DLUHC’s Christmas Bundle.

The annual DLUHC Xmas gifts came on the 19th December this year, and a bigger than usual bundle – Finalised NPPF, Response to Draft NPPF, Ministerial Speech and Statement, HDT results, PPG changes and a Naughty Step list of LPAs facing sanctions.

But what does it all mean for housebuilders (and others) who want to secure more planning consents and build more homes. The Lichfields research, “Making a Bad Situation Worse, for HBF & LPDF indicated in February that Draft NPPF would lead to 77,000 fewer homes per annum. With limited change from the draft, and the absence of the promised rebuttal from Racheal McLean, it seems that the key impact of NPPF will be fewer new homes.

Beyond that headline, some personal observations on the overall package:

1. Mr Gove said planning is noble. This is welcome and accurate – LPA officers generally do great work in very difficult conditions. But calling LPA planners noble whilst introducing policies which potentially make their job harder does seem odd. Demanding much faster planning applications, much faster local plans and fewer officer overturns is great but perhaps needs to come alongside a clear plan of financial, operational and cultural change proposals to make it happen. A few extra millions and a supersquad perhaps won’t cut it.
2. A key cause of the difficulties for planners and housebuilders is uncertainty. The LPAs who just don’t want to build homes love uncertainty and they feed off it. What better reason to stop a Local Plan or refuse consent on an allocated site than uncertain ever changing Government planning policy. Unfortunately the finalised NPPF indicates that, a) LPAs can (or cannot) meet housing needs, b) LPAs can, but don’t have to, review Green Belt and c) we should densify our urban areas but not if it isn’t beautiful.
3. The changes to Green Belt policy are seismic. Talk of tinkering is nonsense. The change to enable LPAs to avoid reviewing Green Belt to meet housing needs will hugely reduce the amount of land released for homes. Why? Because Green Belt Reviews tend to throw up housing opportunities. If you don’t review, no such opportunities arise. And remember, there is no possibility of consistently building 300,000 homes without the release of Green Belt. Only a tiny proportion, say 1-3%, but some releases are required.
4. It’s been 3 years since the Planning White Paper. When new policy takes so long to emerge, it is perhaps inevitable that it ends up as policy suited for a different part of the economic cycle. In 2008 the PPS3 60% brownfield target and sequential test were in place when the GFC arrived. Now we have policies to reduce the amount of allocations and consents at a time when the industry is crying out for an easier route to more sales outlets to try and maintain volume. And policy to shrink-wrap cities at a time when they are acknowledged as our best engines for driving economic growth.
5. More and more and more power to local communities is the mantra. But the rhetoric is also accompanied by sanctions on LPAs if elected Councillors overturn Officer recommendations? Go figure?
6. The Urban Uplift – a 35% sized boatload of extra housing numbers, which must be accommodated within 20 cities which generally don’t have the capacity to accommodate them. But as these cities don’t actually need to incorporate these ‘advisory’ housing targets in their local plans these ‘uplift homes’ simply won’t be built. Exporting those numbers to neighbouring LPAs is also not possible given that the Duty to Co-operate has been killed off in advance of the 2-3 year wait for the forthcoming Alignment Test.
7. In my experience, the 300 or so English LPAs split down very roughly as, (a) 100 LPAs who want to build more homes, (b) 100 LPAs who don’t want more homes but will play fair by clear rules, and (c) 100 LPAs, predominantly Green Belt, who will seize any opportunity to game the system to avoid new homes. Last week’s goodies mean no change for the (a) group. The (b) group will likely prepare local plans more quickly but potentially with lower local plan housing numbers. The (c) group LPAs will continue gaming, confident that applications on their Green Belt sites can and will always be refused.
8. Local Plans prepared in 30 Months sounds great. But the currently proposed roll-out of 50 per year from Autumn 2024 is too slow. Advisory housing targets plus no Green Belt releases means we could be waiting a long while for local plans which then offer no hope of delivering 300,000 homes a year.

All in all – some good stuff in the Xmas bundle which should speed up planning applications on already allocated sites. Very welcome. But in terms of stepping up the amount of homes to be allocated and released – much less confidence.

Grim news for young families, housebuilders and the 240,000 children who woke up on Christmas morning homeless or in temporary accommodation.