The Local Housing Delivery Group – Standards, Standards, Standards – what a poor report #NPPF

The second output of the Local Housing Delivery Group 

set up in 2011 to respond to the Government’s challenge to boost the delivery of new homes, to simplify housing standards where possible, and to support growth and high standards in home building by helping local authorities and developers find agreed ways in which they can fulfil their obligations under the new National Planning Policy Framework (NPPF).

Unlike the other report on viability – which produced a finished usable out of the box product this report is just a report on problems (‘an interim report’) and seems poorly informed.

I note that no-one on the delivery group seems to be a designer of homes so it is no wonder sad to say, though there were a couple of architects on the standards working. group.

Grant Shapps had earlier proposed a muddles and unworkable ‘local standards framework’

conceived as a clearly costed menu of standards from which planning authorities would be able to select priorities, the overall intention being that the effect on viability of individual developments would be more transparent and more widely understood.

But as many standards will immediately come off the price of land or enable major savings in energy this effort would have been meaningless.

the proposal for a costed menu as originally conceived was rejected due to a lack of support.

The report indentifies the 10  most common standards and then focuses on four areas for further work.  The interaction of the standards was identified as a key cause for concern.

It became apparent from the submissions made by the standards’ owners that they have often been developed for good reasons in response to specific needs or concerns. However some did appear to us to have been created in isolation and without regard to other initiatives. There is criticism of the way in which some standards have been developed, operated and maintained, and the way in which the same requirements may need to be ‘ticked off’ more than once to satisfy multiple standards.

On the subject of accessibility they propose a two or three-tier accessibility model to replace lifetime homes etc.  The group seems unaware of the considerable work on a British Standard for accessibility which would do just that.  No disability reps on the group which would have told them that immediately.

On Energy it proposes to replace the Merton rule – about time too as it conflicts with the direction of travel of building regulations and has encouraged counterproductive tokenist interventions like microgeneration on roofs which create far more carbon in their lifetime than they will ever recover.  No mention though of the massive work done through the Zero Carbon hub to replace the CSH.  Again no expert on the working group – why not someone from BRE?

On Security the report is rightly critical of the Secured by Design Approach as they can conflict with good spatial design.  But again the report fails to recognise that the DCLG commissioned a design guide to replace secured by design and integrates with good urban design, as it was written by some of the same people that did the Urban Design Compendium.  Again no specialist.  We are building up to an omnishambles here.

On Water efficiency it sensibly recommends that part G have varying standards depending on local water stress. But again no Environment Agency Rep.

The bibliobiography is full of holes, no evidence base identified for car parking standards.  Err what about the major report on this commissioned for the DCLG and several other private research programmes.

What needed to be done is for the government to set out its policy objectives and then commission a firm piece of research identifying how these could best be delivered through an integrated set of standards – whether b regs planning, funding whatever.  Practically I think this would require an integrated design manual as well as the two areas are so closely linked.  The model here is the London Housing Design Guide  and Levitt Bernstein’s ‘Easi-Guide to Good Housing Practice’.  Then a firm work programme should have been set out including key stakeholders by regulatory sector integrating with in a programme management approach parallel initiatives such as the Zero Carbon Hub.

This report is a classic example of how you shouldn’t expect House builders to regulate themselves.  They have no incentive to build sustainable, roomy, accessible homes.  The report is shoddy, poorly informed and has already pissed off many many bodies such as the UK Green Building Council.  It also shows how the ‘light touch’ approach to regulation by DCLG is a failure.  What was the DCLG rep doing at the meeting their seems to have been no attempt to steer it back on course.  We expect better from our taxes.

New Guidance on Local Plan Viability from Local Housing Delivery Group

At first ministers had proposed an entirely localist approach to housing standards and assessment of viability. Which went down like a lead balloon. Instead the Local Housing Delivery Group led by the HCA and under Sir John Hanham and including HBF and planning/local government reps. Today they launched two key reports, one on local housing standards, and the other on local plan viability. Ill cover the standards publication in the next post.

The final report has the backing of PINS and POS, as well as the DCLG and the key stakeholders and so is likely to be seen as definitive at local plan examinations. Notable is the viability group included two Three Dragons representatives.

The documents definition of viabaility is different from and clearer than the NPPF.

“An individual development can be said to be viable if, after taking account of all costs, including central and local government policy and regulatory costs and the cost and availability of development finance, the scheme provides a competitive return to the developer to ensure that development takes place and generates a land value sufficient to persuade the land owner to sell the land for the development proposed. If these conditions are not met, a scheme will not be delivered.”

Onto the meat of the document. Sadly it could have said what it needed to say in a quarter of the length.

It stresses that ‘It is critical that consideration is given to the cumulative impact of the plan policies, rather than treating policies in isolation’ and

‘Planning authorities will often need to strike a balance between the policy requirements necessary to provide for sustainable development and the realities of economic viability. There should be both clear local justification for the adoption of local standards and policies, and reasonable returns for landowners and developers… This local choice should be supported by a collaborative approach that is taken throughout the policy making process. The advice and input of local partners, particularly those with knowledge of the local market and development economics, and those who will be involved in delivering the plan, should be sought at each stage.

Wisely it states CIL viability should be considered at the same time. Crucially it recommends use of a residual method to valuation which provides continuity with the Three Dragon viability toolkit as used by the HCA. There is no indication that housebuiilders who paid to much for land and refuse to sell plots at market clearing rates should be able to claim special exemption.  On the issue of threshold land value, the % of returns over costs to induce sale it states this should be determined locally, less than helpful and indicating the group could not come to a consensus.

The most useful part of the report is likely to be the appendices which includes technical advice on avoiding certain pratfalls and a standard proforma for sites.