Flexible Housing Targets - Public forum - Planning Advisory Service (PAS)
Flexible Housing Targets
Hello,
Our authority is in the early stages of Local Plan production and is currently in the process of identifying it’s objectively assessed need and housing target. The last Local Plan used the housing target derived from the (former) RS.
CLG projections are the starting point when identifying OAN. The projected number of households shown in the most recent CLG projections for our Borough is much lower than previously predicted in the 2011 interim projections. This got me thinking whether there was any way of “future proofing” the Local Plan given that the OAN is likely to change again over the 15 year plan period.
Bear with me on this one…
- Could authorities set a target in their Local Plan based on current evidence but also include a policy which states how and when the target is to be reviewed? (for transparency it would need to show how the target had been arrived at in the first place and what had been “factored in”)
- Following the production of new CLG figures, the OAN could be reviewed through a SHMA update. A new target could then be produced where necessary (e.g. if the SHMA suggests the OAN has increased), replacing the one in the Local Plan. Could this new target could be set out in the SHLAA Review/Housing Statement?
- Could the Local Plan identify a list of “reserve allocations” which could be brought forward if the target is increased? (the benefit of this would be that the sites would have been through public consultation)
- If the target was decreased in line with the new evidence, how could over-supply be avoided? Or would this be unlikely to happen anyway as developers build to demand?
Having a “fluid” housing target which is reviewed and updated each time new CLG projections are released would give developers the flexibility they often ask for and could reduce the amount of landbanking. Preparing for an increase in the target in advance could also avoid “planning by appeal” and would give communities more certainty over which areas are likely to be developed.
I’d be grateful for your thoughts on this approach. Are any authorities already doing this? Are there any other potential problems with it I've not considered? How and when do other authorities review their targets at present to ensure need is being met?
Thanks, Leanne
Andrea King, modifié il y a 9 années.
RE: Flexible Housing Targets
Enthusiast Publications: 76 Date d'inscription: 19/08/13 Publications RécentesHi Leanne
The ONS/DCLG-based objectively-assessed needs are just the starting point as you say, and not necessarily what your Plan should necessarily provide for, ie. you may have several alternative objectively-assessed growth scenarios, of which the ONS/DCLG figures are just one. Indeed, the PPG advises that the new national projections don't necessary mean your SHMA is out-of-date either. There is also the argument going around that the latest projections are possibly reflective of the recessionary period when household formation has been held back a bit due to housebuilders not building enough homes and people not being able to afford mortgages to buy or rent their own homes (and possibly in some areas a shortage of land allocations which may also have held back building).
I'd say you also need to factor in an appropriate vacancy rate (which the housing market needs to function effectively, ie. it can't reasonably be 0%), so your actual dwelling requirement will actually be a bit higher than what your household needs are projected to be. eg. our old RS sought a 3% vacancy rate, so if we applied that then the household need would equate to 97% of the total OAN dwelling requirement - incidentally, I'd be interested whether anyone else has managed to successfully justify lower vacancy rates (eg. by actively bring long-term empty homes back into use)?. As with average household size, this vacancy rate is actually very sensitive to what your ultimate dwelling requirement turns out to be, so maybe worth doing some sensitivity testing on that too!
Your OAN will also need to reflect the projected growth in demand for communal/institutional living accommodation that your alternative population and household projections indicate. You then need to make an objective choice as to which of your OAN alternatives is most appropriate to pursue in your Local Plan.
But what you then take forward into your Local Plan will also need to take account of the exceptions to meeting your full OAN as cited in the footnote to NPPF para.14 (eg. re. Green Belt, protected wildlife/habitat and conservation designations, flood risk zones, etc.), if your council considers it appropriate to do so.
And then there's the fact that the NPPF clearly says that, while ultimately seeking to be aspirational and providing for your OAN in full (subject to the exceptions), local plans must also be realistic and deliverable. In my view this must surely therefore take into account your realistic assessment of SHLAA-based land capacity and the achievability of the housebuilding sector in your area delivering the build rates that your OAN suggest would be required - ie. there's no point in your plan setting overall and interim plan period targets for the numbers of homes to be provided for through your site allocations if there's ultimately not a hope in hell in all reality of them actually being delivered! So taking into consideration trend analysis of past delivery rates, and realistic rates of increasing those (I recall an FT article a couple of years ago where the HBF advised Government that the housebuilding sector could only realistically increase rates by about 5-10% per annum, so perhaps could apply that to your deliverability calculations to see how much land you reasonably need to allocate for over different time periods) will further inform your allocation requirements. Again, if households can't afford to buy or rent new homes, then the housebuilders won't build them, however much land you allocate for, so realism needs to be taken into consideration.
As regards future-proofing, you'll no doubt be reviewing your Local Plan at least once or twice before the end of your projected plan period, so that's arguably where you can adjust things policy-wise to reflect changing projections. If you're looking at needing to release Green Belt land, then there's the option of safeguarding additional land to potentially cater for longer-term needs beyond the plan period, which can be brought forward later down the line if delivery over the years suggests a need to ultimately do so. I also don't see any harm in allocating some reserve sites that you will only release for development until a later stage in the plan period and if your continuous monitoring suggests they need to come forward, eg. because of greater demand, or economic circumstances holding back delivery of higher priority (eg. brownfield) site allocations.
Never an exact science but hope this helps your thinking a bit more anyway, and of course I'd welcome any further thoughts on these considerations too!
Thanks Andrea, that's really helpful. The main thing I'm worried about isn't coming up with the target in the first place but more how do we keep it up-to-date.
Say for example, the Plan sets a target of 1000 dwellings per annum over the 15 year period. Then a year of two after adoption new CLG projections are produced which are much higher than those which the target in the plan was based upon (forgetting for a second everything else that's factored in which makes up the target). A planning application is then submitted for a site which isn't allocated and which doesn't accord with the Local Plan policies. This is subsequently refused on the basis that the Council has a 5 year supply against the Local Plan target. Could the developer not argue that the target in the Plan doesn't reflect current need and that the Council doesn't have a 5 year supply?
As you say, one of the ways this could be avoided is by carrying out regular Local Plan Reviews but I was trying to think if there were any quicker (and cheaper!) ways to update the target when necessary.
Leanne :)
Andrea King, modifié il y a 9 années.
RE: Flexible Housing Targets
Enthusiast Publications: 76 Date d'inscription: 19/08/13 Publications RécentesThe changing ONS/DCLG targets won't change or automatically render out-of-date your Local Plan allocation requirements or SHMA (which ultimately may not be based on that particular OAN in any case, and may have been constrained for one or more of the legitimate NPPF reasons too), but they can be taken into account as a material consideration I would think, in terms of being more recent evidence depending how up-to-date the Local Plan is in terms of the NPPF presumption. It's then a judgment for the council as to whether that should outweigh your Local Plan policy as the basis for determining applications. If the unallocated site's assessed to be potentially suitable in your SHLAA, then that may also be a reasonable consideration too.
Also, I'd say your SHLAA's determination of 5yr and 15yr housing land supply is based on your adopted development plan allocation requirements, and so is also not changed by new national projections of needs (tho you could assess against both if you wish for comparison purposes). Your regular plan monitoring should ideally pick up on changing circumstances like this and identify whether and in what circumstances it should trigger a Plan review (maybe linked to SHMA and SHLAA too), so perhaps something to consider setting out in your Plan's implementation and monitoring section re. contingencies? An increase in housing needs may not always mean more land needing to be allocated either, and could potentially also be addressed through actively reducing long-term empty homes, higher density housing in appropriate areas (if viably sellable/rentable), etc.