WILL NEW BROOMS BRING FASTER SWEEPING?

With a completely new Ministerial team at DLUHC and press reports of the Levelling Up and Regeneration Bill being abandoned, it is perhaps tempting to feel doomy gloomy about how the planning system is going to support the much-needed increase in housing supply.
Not least because there are already 5 matters which are particularly irritating for housebuilders right now.

1. Nutrient neutrality is effectively a moratorium on housebuilding in large parts of 74 LPAs. Introduced without any consultation and without similar sanctions on those who create most of the pollution. No, the axe falls on housebuilders despite scant evidence that those who buy and occupy our homes create much additional pollution – having generally moved from elsewhere in the same catchment.
2. Changes to Part 0 of the Building Regulations require minor changes to the design of new homes to comply with new carbon performance obligations. All welcome BUT the guidance is that they all need to be the subject of planning submissions to regularise the change. Yup – no PD rights. So, massive extra work for housebuilders preparing submissions, and potential chaos in LPAs when this tsunami of minor applications land.
3. Housing targets are going to be abolished. Nothing for me to add to the excellent recent blog from Zack Simons ( https://www.planoraks.com/posts-1/stalinist-housing-targets ) and left wondering whether the LPAs who simply don’t want to build homes, (usually the ones where homes are needed most) will simply shut-up-shop. In fact, its already happening – 20+ local plans put on hold in the last few weeks alone. Not a good outcome for young families in need of a home where affordability is worst.
4. Housing mix policies – the pandemic has transformed how people use their homes and the space they need. Barratt is responding but often we can’t deliver what our customers need because of policies derived from some outdated pre-pandemic Housing Mix policy or Housing Needs Assessment. Is it really the role of the planning system to stop people getting what they need, in their home, following the massive re-set imposed by Covid19?
5. Working from home – perhaps an elephant in the room but it seems clear that whilst WFH is obvioulsy working well for some, its maybe not for the younger planners with a heavy Development Management workload. Somehow we need to enable them to get back to the meetings and face-to-face collaboration which often drives faster and better DM outcomes. Not easy, and maybe not popular, but perhaps necessary IMHO.

HOWEVER – the reality is that change is exciting and, as always, the planning, land and development sector has a great opportunity to present the evidence and arguments to achieve more homes. And, from a purely housebuilding perspective, to remind ourselves of the huge positives in play:

1. Levelling Up is right thing to do and its way too early to proclaim its death. As a northerner in a national role its a privilege to play a tiny part preaching the benefits of Levelling Up to people who aren’t yet converted.
2. Progress on digitisation by DLUHC is superb. It will be maintained and accelerated thereby transforming the art and science of town planning over the next 5 years. And very much for the better.
3. Looking longer term – its easy to grumble, but much has been achieved over the last 10 years. Important incremental reforms, driven hard by dedicated and talented civil servants such as, inter alia, Simon Gallagher and Steve Quartermain. We must never forget that the counter-factual is a world without deemed discharge, without NPPF Para 141, without a housing target for every LPA and without the Housing Delivery Test. A world where we would not be looking ahead to National Development Management Policies, 30 month local plan timescales and a Local Plan Commissioner. (Hopefully)
4. Despite the daily criticisms we face, the housebuilding sector is delivering some great things. At Barratt, the commitment of colleagues and senior leadership to ‘do the right thing’ is constantly energising. Whether that be our decision to transition to BNG ahead of regulation, the incessant progress along our route to net zero house types by 2030, or our massive increase in charitable giving.
5. And above all, our customers. It’s a massive privilege to help deliver a product which genuinely changes lives. The most important purchase of their lives. I’ve seen the joy that brings and will never lose sight of it. Often wish more people could.

STALIN VS NPPF

Firstly Liz Truss and then Simon Clarke – both declaring their intention to end Stalinist housing targets. Leaving us all pondering how will new homes be delivered in the areas of highest demand around our most successful cities? The areas benefiting from best access to public transport and jobs.

What we do know is that Stalinist targets, Green Belt, and housing delivery are intrinsically linked.

Current policy essentially says that you can’t build homes within Green Belt, but you can change a Green Belt boundary via a local plan review, providing there is a defined housing target and there has been a proper application of the sequential test in para 141 of NPPF.

In otherwords, taking sites out of Green Belt is OK if the defined target cannot be met by either (a) maximising brownfield capacity, (b) increasing density, or (c) exporting that need to neighbouring LPAs.

So, Barratt and others have secured control of sites within Green Belt. Not to build houses within the Green Belt, but to build houses outside it, once those sites have been removed from Green Belt, following the scrutiny of the democratic local plan process. The definition of the housing target, via the Standard Method, plus the application of Para 141, has helped inform where those releases may be.

But when the Johnson/Gove weathercock started pointing towards Chesham, and away from the housing affordability crisis, both Truss and Clarke responded by signposting the end of housing targets.

But will this really be a problem for housebuilders, or those in need of a home?

Outside Green Belt areas – and assuming that PINS is going to retain a role ensuring local plans are sound – the loss of the Stalinist targets will send us back to the future. We will go back to those local plan debates about what the housing need figure should be, pursuant to interminable discussions on affordability, homelessness, build rates, migration, jobs growth, household size, students etc etc etc. And guess what? The Alaska-sized spreadsheets will prove a need for many more homes.

On the assumption that PINS will then recognise that a local housing target which responds to local unaffordability is better for real people than applying a household growth forecast which projects forward the past symptoms of unaffordability, there should be scope to maintain and increase housing need figures in many areas. So lets all pray for PINS’ survival.

No – the problem is those pesky Green Belt areas. Without a Stalinist figure, and with the NPPF not being sufficiently clear that local needs should be met everywhere they arise, local housing targets will be slashed. Indeed, it is already happening. Over 20 LPAs by the start of September.

The rationale goes………….we can only build a few homes round here without changing Green Belt boundaries and we don’t want to do that and we don’t have a Stalinist target and therefore we won’t………”

But there are perhaps two rays of hope.

Firstly, we know Liz Truss and Simon Clarke have (a) previously been supportive of sustainable Green Belt releases and (b) also been careful in choosing their recent words about Green Belt. Talking about supporting LPAs who do not want to build within Green Belt. Conflating those two things perhaps points to a positive approach towards meeting locally defined housing need around our most successful cities, if the local plan process has demonstrated that the Green Belt boundary must change in order to meet those needs. Because there is insufficient brownfield and density capacity, and no neighbour agreement to send the new homes elsewhere.

From a Barratt perspective we don’t assume you can build within Green Belt but we do assume that boundaries can be changed by the Development Plan if it is necessary to do so.

And secondly, there will remain some LPAs who recognise the value of new homes to address the housing crisis and support economic growth. Newcastle has consistently reviewed Green Belt boundaries in line with NPPF advice. With the right national policy many others will do the same.

Guess we are all eagerly awaiting the new NPPF prospectus. Glass half full anyone?