Chapter 6
48) Do you agree the requirements for spatial development strategies and local plans in policy HO1 and policy HO2 are appropriate? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI welcomes a number of elements of this chapter and supports the Government’s overarching objective to substantially increase the supply and mix of housing. This includes both assessing need and setting requirement figures for housing. In terms of HO1, the RTPI would welcome a clear connection with S5(j), ensuring that the development plan can clearly and robustly identify unmet need across housing types. In order for HO1(1)(c) to operated effectively please see our response to Q15(a) in relation to cross boundary matters. Regarding HO2(1) the RTPI would welcome guidance on what constitutes significant change.
As set out in response to 7(a), the RTPI recommends that, given the significant length of proposed time frames for SDSs, a review of current housing need methodology use to inform their preparation and review should be undertaken.
49) Is further guidance required on assessing the needs of different groups, including older people, disabled people, and those who require social and affordable housing? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) If so, what elements should this guidance cover?
A key element of guidance will be how to support monitoring and review of local plans. This would include an understanding of how housing need for different groups change over time.
We note across this chapter the enhanced role of the planning system in setting out the disaggregation of different types of affordable housing. Whilst laudable, it will add considerable complexity to both plan-making and decision-making, which will require significant resourcing and corresponding skills development for planning authorities.
50) Do you agree with the approach to incorporating relevant policies of Planning Policy for Traveller Sites within this chapter? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
No further comment.
51) Is further guidance needed on how authorities should assess the need for traveller sites and set requirement figures? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) If so, what are the key principles this guidance should establish?
The key principles for such guidance need to be mapped back to the objectives of Chapter 6 and the provision within its policies, in particular HO3, HO7, HO10 and HO12.The RTPI would welcome a clearer defined role regarding SDSs on this matter. This could include an understanding of how need is proportioned out across of sub regional areas for allocation in local plans alongside assigning land for plots when identifying land for major strategic growth identified.
52) Do you agree the new Annex D to the draft Framework is sufficiently clear on how local planning authorities should set the appropriate buffer for their local plan 5-year housing land supply? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
No further comment.
53) Do you agree the new Annex D to the draft Framework is sufficiently clear on the wider procedural elements of 5-year housing land supply, the Housing Delivery Test and how they relate to decision-making? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
No further comment.
54) Do you agree the requirements to establish a 5 year supply of deliverable traveller sites and monitor delivery are sufficiently clear? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
a) Please provide your reasons, particularly if you disagree.
Paragraph 10 of Annex D does not contain enough detail regarding how planning authorities are to establish a 5-year supply of deliverable traveller sites. As set out in response to Q51, we await further guidance on assessing need for traveller sites.
55) Do you agree the plan-making requirements, for both local plans and spatial development strategies, in relation to large scale residential and mixed-use development are sufficiently clear? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
HO4(1)(b) we would welcome a consistent approach taken as to HO4(1)(a) in that communities should be capable of being sustainable.
The RTPI would support clarification to HO4(2)(2) that setting expectations for appropriate mix of tenure should be undertaken locally to better reflect local need.
The RTPI strongly supports the need to meet different groups in terms of housing requirements as set out in HO5. However, we are concerned that HO5(1)(d) sets a development size of 150 which is far too small to accommodate meeting the need of all the groups set out in this policy. Such a mix could only be feasibly achieved on very large strategic sites. Such sites themselves may have very long build out rates, which may necessitate a change in mix over different phases of the development, especially if a new plan is adopted, so some flexibility would be welcomed to accommodate such events.
56) Do you agree our proposed changes to the definition of designated rural areas will better support rural social and affordable housing? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
No further comment.
57) Do you agree with our proposals to ask authorities to set out the proportion of new housing that should be delivered to M4(2) and M4(3) standards? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
The RTPI strongly supports the improved accessibility of our existing and future housing stock, however we believe the best way to achieve this outcome is through building regulations. A more nationally consistent approach would create certainty for developers, enabling them to better embed and mainstream inclusive design in their products. Such building regulations could be switched on to higher thresholds in certain areas if needs be. For example, in areas with aging demographics and the associated potential increase in demand for accessible housing.
58) Do you agree 40% of new housing delivered to M4(2) standards over the plan period is the right minimum proportion? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Neither agree nor disagree.
a) Please provide your reasons, and would you support an alternative minimum percentage requirement?
The RTPI strongly supports the increase in threshold provision for M4(2) standards, but as set out in response to Q58, we believe such provisions should be set out nationally through building regulations.
59) Do you agree the proposals to support the needs of different groups, through requiring authorities to identify sites or set requirements for parts of allocated sites are proportionate? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI recognises issues of delivering on the requirements of HO5(1)(a)(ii) if DM5(2) is continually engaged. We are not clear how such a scenario would be dealt with through local plan review. The RTPI supports the laudable intent behind requiring authorities to identify sites or set requirements for parts of allocated sites for specific types of housing. However, we hold some concerns around the workability in practice, particularly around smaller sites, as set out in response to Q55. There also may be issues in local plan preparation in terms of identifying landowners that are willing to support the development in regard to particular tenures on their sites. In order to ensure that proposals are more realistic and workable, we would recommend a higher minimum threshold be set before such policies are engaged. This revised threshold would then be supported with the rationalisation and consolidation of HO5(1)(c) and HO5(1)(d).
The revised NPPF contains supportive framing around bringing forward development in settlement boundaries, the reuse of previously development land, a more positive and proactive approach to sustainably repurposing heritage assets, and the targeting of residential development as part of town centre regeneration. To support all of these objectives, the RTPI would warmly welcome the inclusion of policy provisions in this chapter for heritage-led housing.
60) Do you agree with our proposals to ask authorities to set out requirements for a broader mix of tenures to be provided on sites of 150 homes or more? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly disagree.
a) Please provide your reasons and indicate if an alternative site size threshold would be preferable?
As set out in response to Q59, the RTPI believes the proposed site threshold to be too low, especially if attempting to cover all the specific types of housing need set out in HO5. A minimum threshold of 500 homes would be more practicable to start introducing such measures.
61) Do you agree with proposals for authorities to allocate land to accommodate 10% of the housing requirement on sites of between 1 and 2.5 hectares? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
a) Please provide your reasons
The RTPI strongly recognises the potential benefit of establishing the principle of development for small and medium sites through local plan preparation. The provision of a greater mix of sites could reduce the investment risk to SME builders and expedite the consenting stage. It would also perform a function in terms of anticipating the cumulative infrastructure demands of smaller development in an area. However, we are concerned about the high workloads of allocating small and medium sites in local plan preparation process for planning policy teams. This could be particularly acute for areas which are managing high growth demands from recent changes to housing need assessments. Such increased workloads need to be framed by a diminishing backdrop of resources for planning policy teams, increased workloads elsewhere in the plan preparation process, such as through enhanced viability assessments, the transition of information set out in SPDs and increased emphasis on defining settlement boundaries. See response to Q9(a) for more details. We note particular practical challenges raised around allocating 2.5ha sites as these constitute unusually small field sizes in England, so may not be readily identified in the numbers needed. We note there may be difficulties in certain authorities in terms of availability of such sites to be allocated, therefore this national approach may prove overly prescriptive and unworkable. The RTPI would propose that, given the ambitious new 30-month plan preparation time frame, wording should be reverted to its current form - identifying but not allocating such sites - or Government should provide a wholesale increase to resources for planning policy teams.
62) Are any changes to policy HO7 needed in order to ensure that substantial weight is given to meeting relevant needs?
No further comment.
63) Do you agree that proposals to add military affordable housing to the definition of affordable housing, and allow military housing to be delivered as part of affordable housing requirements, will successfully enable the provision of military homes? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
a) Please provide your reasons, particularly if you disagree.
The RTPI would be concerned that the additional definition of military affordable housing may have unintended consequences of confusing general delivery of affordable housing skewing numbers. We would assert that military affordable housing may be more usefully considered as a part of other specialist housing need.
64) Do you agree flexibility relating to the size of market homes provided will better enable developments providing affordable housing? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly disagree.
a) Please provide your reasons, particularly if you disagree.
The RTPI would welcome further clarification on whether local plans will be able to identify housing mixes in allocated sites. We believe this approach is overly prescriptive and will be particularly challenging in areas which do not currently have optimised housing stock size. For example, homes in rural areas are typically larger on average than in urban areas, which may not suit their demographics.
65) Would requiring a minimum proportion of social rent, unless otherwise specified in development plans, support the delivery of greater number of social rent homes? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) If so, what would be an appropriate minimum proportion and development size threshold taking into account development viability?
The RTPI supports a minimum proportion of social rent, however we believe this should be set locally and tailored to local circumstances.
66) Are changes to planning policy needed to ensure that affordable temporary accommodation, such as stepping stone housing, is appropriately supported, including flexibilities around space standards?
a) If so, what changes would be beneficial?
The RTPI understands the critical need to ensure that we have more affordable temporary accommodation across the country, however we do have concern about the considerable disaggregation of affordable housing in this chapter and the workability of that. Noting that these forms of development can already be consented through the discretionary system. Changes to other fiscal mechanisms may prove more advantageous in bringing forward a stronger pipeline of temporary accommodation.
67) Do you agree that applicants should have discretion to deliver social and affordable housing requirements via cash payments in lieu of on-site delivery on medium sites? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly disagree.
a) If so, would it be desirable to limit the circumstances in which cash contributions in lieu of on-site delivery can be provided – for example, should it not be permitted on land released from the Green Belt where the Golden Rules apply? Please explain your answer.
The RTPI understands the logic behind increased flexibility over the provision of affordable housing on medium sites as set out in the consultation document. This could greatly benefit SME housing delivery but may have unintended consequences. This includes the lack of creation of mixed communities, particularly in rural areas where medium size sites are likely to be the predominant size of site delivering at a larger scale. There will also be variation across the country regarding the ability of local authorities and RPs to coordinate the delivery of housing funded though commuted sums. This has occurred historically and in many circumstances such money has had to be returned as it has not been spent in a timely manner.
The RTPI does not support the discretion for applicants to deliver social and affordable housing requirements as cash payments in lieu of onsite delivery on medium sites. Mechanisms already exist whereby local authorities can agree to such arrangements, enabling the discretion to applicants would likely vastly reduce any on-site delivery on medium sites going forward. If such a proposal were to be brought forward more fully in the future, there would need to be a whole-sale review of the level of support necessary to enable local authorities and registered providers (RPs) across the country to effectively spend such money and deliver affordable homes.
b) If you do not believe applicants should have blanket discretion to discharge social and affordable housing requirements through commuted sums, do you think cash contributions in lieu of on-site delivery should be permitted in certain circumstances – for example where it could be evidenced that onsite delivery would prevent a scheme from being delivered? Please explain your answer.
See response to Q67(a).
68) What risks and benefits would you expect this policy to have? Please explain your answer. The government is particularly interested in views on the potential impact on SME housing delivery, overall housing delivery, land values, build out rates, overall social and affordable housing delivery, and Registered Providers (including SME providers).
See response to Q67(a).
69) What guidance or wider changes would be needed to enable Local Planning Authorities to spend commuted sums more effectively and more quickly? Please explain your answer.
As set out in response to Q67(a), the RTPI believes there needs to be substantive and detailed guidance provided to LPAs to support the spend of commuted sums. This should include highlighting their potential role as facilitators in the partnership delivery of affordable housing, working with key stakeholders such as, housing associations, Homes England, and relevant Parish Councils, in order to deliver adequate amounts of affordable housing that fully reflects the needs of the area. Many other fiscal levers could also improve the LPAs ability to spend commuted sums including, increasing borrowing limits to be able to fund development, and a review of existing procurement roles.
70) Would further guidance be helpful in supporting authorities to calculate the appropriate value of cash contributions in lieu?
a) If so, what elements and principles should this guidance set out? Please explain your answer. For example, guidance could make clear that contributions in lieu should be an amount which is the equivalent value of providing affordable housing on site, based on a comparison of the Gross Development Value of the proposed scheme with the Gross Development Value of the scheme assuming affordable housing was provided onsite.
It is crucial that land purchase is also considered alongside the value of dwellings in order to appropriately reflect the true value of providing houses off site.
71) Do you support proposals to enable off site delivery where affordable housing delivery can be optimised to produce better outcomes in terms of quality or quantity? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
Yes, however if such approach were to be undertaken in significant and wide-ranging manner it will come at the cost of social cohesion, which should be considered a serious negative outcome in terms of the quality of placemaking.
72) Do you agree the with the criteria set out regarding the locations of specialist housing for older people? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
We note many similar but inconsistent approaches to provisions for different specialist forms of accommodation in this policy, for example the approach to management plans in HO9(1)(b)(i) and HO9(1)(c)(iii). Therefore, we believe this policy could be consolidated and rationalised, noting that all such forms should benefit from being well-connected and with good access to the appropriate social infrastructure.
73) Do you agree with the criteria set out regarding the locations of community-based specialist accommodation, including changes to the glossary? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
No further comment.
74) Do you agree with the criteria set out regarding the locations of purpose-built student accommodation and large-scale shared living accommodation, including changes to the glossary? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
See response to Q73(a).
75) Do you agree the proposals provide adequate additional support for rural exception sites? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, including what other changes may be needed to increase their uptake?
The RTPI supports proposals to provide additional support for rural exception sites but believes that there is more to be done to support their success. To give rural communities and land promoters more certainty, we would advocate for future changes to legislation to provide a provision for Planning in Principle approach to be available for rural exception sites.
76) Do you agree with proposals to remove First Homes exception sites as a discrete form of exception site? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
No further comment.
77) Do you agree proposals for a benchmark land value for rural exception sites will help to bring forward more rural affordable homes? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly disagree.
a) If so, which approach and value as set out in the narrative for policy HO10 of the consultation document is the most beneficial for government to set out?
The RTPI does not believe that rural exception sites do not currently come forward because landowners have higher expectations over land values and such approach could be complex and have unintended consequences. Please also see our response to Q75(a) for a proposed solution to bring forward more rural exception sites into the system.
78) Do you agree the proposals to set out requirements for traveller sites at policy HO12 adequately capture relevant aspects from Planning Policy for Traveller Sites, whilst ensuring fair treatment for traveller sites in the planning system? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
79) Please provide your reasons, particularly if you disagree.
No further comment.
80) Do you agree the proposals in policy HO13 will help to ensure development proposals are built out in a reasonable period? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree
a) Please provide your reasons, particularly if you disagree.
No further comment.
81) Do you agree the requirements to take a flexible approach to the consenting framework for large scale residential and mixed-use development is sufficient to ensure the opportunities of large scale development are supported? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI recognises the intentions set out in HO13 to better ensure that major development proposals are capable of being implemented within a reasonable time period. However, beyond tenure mix, local market conditions, and development history of the site, the RTPI would support a fuller appraisal of other relevant factors, such as impact on infrastructure delivery, land preparation, and discharge of conditions, alongside how relevant technical consents play on delivery timescales.
The RTPI understands the intentions as set out in HO13(4) in terms of ensuring that development proposals are consistent with proposed large-scale developments in emerging local plans and such opportunities be safeguarded. However, the way the policy is currently worded may cause some confusion to the user and decision-maker and could benefit from clearer wording.
82) Are any more specific approaches or definitions needed to support the delivery of very large (super strategic) sites, including new towns? Yes, no
No.
a) Please provide your reasons.
No further comment.
83) Do you agree with the proposed changes to the Housing Delivery Test rule book? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
No further comment.
