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
