The Government is expected to publish revisions to the National Planning Policy Framework (NPPF) next week, but will the review go far enough to meet housing need, particularly in London and its commuter belt, and begin to address issues of affordability?
Waverley, the sixth most expensive borough outside London, has recently adopted a local plan five years after the first draft was thrown out by a planning inspector. The adoption of the first local plan for this Surrey borough since 2002 is a massive achievement and a small step towards filling the local planning gap in London’s green belt.
Its story highlights some of the issues we hope to see resolved.
To get its plan adopted, Waverley increased its housing target from a new household projection based figure of 396 homes a year to a minimum of 590. Of this, 84 homes a year are earmarked to make up for the shortfall in neighbouring Woking’s housing target against need. A further 111 homes a year are intended to “tackle affordability, including the provision of affordable homes and to take into account anticipated changes to migration from London to Waverley”.
The 111 additional homes is a 28 per cent uplift from the demographic projection. But Waverley is one of the least affordable locations in the country and this is far short of the arbitrary cap – a maximum uplift of 40 per cent – from the recent Government consultation on housing need calculations, “Planning for the right homes in the right places”. This methodology generates a housing need of 538 homes a year in Waverley, before considering provision for the overflow from neighbouring Woking.
It is now widely accepted that England needs 300,000 new homes a year to have a meaningful impact on housing affordability, but the proposed method of assessing housing need fails to reach this target. It also fails to account for places that have delivered low numbers of new homes for many years, such as Waverley, and which therefore have suppressed household projections.
Applying an alternative methodology proposed by Savills, designed to better tackle affordability and take account of years of undersupply, would apportion more than double the number of homes a year (1,286) to Waverley. Of course, this doesn’t need to be fully delivered within the borough, but if not will need to be provided in well-connected alternative locations. This is a situation that is replicated across London’s commuter belt.
If 300,000 homes are to be built in England each year, we will need a 1.3 per cent addition to stock each year and this needs to be weighted towards the least affordable places, like Waverley, to tackle the affordability crisis.
If the new target in Waverley (excluding the unmet need from Woking) is met, it will only be an addition of 1.0 per cent to housing stock each year. That looks like a small difference, but if everywhere built homes at a rate of 1.0 per cent per annum we would only build 240,000 additional homes per year.
So, the new Waverley Local Plan is a great step forwards, but it will take greater local level ambition if the national housing need is to be recognised and addressed in full.
Will the revisions to the NPPF help?
The housing need consultation (planning for the right homes in the right places) aimed to provide a ‘deliverable’ solution by applying a 40 per cent cap on any increase in housing need above household projections or a plan target that is less than 5 years old.
Deliverability has in the past been treated as a second step, having understood the scale of the challenge in the housing need assessment. If the concept of a cap on housing need remains in place, then we are likely to gain clarity on technically how housing need should be calculated, but this will create confusion over what we actually mean by ‘housing need’.
It is more likely that the revisions will anticipate a greater degree of strategic planning in the system. This could focus delivery on a number of new settlements and may relieve some of the pressure on individual local planning authorities struggling to meet housing need through the local planning system. Arrangements such as the Oxfordshire Growth Deal, which goes far beyond the housing need anticipated by the consultation approach, and the housing delivery anticipated alongside the planned Oxford to Cambridge transport improvements may have similar effects.
Whatever happens, Waverley has secured five years of peace before it is anticipated that the revised NPPF will deem its plan, or at least its housing target, out of date again.