Sajid Javid has talked of a ‘Once and for All’ solution for housing and in a speech last week criticised his ministerial predecessors for not making tough long term decisions.
With the Housing White Paper delayed until the new year -lets hope number 10 Spads are not watering it down – hence perhaps his forthright speeches to get the policy message out first on tough issues like Green Belt – there is a chance to refine it.
Quite simply there are two interrelated problems the white paper must tackle – we have not been planning for enough housing in the right places, and secondly not enough of those are being built out. All other issues including affordability, and the volatility of the housing market to boom and bust, flow from this.
The last four years have seen a failed experiment in trying to devolve responsibility for housing land supply to the lowest possible level. For one brief period the government dropped maintaining a local plans database. That experiment has failed. Whilst maximising local and neighborhood responsibility it wont fill a widening gap as local plans fall ever further behind. A ‘once and for all’ solution has to provide a government backstop to ensure enough land is allocated. The idea of bridging the gap through appeal led planning as a stick to get plans adopted has been tried and failed, it didn’t bridge the gap of land lost through late local plans and simply shifted sites from accessible urban extensions to vast village applications of often 150 units plus in barely accessible locations. Nor did it solve the increasing issue of overspill need from the major cities and Green Belt areas as highlighted in the LPEG report.
A once and for all solution requires universal up to date local plan coverage where plans cumulatively meet all housing needs – ensuring enough land is allocated in the right places.
Currently the baseline is LPAs own assessment of OAN – Objectively assessed need. However LPAs rarely correspond to housing market areas, and we have seen spectacular plan failures, like St Albans, where LPAs have not even participated in Strategic Housing Market Assessments.
The Housing Corporation could be mandated to:
- Define HMAs nationally
- Set out a standard methodology – ensuring in and out migration projection nationally add to zero
- Produce a starting point figure for OAN for each HMA – it them being for local and subregional partnerships to apportion between themselves or to other partnerships when there are constraints.
- Require the OAN apportionment agreed by the partnership to be agreed by the HCA before local plan consultation, and then for the matter to be fixed (apart from HCA led updates)
This would drastically reduce the housing numbers game paper chase then slows plans down so much. It is unapologetically an NHPAU like structure, but with the advantage of being under the wing of a delivery agency. Also it avoids the risk of the current balanced structure of needs not adding up to OAN, inflating numbers always create unnecessary resistance. If meeting the OAN nationally is a national priority the numbers should not be argued per local authority unless there are exceptional local constraints or opportunities.
But an HMA partnership might struggle to meet all need within its boundaries. Look at the overspill of need in London, Brum and Bristol. This leads to the issue of Green Belt.
The Green Belt was never an objective in its own right. It was always to shape urban form as part of strategies to meet the housing needs of cities in full by diverting need to new towns and expanded towns elsewhere. As such they had life spans in structure plans of 20-25 years. With the demise first of new towns (after a temporary demographic blip city populations stopped shrinking in the 1980s) then structure plans and then regional strategies Green Belts became a purely negative measure and hence vulnerable to some government in the future sweeping them away. If Green Belts are to be saved we have to renew that positive purpose.
Currently national policy says the extent of Green Belts is ‘generally fixed’, however that could only apply when housing land requirements were ‘generally met’. The White Paper needs to be clear that to ensure the permanency of Green Belt we need to make relatively limited changes to them where they have sustainable locations for housing development.
Currently following the ‘Boles doctrine’ Green Belt can be considered a policy constraint even if the land has no environmental value. Quite right as Green Belt purposes are to deliver a housing strategy – including stopping urban sprawl. However the Housing White Paper needs to state that where land has limited environmental value it should only be considered a policy constraint where there is a strategy to meet OAN, and Green Belt is necessary to guide development to sustainable locations in that strategy. Accessible locations, such as around stations on land of limited environmental value (the valued landscapes test) should be considered as part of such strategies (the green belt purposes test). This would likely involve relatively small scale loss nationally (less than 5% of Green Belt) and should form part of strategies where existing and new Green Belt are enhanced in terms of public access and environmental quality. Where new settlements and urban extensions are formed new Green Belt can be considered where it is necessary to protect the setting and secure the form of the new development. This goes beyond ‘exceptional circumstances’ – if the White Paper sets an rule it is no longer an exception. When Green Belts were drawn up it wasn’t exceptional and also when there is strategic revision – the exceptional circumstances test applies only after Green Belts – fulfilling their strategic planning purpose – have been made again permanent.
In this way there would be a ‘strategic swap’ of Green Belt land – ex-post. It would be unwise however for the government to require an ex-ante swap as a condition of Green Belt development. That would be an additional hurdle and because of dispersed implementation bodies where Green Belt swaps have been proposed they haven’t come off (example Stevenage).
We have an issue however in that Inner ROSE authorities and some London Boroughs are considering Green Belt reviews and other are not and the Mayor of London has the power to stop all such in London in the revised London Plan. Also authorities around London could be looking at accommodating 1.5 million extra housing around London over the next 20 years – where is this to go?
Clearly some kind of political ‘win-win’ deal between Javid and Khan needs to be done. What might that deal look like? Currently the Mayor is not bound by the legal requirements of DTC or soundness, meaning he can simply ignore panel reports.
Javid might also be unwilling to resurrect some kind of regional structure for London and the South East – although the area is clearly too large for a combined authority fix.
The LPEG report recommended corridor studies, as has the Infrastructure commission for Oxford-MK-Cambridge corridor.
You could see an arrangement whereby the HCA and IC jointly commission five corridor studies around London.
- Western Wedge – The Wedge
- London-Herts/Cambridge-Peterborough – The Arrow
- Thames Gateway (inc Essex, Haven Gateway and Northern Kent) – The Gateway
- London to Gatwick/Brighton, Solent and South Kent – The Kite
- Oxford-Northampton/MK/Aylesbury-Cambridge-East Coast Ports – The Arc
These would be coordinated by a committee chaired by Khan with Javid as vice chair and as Rose re as another vice chair. The quid pro quo for this major responsibility would be to put the London plan on the same dtc/soundness level playing field as everywhere else. London could also be granted the ability to make some London specific variation in NPPF policy providing housing white paper objectives were met.
These corridor studies would be let to consultants with LPA secondees. The mistakes of previous corridor studies must not be repeated, where the aim wasn’t clearer and consultants looked at almost every plot of land between London and Cambridge for example rather than accessible land around stations and towns.
There could be similar arrangements around Bristol and Brum building on existing tentative LEP work.
With a broad strategy recommended how should it be approved?
The easiest way would be a publish an NPS for Garden Communities under the NPS regime. That way there would be consultation and a commons vote.
Then you get on to how they would be built? The easiest way would be to set up development corporations under a refreshed New Towns Act, including a mechanism for them to purchase land at close to existing use value + say 20%, allowing land value capture to pay for them in large part. We need to learn the lessons of development corporations set up under the 1980 act which couldn’t cover rural areas and hence didn’t have plan making powers – useless.
This would give the HCA a significant land bank, and the ability as originally proposed by Danny Alexander, of the Treasury being able to directly intervene to increase housing numbers when completions are too low, at limited cost.
However the majority of housing will be outside such areas, we need the modern equivalent of the 1919 Addison Act to require recalcitrant authorities such as Worthing to get a move on with direct or commissioned build of affordable housing.
Powers exist to intervene to ensure local plans come forward in due time where LPAs are obstructive. It is largely a deterrent power but it wont be a deterrent unless a few examples are made – such as St Albans.
There will also be increased attention on higher density and brownfield development including I hope a more comprehensive and considered approach towards a full zoning and subdivision based system. Perhaps some of the Garden Communities could be used as trials as full form based zoning masterplans – as some of us prepare every day of the week for towns and cities being built around the world.
All in all these measures would constitute a long-term ‘once and for all’ solution for ensuring we return to the kind of build rates we saw in the 50s and 60s.