The housing shortage in the UK looks likely to continue its dominance of headlines this year. The planning system is often blamed for delaying house building which has contributed to spiralling house prices and a shortage of affordable housing.
The Government has previously suggested it aimed to see one million homes built by the end of the current parliament. Achieving that target would entail immediately building at least 200,000 new homes a year – a level of housebuilding not seen in England since 1989 (Currently, the UK builds around 170,000 new homes annually). That pledge has of course been cut short by the recent announcement of a general election having been called, but it is unlikely that the overriding issue of housing need across the country is going to have any less force moving forward into a new administration.
The blame for the shortage is often laid at the planners’ door but, whatever the reasons for the shortage, the consequences have seen rising prices in London, the South East and some other parts of the country. We are now at a point where over 40% of Local Planning Authorities do not have a plan that meets projected growth in households in their area. For example, the Arun District in West Sussex has a five-year housing land supply shortfall amounting to over 4,000 homes. Or, looking at it another way, just 2.1 years supply rather than the required 5-year minimum.
This year we have prepared a visual to demonstrate all the opportunities available to make representations to the Local Plan process.
Landowners can look at strategic promotion through the Local Plan initially. The Local Plan is produced by the Local Planning Authority (LPA) and contains all the policies the authority uses to guide their development decisions. It states where land will be developed, what for and in what quantity. Land is allocated in the Local Plan expressly for certain uses – not only housing, although this is the key use for which most look to secure allocations.
A Call for Sites is issued at the initial evidence gathering stage as LPAs seek information about potential development sites to assess as part of their Strategic Housing and Economic Land Availability Assessment (SHELAA). As a planning team, we regularly make these representations on behalf of our clients.
The SHELAA eventually feeds into the Local Plan when the LPA comes to identifying specific sites for housing and economic uses. As the Local Plan goes through its many stages of drafting and consultation, there are opportunities for us as planning agents to make further representations to promote our clients’ land. Once a parcel of land is included in the Local Plan as an allocated site for local housing, it doesn’t guarantee planning permission but means the principle of development has been accepted and permission will hinge more on circumstantial or scheme-specific factors. Local plan allocation represents the longer term strategic promotion of land for development. It is a process that developers and planning consultants are heavily involved in.
LPAs are required to demonstrate a five-year supply of housing to meet their identified needs. Those that cannot are in a more vulnerable position where housing is concerned and, if faced with an otherwise acceptable scheme in a location they do not want, have reduced weight given to their policy to fall back on as a defence. Those policies guiding housing supply are held to be out of date if there is no demonstrable 5-year supply, meaning little weight can be afforded to them in decision making.
Many Local Authorities across the South East are struggling with housing supply and racing to get a Local Plan in place to ensure they are not faced with such a scenario. This can open a window for landowners or developers under the right circumstances and with the right advice to make a speculative application ahead of allocation. This represents the shorter-term route to development. It is not necessarily the most straight forward process and often it involves navigating the appeal process, but if successful it can offer an opportunity to bypass the lengthy Local Plan allocation process.
The Government white paper, ‘Fixing our broken housing market’, released on 7 February 2017 sets out an emerging range of aspirations to increase housebuilding, and to support policy around development. One of the measures set out in the white paper is to make a standardised calculation for measuring LPAs’ Objectively- Assessed Need (OAN) for consistency. This would make it easier to compare authorities and evaluate their performance. Another proposed measure is to add a 20% buffer to the OAN in LPAs that demonstrate significant persistent under-delivery of housing. This will force them to identify further sites, speeding up delivery. Now is the time to assess the deliverability of your land.