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RTPI response to the MHCLG technical consultation on updates to national planning policy and guidance (1)

OAN II Front CoverThe publication of new household projections by the Office for National Statistics has led to a significant reduction in the overall numbers generated by the standard method for assessing local housing need.

This consultation sets out proposals to update planning practice guidance on housing need assessment to be consistent with increasing housing supply.

This consultation also proposes clarifications of national planning policy on:

  • housing land supply
  • the definition of deliverable
  • appropriate assessment

RTPI's response criticises the move to ignore the standard method so soon after it was introduced but recognises the pragmatic reasons for doing so temporarily in order to avoid undue pressures on local authorities. It asks for clarification on what will happen when projections change in the future, and suggests some ways to improve the methodology.

 

General comments

1. We welcome the chance to respond to this consultation. However, the need for this consultation is symptomatic of the damage caused by constant small changes to the planning system aimed at increasing supply, as we raised in our original response to the Right Homes in the Right Places[1] consultation. Soon after Objectively Assessed Need (OAN) was presented as a way of providing simplicity and consistency, the Government is faced with ignoring or adapting the method, both of which will create uncertainty for local authorities. This presents another challenge for already stretched local planning authorities.

 

2. RTPI criticised proposals for the standard method on the grounds that it does nothing to address the system's tendency to base housing  growth  on  past  trends  rather a  more  forward-looking strategy to also take into consideration future growth aspirations or employment projections. Having adopted the standard method, the Government is now proposing it is ignored in favour of targets which are now identified as being aspirational rather than rooted in the latest household projections.

The Government's proposed approach

Q1: Do you agree that planning practice guidance should be amended to specify that 2014-based projections will provide the demographic baseline for the standard method for a time limited period?

3. This approach is clearly set against the philosophy that underpins OAN. The most up-to-date projections should be used, and updates to the methodology itself should not be aimed at improving the methodology rather than meeting the Government's overall housing target. Moulding the standard method to align with government objectives so suddenly after its adoption undermines its value.

4. The ONS's methodological change only accounts for around half of the difference in projections so it is not a justification in itself. Regarding the rest, the 'affordability adjustment' in the standard method should already account for 'pent up demand' so this seems a poor justification (NPPG para 017, 13.09.2018: "The affordability adjustment is applied to take account of past under-delivery"[2]).

5. In January 2014, the RTPI published research conducted by the University of Cambridge entitled "Planning for housing in England: Understanding recent changes in household formation rates and their implications for housing in England".[3]  This report seeks to explain the changes in household formation patterns and discusses whether those changes are likely to be short or long term. This is an issue that has been identified for some time and a robust way forward is needed.

 

6. The standard method should be improved, for example by.
a. Looking at a longer trend period. For example, for the migration component of sub-national population projections, using a longer trend would help to smooth out peaks and troughs. Note that the GLA use a 10 year past trend rather than the five years built into the ONS projections.
b. ONS producing variant subnational population projections which could be included in Stage 2 of the standard method. They could use the 2016 projections as a base, but allowing a more realistic approach to household formation rates.
c. Local delivery rates and (possibly) localised adjustments to the affordability ratio

 

7. We are sympathetic with the argument that a change in the targets will create disruption for local authorities and others. From  a  practical  perspective, the Government's proposed approach  allows  local planning authorities  and  planning consultancy's alike to carry on as business per usual with regard to strategic planning applications and local plan production which is beneficial in terms of avoiding delays in the short term. However, this is not a sufficient justification nor long-term solution.

 

8. Finally, clarification should be provided on the meaning of:

(i) the 2014-based projections providing the demographic baseline for the standard method "for a time limited period" (Qu 1); and

(ii) the 2016-based projections are not a justification for lower housing need, this being a reasonable approach "in the short-term" (para 27).

Clarifying that 2016-based projections are not a justification for lower housing need

Q2: Do you agree with the proposed approach to not allowing 2016-based household projections to be used as a reason to justify lower housing need? 

9. For pragmatic reasons we agree that the 2016-based household projections should not be used as a reason to justify lower housing need. We accept that to act otherwise would be extremely disruptive to many local authorities.

10. However, we the method should be updated with urgency, and we need greater clarity on how future changes will be responded to, and it is important that local authorities understand and plan based on a nuanced understanding of the latest data.

Applying the cap to spatial development strategies

Q3: Do you agree with the proposed approach to applying the cap to spatial development strategies?

11. There was a range of responses from our members on this. Some said it is reasonable that the cap should be applied at the city regional level at which the methodology has been calculated. The combined authority or group of local authorities can then distribute the resulting housing need figure (based on ability to deliver i.e. history and past rates and strategic opportunities).

12. However, members raised a number of possible problems with this approach, including:

(i) Further fragmentation of the planning system. i.e. some areas will have a strategic level cap whilst other areas may have a single district cap and other areas may have no cap at all.

(ii) It could also complicate the duty to cooperate. The cap might discourage authorities successfully delivering housing from cooperating with authorities who have been less successful. A higher cap would apply across the strategic level to take account of the higher housing need buffer of the authority who was not delivering. This could result in an authority taking housing it would not need if it had not cooperated.

(iii) Development  sites,  particularly  large  scale  strategic  sites,  don't  respect  borough boundaries which would further complicate matters

Housing land supply

Q4: Do you agree with the proposed clarifications to footnote 37 and the glossary definition of local housing need?

13. Yes, clarification would help understand the Government's intention. Without the amendment there is ambiguity which may cause problems at examinations and appeals.

The definition of deliverable

Q5: Do you agree with the proposed clarification to the glossary definition of deliverable?

14. Yes, although further work on the exact wording revision may be worthwhile.

Development requiring Habitats Regulations Assessment

Q6: Do you agree with the proposed amendment to paragraph 177 of the National Planning Policy Framework?

15. Yes, This  change  provides  much  needed  and  welcomed  clarity  over  the  People  over  wind decision. Consideration should be given to including a footnote or policy hook similar footnote 12 of the consultation document which sets out the policies will remain under review as EU negotiations continue.