s plans assume that market mechanisms can deliver affordable housing for all, which we simply do not believe to be the case. We have a crisis of affordability in this country as much as a crisis of building, and history shows that the only way to address that is by creating social housing that is at least in part funded by the taxpayer. Leaving this responsibility in the hands of the big developers all too often allows the latter to wriggle out of their affordability commitments on grounds of (non)’viability’, and the affordable homes simply do not get built. Whether it be Councils, Housing Associations, or private developers that build them, they won’t be ‘affordable’ in any meaningful sense without a substantial degree of public subsidy.
· - We are therefore disappointed that the Government has not been more radical and courageous in addressing the stranglehold the big developers have on the housing market – with their estimated 1 million unbuilt planning permissions, their reluctance to build on brownfield sites, and the ease with which they succeed in slipping out of their commitments on affordable homes. They are driven by different objectives, and we fear that they will be very good at playing the new system to their advantage, while there is little in these proposals to encourage the smaller builders. This will drive the latter into often inappropriate ‘infilling’ in existing settlements, where – as we have seen locally - good design principles are often neglected as developments are over-massed and quality takes second place to quantity.
We turn now to what these changes are likely to mean for us in Normandy:
· - Under the proposed NPPF changes to the method for calculating housing targets, Guildford Borough’s housing target would move from the current 743 per year to 1,102 per year, i.e. an annual increase of 359, or 48%. Over 5 years this adds up to an additional 1,795 dwellings (which could well bring back into play the so-called 1100 home ‘strategic site’ that was initially proposed for the entire area between Westwood and Glaziers Lanes during the Local Plan process).
· - LPAs can still make a case for a lower target, but under the new regime it will be much harder for them to do so. To succeed, they must demonstrate that they have optimised density, shared need with neighbouring authorities, and reviewed Green Belt boundaries. In the case of Guildford this may make it harder for GBC to resist high buildings in the town, may create a stronger obligation to accommodate targets set for neighbouring Boroughs, such as Woking, and will certainly create significant pressure on existing Green Belt boundaries (bearing in mind that 89% of our Borough is Green Belt; new compulsory purchase powers will support this as well).
· - There is also a proposal to introduce a new category of ‘Grey Belt’, i.e. previously developed land and any other parcels that make a limited contribution to the Green Belt (which risks being a very subjective judgment). At the same time the rules on ‘limited infilling’ and building on ‘previously developed land’ would be relaxed. In Normandy the effect of these changes would be to create a real threat to the open spaces that separate the five current settlements of the Parish and make an important contribution to the openness of our Green Belt.
· - The new NPPF includes a sequential test for development land of brownfield, previously developed greenfield, and then high performing green belt which could be made more sustainable. For the latter the consultation document gives the example of land around train stations which is clearly of concern for Normandy. Such a sequential test is a well-established planning rule for out-of-town shopping vs. town centre shops which has been well manipulated over the years by developers with deep enough pockets to employ consultants to argue their case with underfunded and under-resourced LPAs.
We find it depressing that much of the public discussion so far around these proposals has characterised them as kickstarting a battle between progressives and ‘nimbys’, i.e. people who support development as long as it doesn’t happen anywhere near them. We also believe that the weight attached to building more homes in the Green Belt, and the suggestion that anyone who is concerned by this is a ‘nimby’, is deeply unhelpful. The importance of preserving our precious green spaces for present and future generations is obvious, and no one should be apologetic about it. We can and should be trying to build more homes and protect the environment. This is our natural heritage, and once we lose it, we cannot get it back.
The coming months will be critical in determining the success or otherwise of the Government’s initiatives on the housing front. The results from the NPPF consultation will feed in to the Planning and Infrastructure Bill announced in the King’s Speech, which is also expected to include proposals for a series of New Towns, providing further houses over and above those required by increased targets for LPAs. We shall post further articles as these plans take shape.