Putting the Housing Numbers Game in Perspective

Sorry haven’t posted here in a couple of weeks busy on a new project outside England which will take most of my time for the next two years.

What I am up to at the moment puts things in perspective.  Am leading on a plan for a city of around 900,000 which ones knows precisely its population (no census,cancelled at last minute) – or even its rate of population and economic growth precisely – estimate ranges from 4%-9% annum.  So by the plan end point of 2040 you could be dealing with anywhere between 3.5 million or (unrealistically) 12 million population.  Rather puts the HBF 30+ page letters arguing housing need underestimated by 350 in perspective.  Am thinking rather than an end number you plan for doubling – and doubling again – and adjust the end date and rate of infrastructure according to variations in growth.  Interesting also how you estimate small base year population in absence of a census (which you have to do for traffic modelling) in absence of a census – a problem England will soon face, requires exotic statistical methods.  Also interesting is the volatility – wider metropolitan region housing market area suggests that new build vacancy levels are falling below 8% and that will see a ‘correction’ i.e. crash within 1`-2 years. Leads me to think whether you can use this as a metric in order to freeze consents on existing zoned land or automatically speed release of land when vacancy falls below or above certain metrics.  Im getting my economics consultant to look at this.

The UK way is not set in urban planning stone.  Planning can never be precise to within a few hundred units over 15+ years.  What matters is the direction of travel and ability to adjust.

Gold Guidance on DTC and Green Belt – It eats shoots and leaves

From new gold guidance.

The Duty to Cooperate requires authorities to work effectively on strategic planning matters that cross their administrative boundaries. The Duty to Cooperate is not a duty to agree and local planning authorities are not obliged to accept the unmet needs of other planning authorities if they have robust evidence that this would be inconsistent with the policies set out in the National Planning Policy Framework, for example polices on Green Belt or other environmental constraints.

Nice to see the my line highlighted in bold which seems to have become the de facto position used in PINS training and several inspectors reports,and now become de-jure.

But the second – well haven’t the courts pronounced on this on several occasions most notably the recent Hunston St Albans case, that Green Belt is not and never has been an environmental constraint but is rather a policy constraint as the environmental condition in land is not material to its designation.  The position that a number of LPAs have put forward that no strategic or otherwise green belt review is necessary because to do so is contrary to the NPPF ha always been rejected by inspectors post NPPF as in come cases housing need can be an ‘exceptional circumstance’ and plans need to make a policy choice in line with the NPPF about whether its current boundaries meet the NPPF tests including its green belt purposes.  In light of the Hunston case  sure you are aware Masarati Lawyer Peter village’s has intervened in Leeds where the plan/inspectors decision is threatened with JR by the HBF unless they adopt an extreme uber Sedgefield approach and release all green belt now to meet the backlog irrespective of phasing.

LPA may size on the last sentence and argue they no longer need to carry out strategic Green Belt reviews and resist all attempts at a ‘duty to expand’. But it will all end in tears in the courts as the last sentence is grammatically ambiguous as to what its subject it.  Is the subject the class of NPPF constraints policy constraints AND environmental constraints, or the class of all environmental constraints INCLUDING Green Belt. Because it is referring to the NPPF and implying it is unchanged both interpretations are logically possible.  It is to avoid such ambiguity that have commas; at this point the Panda eats shoots and leaves.  For lack of a comma, or perhaps a deliberately misplaced comma (after Green Belt) to prevent strategic Green Belt reviews –if only till after the next election, Nick Boles has subsidised Peter Village at taxpayer expense with another Maserati.  A few weeks down the road a clarification by the SOS will be needed it affects ongoing JRs and examinations.

A return to ‘Brownfield First’- no just reduced Urban Affordable Housing and Infrastructure

Perhaps the previously incompetent DCLG media operation has finally learned how to spin the Daily Telegraph, with Zahawis help, especially now they have lost their excellent editor.

DT misleading story 

Developers are to be given cash incentives to encourage them to build more homes in towns and cities instead of the countryside.

Developers of brownfield sites will no longer have to pay tens of thousands of pounds of fees under the Community Infrastructure Levy, under changes to the National Planning Policy Framework.

Companies which agree to build new homes on brownfield land will also not have to have to provide so many council homes in new housing schemes.

The changes come amid concerns that the NPPF has been used by builders to develop greenfield sites and ignore brownfield areas in urban communities because they are more profitable.

The reforms are being published today in new “planning practice guidance”. which has been cut down from 7,000 pages to as few as 1,000.

Requirements described as “politically painful” forcing councils to give full details of where new homes will be built over 15 years will also be relaxed.

Nick Boles, the planning minister, will set out the details in the House of Commons on Thursday. He said the changes showed the Government was acting in areas where the NPPF was not working as it should.

He told The Telegraph: “The NPPF has been in force for two years. We are making additions to planning guidance in some area where it is not working exactly as we intended.

“We want to use every inch of previously developed land to meet the housing need.”

The reforms were welcomed by MPs and campaigners who have been critical of the NPPF in recent months.

Simon Jenkins, the chairman of the National Trust, said: “We welcome it. There are huge swathes of urban England aching for redevelopment.”

Nadhim Zahawi, a Conservative MP and a member of the Number 10 policy unit, said the changes “show that the Government is listening and is determined to make localism work”.

He said: “It is great news that the planning minister has listened to the calls to clarify the NPPF and is amending planning guidance to close many of the loopholes being exploited by rapacious developers.

“The strengthened focus on greenbelt protection, clarifications around brownfield first and the new focus on ensuring infrastructure is viable and delivered in time to make a difference will be welcomed by groups across the country.”

Nick Herbert MP, a former Conservative Coalition minister, added: “These are welcome changes which show that Ministers have listened to local concerns about planning reforms.

“MPs have argued strongly about the problem of inadequate infrastructure to support development, and as recent flooding shows, these issues cannot be ignored.

“A focus on redeveloping brownfield sites, a more sensible approach on the ‘duty to co-operate’ between councils, and giving proper weight to emerging local plans so that they’re not undermined by speculative development should all help to achieve a better balance between providing housing and protecting the countryside.”

Neil Sinden, spokesman for the Campaign to Protect Rural England, said: “Any help that can unlock difficult to develop brownfield sites are very welcome. But we will be looking at the detail.”

 

So is this a return to brownfield first and changes to the NPPF?

No the NPPF has not changed and no return to BF first – rather the finalised guidance signals some changes in accompanying delivery – such as CIl and issues regarding viability – which presage FURTHER neoliberalisation and degulation – such as letting developers of the hoook for CIL and affordable housing in some cases on BF sites.

No time to do a detailed asessment of the ‘GOLD’ (as opposed to ‘beta’ guidance however a first glance – for exampleon the duty to cooperate – suggests this is typical DCLG spin -simply making offical the current mainstream interpretation of the legal duty by PINS.   Similarly again the 10-15 year housing numbers issue,just clarifying the position where the NPPF was a littrle vague and where teh previous PPG3 was very clear.   The guidance on infrastructure though is helpful and again a return to the pre NPPF position.  Ill post seperately on this if I get 5 mins.