How can we meet housing targets?
If we are going to strive to achieve the Government’s objective of providing new homes (300,000 per year including affordable and older people’s) the question becomes how?
The two initial options of building out (settlement expansion), and building up (higher density), seem to have been taken off the table in most but the most urban locations.
Add to this, the fact that certain allowances will be introduced in relation to housing delivery, with Local Authorities being able to reduce their need to adhere to having a 5-year housing supply, and the matter becomes even more contentious.
Whilst the onus should not fall solely on the Local Authority to deliver housing, as there are many other parties involved, the flexibility proposed to be allowed to local authorities does not help the case for development and instead reinforces the argument to retain the status quo.
The government has tried to address build-out rates by suggesting that financial penalties will be applied for developers who are building out too slowly, and that ‘past irresponsible planning behaviour’ should be a material consideration. However, the consultation stops short of clearly defining what such behaviour entails.
The government has also tried to incentivise and support communities in delivering affordable housing.
Whilst this has some merit, it is unlikely to be wholly successful given the level of local opposition to affordable housing delivery, and the lack of clarification over how this would tie into the existing planning framework.
The current evidence in relation to neighbourhood plans seeks to emphasise this point, with its limited impact in boosting housing supply and providing a clear statement to direct housing within sustainable urban centre.
However, there will be more emphasis on the character of the area which will be established through the introduction of design codes. In the short term, this is likely to increase the appetite for local authorities to bring forward identified urban sites and those on the brownfield register.
Given the likelihood of further delays in local plan making as authorities re-evaluate the housing target and potential site allocations, and with less weight being given to the five-year housing supply and delivery rates, authorities are likely to push back on the need to meet these targets.
As a result, the emphasis will probably turn to known sites as opposed new sites, however, additional calls for development land (Call for Sites exercises) could provide the opportunity to include areas with high redevelopment potential, particularly outside areas of green belt or perceived landscape sensitivity.
In the longer term this will place greater emphasis on previously developed land, and sites with a high level of re-development potential, with urban, town centre and high street sites likely to be an area of particular focus.
In-fill development will likely become the prevailing form of housing delivery, as authorities look to protect settlement boundaries from further encroachment, with development located in sustainable and highly accessible areas lively to be encouraged.
Another missed opportunity
Setting aside the obvious political motives for the revision of the government’s flagship planning policies at this time, the current consultation stops short of recognising the ability of the planning system to guide sustainable growth through improvements to infrastructure and the environment.
Local Plans and policy frameworks should be there to provide guidance, and an overarching local development strategy.
It is disappointing to see yet another missed opportunity to deliver positive planning change, as there are so many great opportunities for innovation and modernisation within the development industry.
More time needs to be spent assessing where the best opportunities for development are, including Green Belt, and the maximising positive benefits that development can bring. This is not to say that places are not worth preserving and maintaining, but instead we should be identifying where improvements can be made, and how development can appropriately facilitate those improvements.
The lack of information on open space, employment, economic growth, infrastructure, and conservation only seeks to highlight this point.
The NPPF should be looking to promote a more coordinated and proactive joined up approach to development at all levels. Instead, this overly pessimistic restrictive approach, will result in piecemeal development, which is in no one’s best interest and will not deliver significant infrastructure improvements.
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