Written evidence submitted by the Home Builders Federation [NPP 31]
The Home Builders Federation is the principal representative body of the housebuilding industry in England and Wales and our submission reflects the views arising out of discussions with our membership of national and multinational plc’s, through regional developers to small, local builders. Our members account for over 80% of all new housing built in England and Wales in any one year.
General comments
This is the first revision of the National Planning Policy Framework since its adoption in March 2012. We believe that it has been one of the strengths of the Framework that it has not been changed on an incremental basis over the last four years as certainty within the planning process is often just as important as the correct policy.
This consistency has, inevitably meant that the changes to the Framework might now appear to be numerous and far reaching when, in fact, they are the culmination of learning over the last four years of how planning policies can be fine-tuned and more closely reflect current practice.
The HBF is supportive of the development plan led planning system. This gives developers and communities alike greater certainty within the planning system. However, a plan led system requires local authorities to produce robust plans and to ensure that they are kept up to date. This requires an approach not of merely producing a one off plan and then putting it away on a shelf, but constant monitoring of the policies effectiveness and ensuring that the objectives of the plan (including housing delivery) are delivered.
Affordable Housing
Everyone deserves to be able to live in a home that they can afford. However, over the last 20 years the choice of tenure has moved from being merely between owner occupation and a social rented product, to many different types of tenure including shared ownership, shared equity, rent to buy, affordable rent and specialist student housing. Indeed, it is not only the occupants of dwellings who might change their tenure throughout their lives but the actual units themselves can move seamlessly between different tenures with no need for planning permission, for example, from shared equity to full owner occupation (through staircasing provisions) then to a private rented product.
Given that, in most areas, there is a need for all of these tenures it is right that, in planning for a mix of dwellings and tenures through the planning process, the widest possible range of products is reflected in negotiations over housing mix on a site by site basis.
Increasing residential density around commuter hubs
Much of the development planned for around commuter hubs is already planned for at higher than average densities and thus we would question the need for this to be a national policy.
We agree with the government that a nationally prescribed minimum density is not appropriate as this is better left to local considerations to reflect the character and pattern of development at such commuter hubs.
Supporting new settlements, development on brownfield land and small sites, and delivery of housing agreed in Local Plans
Supporting new settlements
We believe that the establishment of new settlements has an important part to play in meeting the development needs of the country in a sustainable way. However, we would caution local planning authorities who see the allocation of a new settlement in their areas as a way of putting off meeting their obligations to maintain a five year housing land supply. The trajectory of delivery of new settlements should be realistic and should demonstrate a long term commitment on behalf of the local authority to delivering such settlements as they have long lead in times and require a considerable up-front investment of resources to realise.
Supporting housing development on brownfield land and small sites
One of the key obstacles to the redevelopment of previously developed land is not the identification of such sites but their viability. We would suggest that there is more that central government could do to increase the economic viability of brownfield land. One of the most effective would be to grant tax breaks for the redevelopment of such sites.
We are, however, supportive of the new measures to require local authorities to include brownfield sites suitable for housing development in a register and for such sites to benefit from a “permission in principle”.
We also support the presumption in favour of brownfield land but would point out that this is not a “brownfield first” policy that assumes that all brownfield land is capable or viable for redevelopment for housing. One of the key issues for the brownfield land register is that the land contained therein should be deliverable and developable.
One of the key elements of maintaining a deliverable and developable five year housing land supply is to maintain a choice of sites, in a choice of locations and of different sizes to allow different sized housebuilding companies to participate in the market. Local authorities should, therefore, be under an obligation to ensure that their plans and decisions reflect this need for choice in order to enable delivery of the housing targets set out in their plans.
Ensuring housing is delivered on land allocated in plans
It is important to recognise that there is a difference between land that is allocated for development in a plan, land with a planning permission subject to further actions required such as discharge of conditions, land with an implementable planning permission and land which is currently under construction. If the country is to deliver over 200,000 dwellings a year the difference between these groups of “development land” must be recognised and reported clearly and transparently.
Many local authorities believe that their role in housing delivery stops once they have allocated a site for development or once they have granted a planning permission. However, we believe that local authorities should take more interest in the delivery of those sites and work more closely with developers to ensure that they allocate enough sites and grant enough permissions to ensure that the market can deliver the housing required to meet identified needs. This is primarily the reason why local authorities are under an obligation to ensure a constant deliverable five year supply of land for housing.
However, we recognise that for most local authorities the delivery of dwellings is not in their direct control and that they are dependent upon the housebuilding industry to build the houses they need.
It is, therefore, critical that local authorities work closely with the development industry to secure agreement over the intended delivery trajectories for sites allocated within plans and with planning permission. The more agreement there is between the authority and the industry the more likely the trajectories against which delivery will be tested will be met.
The current debate between local authorities, government and the development industry regarding build out rates fails to respect fluidity of sites moving through the development process. The allocation of sites and the granting of planning permissions is a reservoir from which development will flow. The number of completions per year is the rate of flow, not the size of the reservoir itself. Once a tap is fully open (in housebuilding terms this is the equivalent of a site delivering houses at the maximum rate the market can sustain), the only way to increase the flow is to open more taps through granting more planning permissions. This may, temporarily, increase the size of the reservoir but, ultimately, if we are to increase output of housing we must plan positively for more housing.
In simple mathematical terms, if we are to build houses at a rate in excess of 200,000 dwellings per year, the cumulative five year housing land supply (the reservoir) should be a minimum of 1m dwellings.
Supporting delivery of starter homes
Making the best use of land is a national policy to which the development industry subscribes. Resolving the competition between different land uses is, indeed, one of the key features of the modern planning system. It is, therefore, important that land is not underused or left in unproductive use when it could be used for housing. This is especially the case when it is brownfield land such as that used previously for employment. Combining this best use of land with a social policy such as starter homes will increase viability of some sites, allowing them to come back into productive use. There is, of course, no reason why all previously developed sites should not be allowed to be brought forward for the provision of starter homes nor why starter homes should not be provided as part of mixed use developments.
Providing starter homes in rural areas has the potential to meet specific housing needs in those areas and it will be up to local communities, through neighbourhood plans, to plan positively for sites for such homes.
Transitional arrangements
Transition from one policy regime to another is always critical either to avoid unintended delay or the creation of a void in policy terms.
However, local plans are already supposed to be flexible to allow for unexpected changes in policy or circumstances. We therefore see no need for a transition period to apply to the changes proposed by this consultation, rather we would expect decision makers to treat the changes in policy as a material consideration when determining applications and, should they believe that their adopted policies are out of date, to undertake the necessary review as soon as possible.
We look forward to seeing the committee’s report in due course.
