Affordable Housing
A core aspiration of the Government’s planning reforms is to help more people on to the housing ladder. Reflecting the 2017 Budget, the draft proposes that authorities support the development of entry-level exception sites which are outside existing settlements and on land which is not already allocated for housing. These sites should comprise a high proportion of entry-level homes that will be offered for discounted sale or affordable rent.
The updated glossary proposes a broader definition of affordable housing which now includes starter homes, a new form of affordable housing for first time buyers. The proposed wording states that the definition of a starter home should reflect the meaning set out in statute at the time of plan-preparation or decision-making.
Eligibility to purchase a starter home will be restricted to those who have maximum household incomes of £80,000 a year or less (or £90,000 a year or less in Greater London).
Revised Planning Practice Guidance (PPG)
In addition to the proposed updates to the NPPF, last week also saw a number of key changes made to the Planning Practice Guidance (PPG). PPG comprises 51 pieces of concise individual guidance covering a range of planning-related topics, from appeals to advertisements to air quality. Seven of the PPG documents were updated on 22 February 2018. The key changes within each are:
- Fees for planning applications - Various amendments have been made throughout to reflect the 20% increase in planning fees recently introduced by the Town and Country Planning (Fees for Applications, Deemed Applications, Requests and Site Visits) (England) Regulations 2017.
- Neighbourhood planning – Following the Neighbourhood Planning Act 2017, a number of modifications have been made to PPG. These include guidance on how amendments can be made to boundaries of neighbourhood areas, additional information on the Independent Examiner’s role in considering a proposal for the modification of a neighbourhood plan, information on changes to the process of Referendum and bringing the neighbourhood plan or Order into force and additional text reflecting new legislation which gives the community greater powers to amend designated neighbourhood areas.
- Community Infrastructure Levy (CIL) – Guidance on CIL has been amended to reflect changes regarding the process of exemption of ‘self-builders’ from paying the levy, including further explanation of the application process that needs to be followed to gain a self-build exemption.
Analysis
There are a number of changes proposed to the NPPF which are to be seen as an attempt to address the on-going housing crisis. The standardised methodology for calculating housing need should be welcomed as a tool to hopefully speed up both plan-making and
decision-taking and reduce time spent at appeal analysing matters of housing demand and supply. Furthermore, the new housing delivery test could present new opportunities for land owners and developers, as will the measures to encourage the redevelopment of under-utilised retail or industrial space for residential purposes.
There are some helpful references to further emphasise the suitability of urban brownfield land for housing and to encourage the release of sites which have no realistic prospect of being taken up for their designated use. This may well help to unlock stalled retail supermarket sites or longstanding vacant employment land which is unattractive to the market. The delivery of affordable housing is to be boosted although there is no mention of a specific delivery vehicle for the numbers required (such as Local Authority
build).
There are clarifications around the Green Belt too, allowing Neighbourhood Plans, which seek to deliver new development, the power to do so by amending the designation but only where this is based on appropriate needs evidence. Affordable housing on brownfield land which does not reduce openness is to be added to the list of development that is not inappropriate, however the sanctity of the Green Belt is to be preserved and is still to be seen as a last resort for Councils planning where to locate their housing and employment requirements.
The draft follows through on the White Paper, in proposing to allow Councils to reduce the standard time limit for implementation of consents from three to two years which could create significant pressure on sites with complex technical issues but
is to be seen as a “stick” to speed up housing delivery. Pressure is also proposed to be placed on Councils should delivery fall below 75% of the housing target, with an automatic presumption in favour of housing where this is the case.
Both the Prime Minister and Secretary of State have been at pains to acknowledge and highlight the major shortcomings of the housing market in England however the amendments proposed would appear to be a continuation of a theme, incremental change, and cannot be described as radical. The sheer scale of the housing crisis requires fundamental change to the way housing is both planned for and delivered, and the consultation will be a disappointment to those expecting major change. It can best be described as an attempt to further streamline the system and a tweaking of existing guidance.
The final format of the changes to the NPPF will only be known following the current consultation and therefore the industry has an opportunity to influence the guidance. A further update will be provided once the Government has confirmed the content of the updated Framework.
For any queries on the consultation or guidance as to what the changes might mean for you, please do get in touch.