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22 July, 2024 · 3 min read

WHAT NEXT FOR HOUSING DELIVERY?

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In her first major speech of the new government, Chancellor Rachel Reeves highlighted the importance of planning and planning reform, making it clear both were in the national interest. The King’s Speech this week continued to reflect its importance.

With a welcome return to strategic planning and housing targets, we believe evolution not revolution is all that is needed initially to ensure the planning system can play its part in the much-needed delivery of new homes at the level once again targeted by the Central Government.

The amendments below would have a demonstrably positive impact.

1) BROWNFIELD, GREEN BELT AND GREY BELT

Brownfield land should, of course, remain a priority for new housing development. Proximity to existing transport and social infrastructure and services is an important consideration, and the potential for higher-density development in strategic urban sites remains the best way to deliver new homes where they’re needed without encroaching on undeveloped land.

Self-evidently, this is not enough to meet the 300,000pa target. A mandatory Green Belt Review and the setting of clear guidance on how within this review Grey Belt sites should be appraised would assist in identifying opportunities where there is a strong case for appropriate new development outside of urban area.

It has already been confirmed that the definition of the Grey Belt will go beyond previously developed land and should have a more significant positive impact on housing delivery than the exception to inappropriate development in the Green Belt contained in paragraph 154(g) of the National Planning Policy Framework (NPPF).

There now needs to be a clear and concise definition of Grey Belt within the NPPF and this needs to be as objective as possible to be effective. The current 154(g) exception is highly subjective, requiring an assessment of the impact on openness and harm to the Green Belt. The setting of a more objective approach can only serve to provide greater certainty in the decision-making process.

And it is not sufficient to target Grey Belt land without looking at other considerations that will impact delivery, such as accessibility, contamination and ecology. Not every Grey Belt site will be suitable for new homes, but those that are should be optimised. A clear set of criteria would allow different elements to be compared and balanced.

It is paramount that Green and Grey Belt reviews are undertaken immediately if development is to be unlocked in a timely manner and we welcome the Chancellor’s reference to the use of Ministerial Statements to Local Authorities to direct this.

2) LOCAL AUTHORITY ACCOUNTABILITY

The Chancellor was clear in her speech that the government would not allow Councils to use Green Belt as an excuse to avoid meeting their housing need. At the local authority level, where political control is varied and local democracy comes into play, the Central Government should make clear both the incentives and penalties for ensuring housing needs are fully met and ideally exceeded. In this context, an update to the NPPF needs to make clear that a lack of housing in areas with unmet needs would constitute part of a Very Special Circumstances case.

Central Government’s intervention in live but stalled applications is fully supported. Given the time and investment required to pull new applications together, unblocking stalled applications should be a priority.

We would also encourage further consideration of a Development Consenting Order style of approach for strategic scale residential-led developments which would allow applicants to submit directly to Central Government for schemes of a certain scale rather than to LPAs.

3) MORE RESOURCES AT EVERY LEVEL

An extra 300 planning officers dispersed across the country will not materially improve the system. It needs significant resource investment at every level. Moreover, the planning regime needs to empower Councils to take the hard decisions having fully understood professional Officer recommendations.

This isn’t just about local authorities. Adequate resourcing of the Planning Inspectorate (PINS) and wider statutory consultees is vital. At present, all of the key consultees, including Natural England, the Environment Agency, National Highways and PINS, are materially under-resourced, leading to regular and lengthy delays in planning decision-making.

Of course, the detail of new policies is always more important than the headlines, and as rapidly as the new government wants to tackle these issues it will take time for any new approach to bed. Nevertheless, with a new NPPF out for consultation this month and ideally adopted within the first 100 days, the pace has been set.

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