We can’t set Targets for Housebuilding in Broxstowe – if we miss them we look stupid

Inside Housing

Instead it just ends up looking powerless

Sheena Ramsey, chief executive of Gateshead Council, was speaking at the Chartered Institute of Housing (CIH)’s annual conference on Tuesday during a session on the opportunities and risks for local authority development.

“Get people in a room, tell them what you want and say we aren’t letting you out until we have sorted it,” she told delegates.

“Local government went through a really torrid time and it has taken a long time to get people’s heads back up.”Morning Briefing: thousands descend on Manchester for Housing 2019

She was responding to an audience question from Teresa Cullen, chair of the housing committee at Broxtowe Borough Council, who revealed that the authority’s chief executive had warned that setting too high a development target risked making the administration “look stupid”.

May to end ‘Postcode Lottery’ of Nationally Described Space Standards

Local Gov

Would this apply to PD homes?

The Prime Minister yesterday called for new design laws to ensure high-quality homes in a speech dismissed by Labour as a ‘lame duck announcement’.

Addressing the Chartered Institute of Housing conference, Theresa May said there needed to be new design standards for homes, more social housing, and further tenant rights.

She said that Nationally Described Space Standards are currently a condition of granting planning permission in only a few local authority areas.

This has created an uneven playing field leaving ‘tenants and buyers facing a postcode lottery’.

Mandatory regulations would be universal and provide clear, national standards, the PM told the conference.

Mrs May also confirmed plans to end so-called ‘no-fault’ evictions and said a consultation will be published shortly.

There will also be further action on the Social Housing Green Paper agenda, according to the PM.

This will see more high-quality social housing built, better tenant rights ensured, and landlords will be required to demonstrate how they have acted on concerns raised.

‘This is a Government with a bold vision for housing and a willingness to act on it,’ said Mrs May.

‘A Government that has delivered radical reforms for today, and the permanent structural changes that will continue to benefit the country for decades to come.’

The number of additional homes being delivered in England has increased from 137,000 in 2010/11 to 222,000 in 2017-18.

However, according to a PAC report published today the Government’s target of delivering 300,000 new homes a year by the mid-2020s is in danger because of a ‘lack of decisive action’.

Responding to the PM’s speech, John Healey MP, Labour’s shadow housing secretary said: ‘This is a lame duck announcement from a lame duck Prime Minister.

‘Her ministers have launched 83 housing consultations in the last three years, but little action or legislation has followed.

‘Today she still only promises change on building standards and social housing in the future.’

Government complicates UCO issue over Housing for Elderly in new NPPG

NPPG Update

How does the use classes order apply to specialist housing for older people?

It is for a local planning authority to consider into which use class a particular development may fall. When determining whether a development for specialist housing for older people falls within C2 (Residential Institutions) or C3 (Dwellinghouse) of the Use Classes Order, consideration could, for example, be given to the level of care and scale of communal facilities provided.

Paragraph: 014 Reference ID: 63-014-20190626

This is a shift from ministry letters over the years stating the level of internal care was not a land use matter no doubt prompted by caselaw and ministerial decisions.  (see for example)

This will simply confuse matters.

Why cant it simply follow precedent

In these cases, a recurring theme is the degree of care provided to the majority, or all residents. It appears that conditions limiting occupation to those in need of care and support and receipt of a domiciliary care package of at least 2 hours per week are likely to underpin acceptance of a C2 classification. The 2 hours appears, in some of the cases, to be considered more than would normally be available in sheltered housing. It is argued provision of care by an on-site care team is more than would normally be provided by a warden within a sheltered housing scheme. While domiciliary care can be received in sheltered housing, the receipt of care is not a condition of occupation as it may be in extra care schemes. It is the explicit requirement to be in receipt of care as a condition of occupation that can make the difference.

On the other hand there is a case to state the level of care in not a material planning consideration.  Letters from the ministry dating back over 20 years state this clearly.  For example at an appeal in Hereford

‘the level of care to be provided is not relevant, since the Use Classes Order does not refer to that’ (paragraph 29) (source Tetlow King)

After all a resident of a C3 sheltered housing development could be receiving full time care – it would not switch the use class.

What matters I think are three things

  1. whether it is designed for people who cannot live independently (including independently with warden care) and
  2. whether those design features include elements essential for the care of those who cannot live independently and
  3. whether occupancy is limited by condition to those who cannot live safely in single family C3 dwellings (including conventional sheltered housing with wardens)

If the SoS wants the level of care to be material they should modify the UCO to reflect that. However this approach I think takes planning down a tricky path.



The PAC report, GAP Analysis and the 300k/annum Government Housing Target

The first things the new Communities and Planning Secretaries will have on their plates (potentially after an election) is responding to the HOC PAC report on Planning and the Broken Housing Market 

The Department has a highly ambitious target to deliver 300,000 new homes per year by the mid-2020s but does not have detailed projections or plans on how it will achieve this. Meeting the target of 300,000 new homes a year will need a significant step-up in the level of house building. Current levels are not promising: the number of new homes has increased every year since 2012–13, with 222,000 new homes in 2017–18, but the average number in the period 2005–06 to 2017–18 was still only 177,000 a year. The Department accepts that it will need to transform the housing market to get more new homes built and says that achieving the target would be “very challenging”. Despite having introduced some projects to help, including encouraging small builders through the small builders guarantee scheme and reforming the planning system, the Department simply does not have the mechanisms in place to achieve the 300,000 target. This is compounded by lack of detailed rationale as to why this target was chosen in the first place. It also lacks year-on-year projections on how it will ramp up house building, only illustrative projections which are not in the public domain. To make this even more concerning, the target does not align with the Department’s new method for calculating the need for new homes which shows that just 265,000 new homes a year are needed.

Recommendation:By October 2019, the Department should set out, in a single publicly-available document, the full set of actions it is taking to achieve the target of 300,000 new homes and include year-on-year projections for the number of new homes it expects to be built.

This will be an extremely useful exercise in civil service contingency planning.  To do a GAP analysis on why the 300k target is not being met.  In the same timescale the London Plan panel will be reporting, showing a likely huge gap between what London needs and what it can build creating a huge overspill issue for ROSE and the Camkox arc.

There are too aspects to the problem which are interrelated.  Housebuilders find it hard to build on land not zoned for housing; but despite the NPPF making this easier a large uptick in consents has not, over time. led to a proportionate uptick in  completions.  The central issue of the Letwin review.  The governments standard method has taken one cause of delay from the system but as the PAC says (and the governments says) it doesn’t tally to the 300k target only adding up to 265k homes (assuming 2014 based HH projections).

This is deeply unsatisfactory because despite the government and ONS protestations about the 2016 based HH projections it still allows anti growth protesters (witness the latest local elections) to claim the figures are ‘grossly inflated’ despite current growth deals containing zero ‘arc uplifts’ or uplifts from transfers from ‘land constrained’ areas (such as London).

As the PAC report says:

While the Department does not have detailed calculations as to why the target was chosen, it told us that the figure was based on a number of studies including Kate Barker’s work of 2004 and the Lyons review, which suggested 250,000 new homes and above and close to 300,000 are needed to stabilise prices. The target does not align with the Department’s new method for calculating the need for new homes which shows that just 265,000 new homes a year are needed

This is a mess.  Lets track back over two governments and in that time two methods have been used to estimate how many houses were needed to stabilise house prices.  The first used the departments own econometric model and the former NHPAU estimated it needed around 12% uplift nationally to do so.  Under Cameron despite the NHPAU being abolished the issue didn’t go away and as part of the LPEG report a crude formula based spreadsheet was used to redistribute housing numbers away from poorer paying regions to higher paying ones, even though it meant in many cases lowering housing numbers below need in fast growing northern cities (see this report on the dramatic unjustified deletion of 20,000 homes from the Leeds Local Plan)  and redistributing the numbers towards land constrained areas such as London Boroughs.  The implication was vast economic migration away from cities where people could get a job but not a house towards London where you would be far less likely to afford a house.  It was crazy and with the 2016 based household projections even implied negative household growth in ,many fast growing areas.

The unsatisfactory nature of the current method for setting targets is that the MHCLG has stated it still uses economic modelling for roughly estimating the 300k target but not for setting local plan based ones.  If you want to start your gap analysis this is a good place to start.  Running the MCHLG affordability model on the 2016 HH baseline and then investigating what would happen if HH formation had not been constrained by the housing stock (which dates back well before 2014) using a new baseline for stabilising affordability (the NHPAU used 1987  the government could now use 2010) would give you around 300k units.  What is more if you could apply such a model around functional economic regions, there now being enough data to do so .  This could replace the crude standard method spreadsheets.  You could do so in land constrained and unconstrained modes (using GIS data) and Green Belt off and Green Belt on modes.  The difference being the ‘strategic planning problem’  the amount of overspill growth corridors such as those around London would have to accommodate on top of local demographic targets.

Drilling down to functional housing markets is essential because a gap analysis between the sub-regional need and completions will be different in each.  For example South Hampshire – European sites nitrates issues, Northampton, slow delivery on SUEs and capacity issues on the M1 leading to resistance to creating new ones.  Understanding these gaps is essential to the government tayloring what replaces growth deals with appropriate locally applicable sticks and carrots.  For example one sub-region I know well South Essex. money towards re-routing of the A127 in key areas, and adding a multimodal tunnel to the East Thames River Crossing could open up at least four strategic growth locations.

Here the government could commission a swift series of reports for each subregion/joint planning area/functional city region with consultancies which specialise in each to find out what these gaps are and what the most appropriate stick and carrots to resolve growth resistance.

In terms of the gap between allocation and completion I think the understanding of the ministry has come on leaps and bounds in recent years.  It now knopws to look for comparators either overseas and in the past about when and where completion rates were high.  It is easy to see when and where it was, when there were master developer masterplanned communities releasing parcels to several housebuilders at once, as in the last phase of Milton Keynes expansion.

With many authorities now needing to hit uplifts in their housing completions anywhere between 600-1500/annum that implies one or more master-community type developments, either extensions or freestanding garden communities.  We therefore face a ‘garden communities gap’ .  So far nationaal competitions etc. have failed to fill that gap with all but one or two such winners already planned in local plans.  What is needed is a more sub-regionally based series of initiatives.  Here is where the Oxford Cambridge growth corridor has been such a disappointment.  It gave the impression that the government was going to be proactive in helping to identify where the garden communities gap could be filled, in the corridor or greatest need and left it all to local authorities, who promptly went backwards in a reflex of local fears about locations, sustainability and infrastructure.

This is against the context of concerns for zero carbon development, something that can only be achieved with new zero carbon transport and energy infrastructure, for which there are no integrated regional studies anywhere in the UK.

What is more the garden communities gap requires filling of the master developers gap.  There is a shortage of master developers and Homes England has in some cases stepped in on some long zoned but slow progress sites.  I know many strategic sites where country solicitors are filling in the master developers gap (badly).

An obvious way of filling this gap is tasking Homes England to prepare regional action plans on homes and infrastructure about where the greatest gaps between need and completions are and what the options for bridging this is.  Of course new joint planning bodies would choose following SEA from the options but what we have seen so far is a morbid fear amongst them of even publishing the options – some are  year or two late – for fear of a mighty backlash.  Homes England here could act as a buffer, allowing daylight to appear on what many in the planning community have long felt to be the strategic options, whilst insulting local politicians from having the temerity for even having thought of them.