Meeting a 35% uplift in Housing Need for top 20 Cities - Where?

2021-06-24T10:57:24Z

Wondered if anyone has thought about this new part of the Standard Method for calculating housing need (in Plan Making)?

We previously had the Standard Method which set out three steps to calculate our housing NEED based on Household Projections, Affordability Ratio and Capping.

We probably all know that in December 2020 the Standard Method was changed to add a forth step, applying a 35% increase to the previous number if you were one of the top 20 biggest cities/urban areas.

So, clearly this additional 35% is not your NEED is it? You can't just say 'Add 35% and that is your need'. This new Standard Method is your NEED (steps 1 to 3), plus an additional 35% (Step 4) which is a Government imposed policy to direct housing into urban areas because they don't want to see Green Belt and countryside lost and they want to maximise BF land and increase densities. But it's not NEED.

How does this 35% extra reconcile with the NPPF Para 59 which requires that "To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed" (my emphasis). The quantum of homes NEEDED by using the 35% increase are not what is NEEDED in these locations. Steps 1-3 identify the amount of NEED.

The 35% is going to be a killer for many big authorities, especially those that already have high needs before applying the uplift. I suspect it could make placemaking and 'proper' planning really difficult. Remember that along with these homes comes a requirement for the supporting infrastructure and lots of it in these areas. So where does that go?

Part of the argument for this approach is that cities are sustainable locations. But there are three strands to sustainability Social, Economic and Environmental. And all three are equally important. There's the pressing issues of climate change, air quality, biodiversity etc. and surely we have all learnt from the lockdowns how important both internal and external open space is for our health? I struggle to see how this simple 'uplift' can be socially and environmentally sustainable as a concept unless there is clearly room in these locations to do it.

The PPG advises that "This increase in the number of homes to be delivered in urban areas is expected to be met by the cities and urban centres themselves, rather than the surrounding areas, unless it would conflict with national policy and legal obligations."

My question is - does the PPG mean that the whole of the need (including the 35%) must be met within the LPA boundary or can some of it be exported across the boundary into an adjacent urban area?

And also given the "Unless it would conflict with national policy" in the PPG, does that actually mean you don't have to meet all of your 'need'? or does it just mean you CAN export some of it to surrounding areas, presumably through Duty to Co-operate?

Cheers