Tandridge – Without Government Support Strategic Developments are Stuffed – So why do they pretend its a local decision?

Inspectors Report

  • In summary – South Godstone Garden Community only deliverable with major transport improvements
  • Funding for these rejected by government because of land assembly issues
  • Garden Communities bid rejected because of land assembly issues.

With a willing government you could have had a development corporation land assembly and transport improvements all within the plan period.

The circular logic of the government argument reveals a hidden policy – are you in the Green Belt – sorry guys your on your own you need to sort out these issues wthout government help. Which just pushes the overspill problem and the 300k national number fruher and further out in time and further and further out in space to places like the arc.

A Major Change to Green Belt Policy in Yesterdays Announcements?

Government Response

More broadly, we heard suggestions in the consultation that in some places the numbers produced by the standard method pose a risk to protected landscapes and Green Belt. We should be clear that meeting housing need is never a reason to cause unacceptable harm to such places.

Within the current planning system the standard method does not present a ‘target’ in plan-making, but instead provides a starting point for determining the level of need for the area, and it is only after consideration of this, alongside what constraints areas face, such as the Green Belt, and the land that is actually available for development, that the decision on how many homes should be planned for is made. It does not override other planning policies, including the protections set out in Paragraph 11b of the NPPF or our strong protections for the Green Belt. It is for local authorities to determine precisely how many homes to plan for and where those homes most appropriately located. In doing this they should take into account their local circumstances and constraints. In order to make this policy position as clear as possible, we will explore how we can make changes through future revisions to the National Planning Policy Framework, including whether a renaming of the policy could provide additional clarity.

This is clumsily worded. The dictum that housing need was not a very special circumstance (only applying to dm decisions) was DROPPED from PPG several years ago. Precedent and caselaw is clear that ‘exceptional circumstances’ can be met by high housing need Gallagher Estates v Solihull Ltd, IM Properties V Lichfield

There is a mistake also in treating Green Belt as an environmental designation. It isnt. It is there to stop sprawl, something that a strategic review might better accomplish than building beyond the Green Belt

New Standard Methods Ridiculous Definition of urban – Newcastle is, Gateshead Isn’t, Wolverhampton is Walsall isn’t etc.

The guidance on the new standard method has been published following a parliamentary statement, and our concerns over how they will define the 20 largest urban areas are confirmed. It is an even cruder and worse method than the old principal urban areas method. Revised Guidance

Response to consultation

Having taken the responses into account, we have decided the most appropriate approach is to retain the standard method in its current form. However, in order to meet our principles of delivering more homes on brownfield land we will apply a 35 per cent uplift to the post-cap number generated by the standard method to Greater London and to the local authorities which contain the largest proportion of the other 19 most populated cities and urban centres in England. This is based on the Office for National Statistics list of Major Towns and Cities, ranked in order of population size using the latest mid-year population estimates provided by the Office for National Statistics.

As at the date of this government response and in order of size beginning with the largest as per the 2019 mid-year estimates (latest estimates), these places are: London, Birmingham, Liverpool, Bristol, Manchester, Sheffield, Leeds, Leicester, Coventry, Bradford, Nottingham, Kingston upon Hull, Newcastle upon Tyne, Stoke-on-Trent, Southampton, Plymouth, Derby, Reading, Wolverhampton, and Brighton and Hove.

The 20 authorities which contain the largest proportion of the city or urban centre’s population will have the 35 per cent uplift applied. The cities and urban centres list was objectively determined using national datasets provided by the Office for National Statistics to determine the urban local authorities which contain the largest proportion of the 20 most populated cities and urban centres in England.

Firstly the whole consultation was about giving less emphasis to household formation and more on number of houses. This was botched due to giving the latter too little weight and affordability too little, resulting in the opposite outcome to what was intended. Less not more to urban areas. What is more the discredited cap which kept numbers well below 300k is retained. The cap says its hard to deliver increases so large then the uplift undoes that but only for these 20. It says its about need not constraints or targets then for these areas only says the opposite. What a mess.

Is the London plan now out of date the very week it is being finalised?

It is clear that in London, in the medium term, there will need to be a much more ambitious approach to delivering the homes the capital needs. The Secretary of State for Housing, Communities and Local Government expects to agree the London Plan with the Mayor shortly. This new plan, when adopted, will set London’s housing requirement for the next 5 years. The local housing need uplift we are setting out today will therefore only be applicable once the next London Plan is being developed. 

So numbers in London will somehow double in the next London Plan review – even though the minister has directed changes which will reduce capacity for major sites by 20% from what was assessed in the London plan capacity study. This is a fantasy. What is worse is the impact this will have on overspill. Under the previous method the new London Plan was undershooting need by 40,000 a year. Which you could legitimately could say should be met through overspill. Beyond 2026 you could no longer say that. London target would rise from 52,000 in the London plan (need under old SM 54,000) to 76,000 /annum, though less than the 94,0000 per annum proposed in the summer consolation. The real tragedy on this is the postponement for 5 years on agreeing the scale of London’s overspill, killing off probably strategic scale Garden Communities meeting wider than a local need. It also postpones for 5 years at lest hitting the 300k plus target as without a London uplift too much weight is given to other urban areas.

The justification for using old HH projections has changed.

We will continue to use the 2014-based household projections. The government has carefully considered whether to use the 2018-based household projections and has concluded that, due to the substantial change in the distribution of housing need that would arise as a result, in the interests of stability for local planning and for local communities, it will continue to expect only the use of the 2014-based projections.

So the O in OAN no longer stands for objective but outdated. The disruption was caused by HH formation playing less and less relevant as suppressed formation due to lack of housing to form into played a less and less a role. Just drop its use and rely on population and a needs formula based on a proxy for concealed household (overcrowding) instead.

But worst is the defintion of urban which misses out more than half of the 20 largest conurbation.

Lets look at where is missed out. Note the defintion – Greater London and local authorities, So the definition of Manchester is the Borough not the combined authority, same with Brum etc. Which misses out:

  • Birmingham – misses out Solihull
  • Liverpool – misses out the whole of the rest of Merseyside and the Wirral
  • Bristol –  South Gloucestershire (most of North Bristol including all its large Brownfield sites)
  • Manchester – all of the rest of Greater Manchester – Salford, Rochdale etc. which contain all of the large brownfield sites outside the city centre
  • Sheffield – all of the rest of the South Yorkshire authorities – Wakefield etc.
  • Leeds – misses all of the rest of West Yorkshire apart from Bradford – Halifax, Huddesfield etc.
  • Leicester – all of the authorities which form part of the Leicester conurbation including Oadby and Wigston.
  • Coventry – Bedworth
  • Bradford – see under Leeds
  • Nottingham – all other Nottingham conurbation authorities Broxtowe, Gelding etc.
  • Kingston upon Hull – None
  • Newcastle upon Tyne – the whole of the rest of Tyneside – Gateshead etc. The whole of Wearside
  • Stoke-on-Trent – Newcastle under Lyme missed
  • Southampton, Portsmouth- the whole of the rest of the PUSH conurbation
  • Derby – Parts of the Derby conurbation within the three South Deryshire authorities
  • Reading – Catersham
  • Brigton and Hove – adjoining urban areas in Adur and Worthing

This totally undermines the three reasons given.

  • Maximise existing infrastructure – it misses off most urban infrasyticture and overloads a few districts based on often arbitrary boundaries
  • Utilising released retail and commercial land – it misses off the vast majority of retail and commercial land in England
  • Climate targets – by focusing on only a few areas travel distances are enlarged.

Lets be clear this is spatial illiteracy. All you had to do was print off a map and look. Did they, do any senior ministry official even have GIS installed on their desktop. What I suspect is that civil servants having had hairdryer treatment from the Minister for botching the last formula tried the old civil service method – giving what the minister and PM EXACTLY what they had asked for however ridiculous or impractical it was.

What is worse this option was never even consulted on. Birmingham, Newcastle etc. I suspect a swift and successful legal challenge.

Ill separately blog on a profound change to Green Belt policy.