Objectively Speaking - NLP Presentation 030613.ppt pdfs/Presentations/southeastplanning... · Objectively Speaking: 12 months of applying the NPPF to housing targets in Local Plans

Objectively Speaking: 12 months of applying the NPPF to housing targets in Local Plans

Presentation of our Proposal

Objectively Speaking12 months of applying the NPPF to housing targets in Local Plans

Matthew Spry, Director, NLP


Structure

• Background

• What we did

• Our findings

• Implications

• Report and animation available:

www.nlpplanning.com/objectively-speaking

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Presentation of our Proposal Background


Background

• Housing targets were fulcrum for debate on localism in 2010

• Drive for localism• RS abolished / local plans set targets

• Drive for growth• NPPF introduced

• What impact did this combined change have on housing targets?

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Background

Policy Exchange:

“Housing Targets down 270,000 since RSS abolition announced”

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Background

CPRE:

“imposing a very rigid ‘predict and provide’ policy to set and enforce housing targets”

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Background

• Which is right?

• Will localism and the NPPF result in Local Plans proposing more or less housing than was envisaged by Regional Strategies?

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Presentation of our Proposal What we did


What we did

• Reviewed all Local Plans outside London formally submitted or examined in 12 months March 2012 – March 2013

• Recorded:• Submitted housing target• Outcome of examination• Target post-examination

• Benchmarked:• Against RS• Against H/H projections

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Presentation of our Proposal The findings


Findings – 55 Plans submitted or examined

• NPPF fired starting gun on a frenetic 12 months of plan-making

• 55 Local Plans submitted or examined

• Majority assessed during period when RS remained extant• First revocation came into force on 3rd January 2013• Majority of ‘top-down’ targets remained in place

• Most LPs had to balance• General conformity; with• Compliance with NPPF

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Findings – 55% proposed a reduction on the RS

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Findings – Only 18 found sound within 12 months

• 18 found sound

• 2 withdrawn (Hull and Salford)

• Remainder (35) ongoing

• More than half of these experienced delays:• Suspension• Further consultation• Housing target most

common point of contention

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Findings – 44% of ‘sound’ plans had to increase target

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Findings – ‘Early reviews’ – the compromise solution

• Inspectors have been pragmatic in situations where LPAs were well progressed on strategies but did not meet needs

• ‘Ghost in the machine’ – on-going presence of the RS caused difficulties

• 5 plans were subject to immediate/early review (now joined by MK)• Wealdon• West Berkshire• Bournmouth• Purbeck• Hertsmere

• Question marks over the lawfulness of this approach• “A plan is either sound or it isn’t”

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Presentation of our Proposal Implications


Implications – what caused the problems?

• Lack of evidence on objectively assessed needs• Lack of evidence to justify arguments about environmental or other

constraints • Dubious assessments of housing requirements:

• Artificial suppression of migration, commuting, headship and other demographic assumptions without considering housing market and other outcomes

• Failure to take account of need for affordable housing and other types

• Misalignment of economic and housing: ‘pro-jobs/anti-housing’• Conflating policy and supply-side factors within demand-side

assessments• Lack of evidence and consistency of approach on cross-boundary

issues• Too many LPAs didn’t acknowledge in time that the policy had changed

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Implications – The policy has changed. PPS3 said:

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• “32. The level of housing provision should be determined taking a strategic, evidence-based approach that takes into account relevant local, sub-regional, regional and national policies and strategies achieved through widespread collaboration with stakeholders.

• 33. In determining the local, sub-regional and regional level of housing provision, Local Planning Authorities and Regional Planning Bodies, working together, should take into account:

• Evidence of current and future levels of need and demand for housing and affordability levels based upon:

• Local and sub-regional evidence of need and demand, set out in Strategic Housing Market Assessments and other relevant market information such as long term house prices.

• Advice from the National Housing and Planning Advice Unit(NHPAU) on the impact of the proposalsfor affordability in the region.

• The Government’s latest published household projections and the needs of the regional economy, having regard to economic growth forecasts.”


Implications – compare that to the NPPF. It says:

• “Local planning authorities should positively seek opportunities to meet the development needs of their area;

• Local Plans should meet objectively assessed needs… unless • any adverse impacts of doing so would significantly and demonstrably outweigh

the benefits when assessed against the policies in this Framework as a whole; or • Specific policies in this Framework indicate development should be restricted.”

• Paragraph 17 of the NPPF states that “every effort should be made objectively to identify and then meet the housing … needs of an area”.

• Paragraph 47 states that “local planning authorities should use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing.”

• Most RS targets formed on the basis of:• Assumptions that are now out of date• Appraisal against the balance of PPS3 (“take into account”)• A higher level approach to evidence and scrutiny

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Objectively Speaking: 12 months of applying the NPPF to housing targets in Local Plans20

Implications ‐ ‘Muscular Localism’

A focus on the local An emphasis on growth

Cultural Change“every effort

should be made objectively to

identify and then meet needs”

Drives decisions down to give more local control

Exposes evidence and judgements on growth to more scrutiny

Incentivises growth

Raises the bar on:

a) expectations that growth should be met

b) Quality of justification of harm if development to be turned down

Positive Planning


Implications – and the evidence = upward pressure

• In many locations, the latest evidence shows household growth is higher than RS targets

• This includes even the latest Interim 2011-based household projections• And they only go to 2021 anyway, and should be handled with care• In the south east, the London overspill is huge (20K+ per annum)

• Ageing demographics mean many areas need to increase housing to maintain economic status quo, let alone pursue job growth

• To date, evidence has rarely supported a defined capacity beyond which impacts ‘significantly and demonstrably’ outweigh the benefits of meeting needs

• Many LPAs, if pushed, will concede their area can accommodate more development if it has to

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Implications – What next?

• Awaiting the SHMA guidance

• But whatever the guidance may say about method, take the NPPF at face value

• Not an unreasonable proposition:• Plans should objectively assess and then positively seek to meet needs• Evidence of the adverse consequences of not doing so is all around us

• Planners and housing professionals should take the opportunity to make the positive case as well as identifying housing need• Supporting infrastructure viability

- Shops, services, schools etc• Supporting the local economy

• Secure wider range of resident views through opinion polling to get a more balanced picture of ‘popular opinion’

• Done the right way, prospect is an invigorating ‘shot in the arm’ for Local Plan making

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Objectively Speaking: 12 months of applying the NPPF to housing targets in Local Plans23

This publication has been written in general terms and cannot be relied on to cover specific situations. We recommend that you obtain professional advice before acting or refraining from acting on any of the contents of this publication. NLP accepts no duty of care or liability for any loss occasioned to any person acting or refraining from acting as a result of any material in this publication.

Nathaniel Lichfield and Partners is the trading name of Nathaniel Lichfield & Partners Limited. Registered in England, no.2778116. Registered office: 14 Regent's Wharf, All Saints Street, London N1 9RL

© Nathaniel Lichfield & Partners Ltd 2013. All rights reserved.

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Objectively Speaking - NLP Presentation 030613.ppt pdfs/Presentations/southeastplanning... · Objectively Speaking: 12 months of applying the NPPF to housing targets in Local Plans