Poor housing delivery rates could expose almost two-thirds of English councils to new government measures encouraging housing delivery and plan-making, say the authors of a new report.
‘Planned and Deliver’ from planning and development consultancy Lichfields looks at the progress of Local Pans under the National Planning Policy Framework (NPPF) since its launch five years ago.
It finds that 36% of local planning authorities have seen a local plan through examination to adoption, whilst 43% have yet to publish a draft local plan.
This tardiness in plan-making varies across the English regions, but the inability of some councils to make progress could expose them to new government interventions, as announced in the recent Housing White Paper, say Lichfields.
The research also reveals that in aggregate, adopted post-NPPF Local Plans, when combined with the London Plan, are not providing for sufficient housing even to match the number of homes implied by household projections – a shortfall of 3,945 dwellings per annum – let alone to improve affordability.
With many plans still to be prepared in locations subject to restrictive policies – such as Green Belt – there is likely to be a need for upward pressure on housing requirement figures in emerging and next generation plans.
Matthew Spry, Senior Director of Lichfields – and an advisor on the DCLG Local Plans Expert Group in 2016 – said, “As it has been from the beginning, the major factor slowing the Local Plan process is the debate and disagreement over housing numbers. Indeed, almost half of plans found sound have needed to adjust their housing targets before making the grade.
“To encourage local authorities to proactively manage the delivery of new homes, Government is consulting on the introduction of new housing delivery tests.
“Our research has identified some 222 local authority areas (56%) may fail these tests and face the consequences of needing an action plan or application of a 20% buffer on their five year land supply.”
Lichfields found that the biggest gaps in Plan coverage are increasingly concentrated in the areas with the most difficult planning issues – London, the South East and surrounding Birmingham. These are often covered in Green Belt or subject to national designations that can restrict development.
The government recently re-emphasised its desire to ensure all local areas have ‘an up-to-date, sufficiently ambitious Plan’ and is legislating to make having a Plan a statutory requirement.
Where a council does not have an up-to-date Plan, government may intervene by either; directing a local planning authority to review their existing Plan, directing one to prepare a Plan, setting the timetable for its production or arranging for a Plan to be written for them in consultation with local people.
Spry continued, “Five years on from the NPPF’s introduction of a ‘less complex’ planning system, over 60% of LPAs are still without a Local Plan tested and found sound against national policy, with the majority of those still to get to the starting blocks of a local plan examination.
“Despite some frenetic plan making activity over the past 12 months, our research shows that getting these plans to formal submission remains over the horizon for many areas.
“There are clear signs that the prospect of the Housing White Paper’s reforms has caused a hiatus, but with net housing completions reaching almost 190,000 last year despite poor plan coverage, it is perhaps better to apply one comprehensive set of reforms now, rather than have constant tinkering.”
Lichfields found that 31 adopted local plans are subject to a requirement for early review with the overwhelming factor driving an early review being housing – all 31 early reviews were wholly or partially related to this.
The research found that no early reviews of post-NPPF plans have been completed to date, and that the majority of reviews are yet to begin the process.
Mr Spry said, “Because Plan reviews are generally being required to address unmet housing need it is a clear concern that a failure to bring forward reviews will see those issues not addressed, worsening the under delivery of housing and increasing housing shortfall.
“Whilst early reviews may have had a place in certain circumstances, and help to get Plans through the system and adopted, our analysis does not provide any assurance that early reviews are an effective mechanism in addressing substantive planning issues in a timely manner.
“It must be better to get the Plans that are produced right first time, and this will mean more focus on getting Plans flexible and resilient to uncertainty and having more effective approaches to addressing cross boundary working. Where early reviews are required, it’s clear they need to be worded so they provide a panacea, rather than a sticking plaster to a problem that simply gets shuffled down the road.”
Looking further ahead Lichfields believes there is real momentum for a geographically broader approach to Plan making, over and above the existing ‘duty to co-operate’ with neighbouring authorities.
Spry said, “Whilst Government threats to intervene in local plan production in response to the ‘early 2017’ deadline have receded, the ability to intervene has been strengthened, and it is likely the approaches will be ‘larger than local’ given it is cross-boundary conundrums that remain the primary cause of so many delays and disputes.
“In this respect, might the National Infrastructure Commission’s recent discussion paper on a strategic planning approach for the Cambridge – Milton Keynes – Oxford corridor be a smoke signal on the direction of travel, particularly for other key areas of development pressure and economic opportunity?”