Objectively Assessed Housing Needs

Transcription

1 Objectively Assessed Housing Needs Matthew Spry 17 th March 2014

2 Structure 1. The policy requirement 2. What s been happening with Local Plans? 3. Practical issues 4. Conclusions 2

3 1. The policy requirement 2. What s been happening with Local Plans? 3. Practical issues 4. Conclusions 3

4 The NPPF introduced a marked change in role of housing needs. Compare PPS The level of housing provision should be determined taking a strategic, evidence-based approach that takes into account relevant local, subregional, regional and national policies and strategies achieved through widespread collaboration with stakeholders. 33. In determining the local, sub-regional and regional level of housing provision, Local Planning Authorities and Regional Planning Bodies, working together, should take into account: Evidence of current and future levels of need and demand for housing and affordability levels based upon: - Local and sub-regional evidence of need and demand, set out in Strategic Housing Market Assessments and other relevant market information such as long term house prices. - Advice from the National Housing and Planning Advice Unit(NHPAU) on the impact of the proposalsfor affordability in the region. - The Government s latest published household projections and the needs of the regional economy, having regard to economic growth forecasts. 4

5 The NPPF is far more direct. It says: Local planning authorities should positively seek opportunities to meet the development needs of their area; Local Plans should meet objectively assessed needs unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits when assessed against the policies in this Framework as a whole; or Specific policies in this Framework indicate development should be restricted. Paragraph 17 of the NPPF states that every effort should be made objectively to identify and then meet the housing needs of an area. Paragraph 47 states that local planning authorities should use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing. 5

6 Implications - Muscular Localism A focus on the local An emphasis on growth 6 Drives decisions down to give more local control Exposes evidence and judgements on growth to more scrutiny Incentivises growth Positive Planning Cultural Change every effort should be made objectively to identify and then meet needs Raises the bar on: a) expectations that growth should be met b) Quality of justification of harm if development to be turned down

7 1. The policy requirement 2. What s been happening with Local Plans? 3. Practical issues 4. The new NPPG 5. Conclusions 7

8 Significant work still to do setting housing targets in Local Plans Local Plan (Strategic issues/ core strategies ) Status as at March 2014 (% of Local Authorities) Local Plan Found Sound/ Adopted Post-Final NPPF Local Plan Found Sound/ Adopted Post-Draft NPPF Local Plan Published/ Submitted for Examination Pre-NPPF Local Plan or No Local Plan 8

9 What is happening with housing targets in Plans? Research reviewed all Local Plans outside London formally submitted or examined in 24 months March 2012 March 2014 Recorded: Submitted housing target Outcome of examination Target post-examination 109 Local Plans examined or submitted for examination 40 Local Plans found sound 15 Councils Local Plans withdrawn Benchmarked: RS target Relevant H/H projections (2008 or 2011-based) 9

10 Time it takes for plans to get through is increasing Average time from Submission to being Found Sound Pre-NPPF Submission 9.7 months Found Sound Post-NPPF 13.7 months Months Average time from Submission to being Adopted Pre-NPPF Submission 11.6 months Adoption Post-NPPF 15.1 months Months 10

11 Housing is the factor driving delays on most plans 40 Found Sound 37% Found Sound 109 Plans submitted Post-NPPF 49% Ongoing 54 remain ongoing Nearly half of these have experienced delays: Suspension Further consultation Housing target most common point of contention 14% Withdrawn 15 withdrawn 11

12 Almost a quarter of sound Plans require an early review 37% Found Sound 23% Subject to immediate/ early review 109 Plans submitted Post-NPPF 49% Ongoing 14% Withdrawn 12

13 Nearly half of ongoing plans require further amendments/work, mainly on housing 37% 109 Plans submitted Post-NPPF 49% Found Sound Ongoing 48% Require Modifications 69% Require more evidence of objectively assessed housing need 14% Withdrawn 13

14 Withdrawn plans stumbling on housing numbers Hartlepool Main reason withdrawn Housing Numbers Failure to meet duty to cooperate 37% Found Sound Kirklees Salford North West Leicestershire Kingston upon Hull Central Lincolnshire (Lincoln, North Kesteven, West Lindsey) Melton 109 Plans submitted Post-NPPF 49% Ongoing Tamworth Coventry Aylesbury Vale Hart Medway Waverley 27% Main reason withdrawn due to failure to meet duty to cooperate 14 14% Withdrawn 73% Main reason withdrawn due to housing numbers

15 Over half of submitted Plans proposed housing targets lower than RS equivalent and HH projections Proposed housing targets compared to RS and Household Projections for all plans submitted Post-NPPF RS Targets CLG HH projections 24% 24% LPAs proposing an increase on RS LPAs proposing RS figure 45% LPAs proposing more homes than household projections 52% LPAs proposing a reduction on RS 55% LPAs proposing fewer homes than household projections 15

16 Later plans more likely to have targets exceeding relevant HH projections Plans submitted BEFORE 9 April 2013 and subject to review against 2008 Household Projections Plans submitted AFTER 9 April 2013 and subject to review against 2011 Household Projections 38% LPAs proposing more homes than household projections 56% LPAs proposing more homes than household projections 62% LPAs proposing fewer homes than household projections 44% LPAs proposing fewer homes than household projections 16

17 As the NPPF and scrutiny process beds in, its taking longer for plans to get through Average time from Submission to being found Sound NPPF Year 1 Submission 12.1 months Found Sound April 2012 March 2013 NPPF Year months April 2013 March 2014 Months Average time from Submission to being Adopted NPPF Year 1 Submission 13.7 months Adoption April 2012 March 2013 NPPF Year months April 2013 March Months

18 A third of sound Plans had to increase their housing targets after submission 40 Plans found sound Post-NPPF 65% (26) 35% (14) No change to housing targets after submission Required increase to housing targets after submission This figure will increase as delayed plans are adopted 18

19 As the NPPF bites, more plans are proposing increased housing targets In the first year of NPPF none of the Plans found sound/adopted proposed an increase against RS target (over half proposed a reduction) In the second year 43% of Plans found sound/adopted proposed an increase against RS target NPPF Year 1 NPPF Year 2 April 2012 March 2013 April 2013 March % Approved Plans proposing RS figure 43% Approved Plans proposing an increase on RS 52% Approved Plans proposing a reduction on RS 19% 38% Approved Plans proposing RS figure Approved Plans proposing a reduction on RS 19

20 1. The policy requirement 2. What s been happening with Local Plans? 3. Practical issues 4. Conclusions 20

21 The housing evidence arms race Option 1 numbers District-wide needs studies SHMAs Economic forecasts New projections 21 Migration and other demographic assumptions Economic activity rates Market signals

22 Key practical areas A. Format and scope B. Projections, migration and headship rates C. Jobs growth / forecasts / economic activity rates D. Affordable housing E. Unmet need F. Market Signals G. Positive not reductive 22

23 A. Format and scope Many early plans relied on old SHMAs supplemented by local needs studies Assessment of need must be within a SHMA (NPPF para 159) Meet needs and cater for the housing demand and identify scale of supply to meet that demand (NPPF and NPPG) Scale and mix and range of tenures Only need scenarios reasonably expected Facts and unbiased evidence / avoid applying constraints (a matter for the plan) No one methodology for a definitive assessment Cover housing market area (defined by prices, migration, search patterns, travel to work, retail, school catchments) 23

24 B. Projections CLG Household projections published by CLG are the starting point Latest projections were released 09 April 2013 Based upon the ONS 2011-based Interim Sub-National Population Projections (i.e. converts ONS population projections into households) Supersede the previous 2008-based projections (which covered period 2008 to 2033) Only covers period 2011 to 2021 Can deviate where justified. Areas of common debate: Headship rates post-2021 Migration assumptions (based on new Mid Year Estimates) 24

25 C. Jobs Growth, forecasts and economic activity rates Jobs forecasts a common feature of most evidence-work often drive growth higher than demographic trends How many homes are needed to sustain a given level of job growth? An outlier (ie Lichfield) or a driving assumption (South Worcestershire)? Economic forecasts Reliability Status Alignment with economic policies of Plan LEP plans Commuting / labour force:housing ratio Propensity of residents to work (retirement ages, changes in unemployment, vacancy to unemployment ratios etc) 25

26 D. Affordable Housing Well established methodology (largely as per previous SHMA guidance) Unmet gross need (homeless, temporary accommodation, overcrowding, concealed households, existing tenants in need, others) Newly arising households in need Price-income relationship Current affordable housing supply and re-lets Annual flows / affordable housing as a % of overall delivery An increase in total housing figures should be considered where it could help deliver required number of affordable homes 26

27 E. Unmet need Needs from within HMA SHMA Needs outside HMA Other SHMAs (if available) Benchmark against HH Projections Jobs growth Emerging / future targets London (42K against >52K pa) 27

28 F. Market Signals Neglected part of NPPF (para 17) given new life by NPPG Land prices House prices and rents Affordability Rate of Development Overcrowding Accepts basic Barker Review / NHPAU premise that increased supply will help reduce relative problems of affordability Comparisons: HMA Similar types of areas Nationally Worsening trend in any indicator requires upward adjustment compared to ones based solely on HH projections. Worse affordability constraints = bigger supply response 28

29 G. Positive not reductive Soundness Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth (para 17) Positively prepared the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements (para 182) Warning signs: Investing energy in trying to justify downward pressure on housing target at every assumption Relationship of evidence to political decision making process Obscure / black box analysis Turning a blind eye to justified upward pressure on the target 29

30 1. The policy requirement 2. What s been happening with Local Plans? 3. Practical issues 4. Conclusions 30

31 Conclusions Housing needs evidence (and how to respond to it) remains greatest hurdle to getting plans adopted Early review get-out clause no longer justified by RS legacy Most Local Plan Inspectors attuned to issues/risk areas (as are objectors) Greater role in applications and appeals (Hunston) Arms race in evidence, but LPAs (and their consultants) should avoid trying too hard No one methodological approach that will provide a definitive assessment (NPPG) Look at NPPF and messages about positive planning 31

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