How realistic is it to expect that the government will meet its target of 300,000 homes and will the 2018 NPPF help it meet this target?
The supply of housing land has been argued over long and hard for many years including since the NPPF was first published in 2012. Key to the presumption in favour of sustainable development, the 2012 NPPF required local planning authorities to maintain a 5 year land supply of housing sites or face the consequence of planning permissions being granted at appeal. The 2018 NPPF published on 24 July, has introduced at paragraph 60 the following.
“To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.”
Paragraph 11, 2018 NPPF sets out the context for the continued application of the presumption in favour of sustainable development and includes the theme that strategic policies should, as a minimum, provide for objectively assessed needs for housing. A consultation on the standard methodology was undertaken in 2017. Although it is hoped that it will achieve the objective of speeding up the preparation of plans and foreshorten the amount of time spent on this issue at appeals, it is anticipated that the result of this new methodology may be mixed across England.
It may be expected that where the result for a local planning authority reduces the amount of land required to be allocated, this may be welcomed with open arms by some members. However, equally in areas where larger amounts of land are required, it may be that the local authority might endeavour to demonstrate that the “exceptional circumstances” referred to in paragraph 60 apply to that local authority. It remains to be seen how this will work in practice and it is not going to be applied to plans that are submitted for examination prior to November 2018 so we may have to wait some time to see.
The 2016-based Sub National Population Projections were published by the ONS on 24 May 2018. These provide projected population growth statistics for the period 2016-2041 for each local authority in England based on the 2016-based National Population Projections that were published in October 2017. The standard method referred to in paragraph 60 of the 2018 NPPF will look at the growth projected over the first 10 year period.
Although the average growth is predicted in this period to be 5.9%, 15 local authorities in the north of England are all predicted to see a decline. However, although generally the 2016 based statistics suggest that housing need might reduce from the assessments based on the 2014 statistics, the location of areas of growth is spread across areas such as the south west, midlands, central London and around conurbations in the north of England. In essence, however, we will have to wait for the projections that are due to be released in September before we can see how this will impact on the standard methodology.
How realistic is it to expect that the government will meet its target of 300,000 homes and will the 2018 NPPF help it meet this target? 300,000 homes per year was a substantial increase on the previously seemingly ambitious target of 250,000 homes. Although progress has been made in increasing the supply of new homes, with completions in 2017 up 16 percent on 2016 at 163,250, there is still a gulf between the target and actual completions.
A decrease in the population projections may hinder the acceleration as some local authorities will see this as an opportunity to try to put the brakes on and argue using the standard methodology that it has a 5 year land supply negating the need to allocate more land for housing.