Written evidence submitted by the Regional Studies Association [NPP 36]
Introduction
Q1. Do you have any comments or suggestions about the proposal to amend the definition of affordable housing in national planning policy to include a wider range of low cost homes?
According to the estimate of Cambridge University, 75,000 out of the 240-245,000 (nearly one third) of required dwellings annually need to be at below market prices and rents. There is clearly a need to have a wider range of low cost homes and affordable housing. However, the consultation proposes to widen the definition of affordable housing by including starter homes as defined by the Housing Bill as ‘new dwellings for first time buyers under 40, sold at a discount of at least 20% of market value and at less than the price cap of £250,000 (or £450,000 in London). Support is available through the Help to buy ISA to help purchasers save for a deposit.’ This definition does raise concerns:
(1) Conflation effects: by including discounted starter homes as affordable housing can conflate the provision of social rented housing and other special needs dwellings and those that gain a subsidy to access to the housing market. This makes it more difficult to monitor the provision of housing to those most in need and without resource.
(2) Displacement effects: a change of definition may change the behaviour of developers to choose to provide starter homes rather than social housing (for the more prestigious image of the development projects), and local planning authorities may find it more difficult to negotiate social housing via S106. This may lead to a further reduction of housing provisions to those who are most in need and cannot access the housing market even with the starter home subsidy.
(3) Public money subsidised private housing assets accumulation: the offer of a subsidy to first time buyers to become home owners is to use public resources (planning permission and the Help to Buy subsidy) for private housing assets accumulation, so it is important to impose ‘in perpetuity’ restrictions or to recycle the subsidy – the Home Ownership scheme Housing in Hong Kong is an example. The absence of perpetuity restrictions can lead to the cumulative effect of reinforcing house price inflation in the buoyant housing market areas of London and the South East as well as losing affordable housing from the system.
Q2. Do you have any views on the implications of the proposed change to the definition of affordable housing on people with protected characteristics as defined in the Equalities Act 2010? What evidence do you have on this matter?
If the definition is widened to include starter homes, then an equality impact assessment has to be carried out to assess whether the lower income groups will be disadvantaged in this process if affordable housing provision shifts from social housing to subsidised market housing for ‘starters’ to become home owners and accumulate housing assets.
Q3. Do you agree with the Government’s definition of commuter hub? If not, what changes do you consider are required?
The definition of (a) a public transport interchange (rail, tube or tram) where people can board or alight to continue their journey by other public transport (including buses), walking or cycling is clear; but the definition of (b) a place that has, or could have in the future, a frequent service to that stop is less clear. Even though the consultant suggests the definition of a frequent service as running at least every 15 minutes during normal commuting hours, this is not reliable for the future and does not necessarily create a commuter hub – what matters is the permutation of accessibility to a range of routes and locations.
In fact it would be best to restrict any amendment here to urban, i.e. mainly built-up areas. In rural and former mining areas there still exist some 15-minute services with regular stops across unbuilt areas, for example at farm lane ends, country parks and isolated public houses. In County Durham there are profitable bus routes on the A167 (former A1) all the way from Darlington to Gateshead; the X21 Go-Ahead Northern service (Bishop Auckland-Durham-Gateshead) runs every 15 minutes across the full width of the Durham Green Belt, and across some more open country south of Durham City . The use of this criterion as a material factor in supporting new build housing would have highly fortuitous effects; there is major dissension over a recent Local Plan proposal to build on the first few fields of this Belt north of Durham.
As reported in other analyses, the use of rail stations in Green Belts and more open country, although among the solutions needing consideration for the grave housing crisis in the South East, may lack any proportionate beneficial impact on road traffic. For example, while the Borough of Reigate and Banstead includes a large number of rail stations in the Surrey Green Belt, the proportion of the working population travelling to work by train is only 17.1%, compared with 61.6% car drivers ( 2011 Census).
Q4. Do you have any further suggestions for proposals to support higher density development around commuter hubs through the planning system?
Based on the examples of high density development in Asian cities e.g. Hong Kong, commuter hubs tend to be integrated into mixed use development with retail, office and residential development in high density form, but also with a high quality public realm and green space, good infrastructure provision as well as educational and recreational facilities. It is all about having good design and planning to create quality places. In contrast, simply talking about high density in commuter hubs without other facilities and place-making requirements has resulted in some ‘ghost town’ development around some high speed rail stations in China.
Q5.Do you agree that the Government should not introduce a minimum level of residential densities in national policy for areas around commuter hubs? If not, why not?
Guidance on density and good design is helpful, but imposition of strict density requirements can be counter-productive and makes housing development less flexible and adaptable to different situations. Judging from international experience, high density development tends to be driven by land values and market demand; and the role of planning is to ensure that the proposed design and density will meet the principles of sustainable development and quality places.
Q6. Do you consider that national planning policy should provide greater policy support for new settlements in meeting development needs? If not, why not?
In areas with large development needs, e.g. London and South East, new settlements have to be an important part of the policy package to ensure housing supply. This will need comprehensive assessment of all planning factors including arrangements for establishing workplaces and commuting in liaison with adjoining planning authorities across housing market and travel-to-work areas. a blanket policy change in national policy may not work in areas with low demand and depressed housing markets in the Midlands and the North, e.g. Stoke on Trent, as many of these areas would benefit from urban regeneration rather than developing further new settlements.
Q7. Do you consider that it would be beneficial to strengthen policy on development of brownfield land for housing? If not, why not and are there any unintended impacts that we should take into account?
Manchester University’s previous work for Joseph Rowntree Foundation on brownfield land (https://www.jrf.org.uk/report/brownfield-residential-redevelopment-england) has already shown that most of the non-hard core land has been developed in London and the South and that the only way forward will be to increase density and to increase greenfield land. Given the challenges around this issue, there will be a need to think innovatively and sustainably in using both measures. Recommendations on developing garden cities, a New Homes Corporation and a better quality high density development have been made in the Lyons Review. On the whole, it is important to support brownfield land for housing to encourage efficient use of land resources and urban regeneration. However, in some cases where brownfield land has been exhausted or is markedly difficult of access, there is a need to consider the use of such land to serve other purposes, e.g. warehouse and small workshops.
Q8. Do you consider that it would be beneficial to strengthen policy on development of small sites for housing? If not, why not? How could the change impact on the calculation of local planning authorities’ five-year land supply?
Yes, in urban areas as it will encourage diversity of provisions by small house builders.
Q9. Do you agree with the Government proposal to define a small site as a site of less than 10 units? If not, what other definition do you consider is appropriate, and why?
Yes
Q10. Do you consider that national planning policy should set out that local planning authorities should put in place a specific positive local policy for assessing applications for development on small sites not allocated in the Local Plan?
A positive policy towards the development of small sites should be included in urban areas. However, more rigorous assessment will be required for smaller villages and rural areas as the cumulative impact brought by small sites can lead to stress on local infrastructure and amenities. Experience of these applications in small towns and rural areas indicates that they need the full scope of analysis by planning staff against established local plan policies, and full democratic consideration by planning committees, including site visits.
Q11. We would welcome your views on how best to implement the housing delivery test, and in particular
• What do you consider should be the baseline against which to monitor delivery of new housing?
With the introduction of the Housing and Planning Bill and the recovery from the economic downturn, 2015 could be a suitable year to use as a baseline to benchmark against future delivery.
• What should constitute significant under-delivery, and over what time period?
The delivery of 20% less than the target for 3 years should be considered as under delivery.
• What steps should be taken in response to significant under-delivery?
This has been proposed in the Lyons Housing Review (Lyons, 2014, p.47): “Where there is a persistent under delivery, the Secretary of State will have the power to intervene to ensure improved performance. Such measures could include an increase in the buffer provision of additional land to increase the number of sites with potential for delivery; designation of a planning authority under the regime currently used for performance on determining major planning applications (under which applicant could choose to submit their application directly to the Planning Inspectorate); or the creation of a New Homes Corporation to drive delivery.”
• How do you see this approach working when the housing policies in the Local Plan are not up-to-date?
The consultation document suggests that “One approach could be to identify additional sustainable sites if the existing approach is demonstrably not delivering the housing required.” The likelihood for this to happen should not be great if there is a Local Plan in place as the Plan should have gone through the participation and examination process already.
Q12. What would be the impact of a housing delivery test on development activity?
The delivery test will focus the attention of local planning authorities, though it may have some unpredictable side effects, e.g. reducing the ability of local planning authorities, particularly those in weaker housing markets, to negotiate affordable housing.
Q13. What evidence would you suggest could be used to justify retention of land for commercial or similar use? Should there be a fixed time limit on land retention for commercial use?
The economic cycle will affect the demand of different property sectors and major infrastructure development, e.g. HS2 will also impact on the demand for commercial and employment land. It would not therefore be wise to rigidly fix a time period on land retention. There is a need to improve the data on the land register on a consistent basis. Strategic land assessment for housing and commercial land should be carried out on a frequent basis to inform robust planning policies.
Q14. Do you consider that the starter homes exception site policy should be extended to unviable or underused retail, leisure and non-residential institutional brownfield land?
As explained above, it will depend on the (local) analysis of strategic land assessment. The availability of brownfield land and their quality for development is rather complicated as those sites with the best development potential have largely been developed. A blanket exception policy will not suit all locations with different spatial contexts of development.
Q15. Do you support the proposal to strengthen the starter homes exception site policy? If not, why not?
For some locations, there will be economic considerations as well, especially in economically buoyant areas, so the blanket exception site policy may distort the supply of land to meet other development needs.
Q16: Should starter homes form a significant element of any housing component within mixed use developments and converted unlet commercial units?
Depends on local circumstances (see above).
Q17. Should rural exception sites be used to deliver starter homes in rural areas? If so, should local planning authorities have the flexibility to require local connection tests?
In appropriate circumstances but there is a danger that traditional forms of affordable housing for those with insufficient means to access starter homes could be lost. Local connection tests are also needed to guard against limited land resources for starter homes being used up by incomers (especially commuters) gaining initial access to the housing ladder without meeting the needs of the local rural population.
Q18. Are there any other policy approaches to delivering starter homes in rural areas that you would support?
No further comments.
Q19. Should local communities have the opportunity to allocate sites for small scale Starter Home developments in their Green Belt through neighbourhood plans?
Maybe in exceptional circumstances, depending on local need and the merits of particular sites but the preservation of the Green Belt is a national policy and should not, in principle, be undermined by a multitude of neighbourhood decisions.
Q20. Should planning policy be amended to allow redevelopment of brownfield sites for starter homes through a more flexible approach to assessing the impact on openness?
There is discussion at this point in the consultation of land allocated for employment uses which has no reasonable prospect of coming into use. Such land should indeed not be subject to long term protection, which tends to occur as a result of the concerns of councillors, for example those sitting on the Policy Committees which approve local plans. There is need for a thorough review of the need to update planning methods for employment land after the recession, in terms of the expected balance of future development between use classes, densities of employment, and reliance of staff on public transport.
As in Q19 above, there may be merit in reviewing the approaches to the redevelopment of brownfield sites in the Green Belt more generally, including for affordable housing, but this needs to be considered at a national level rather than risking inconsistencies in the implementation of national Green Belt policy at the local or neighbourhood level as this would undermine the purpose of the Green Belt.
Q21. We would welcome your views on our proposed transitional arrangements.
No significant comments other than to note that experience suggests that local authorities tend to take longer to revise policies than initially anticipated and a period of 6-12 months might therefore be over-optimistic. Similarly, some delay to emerging local plans is likely as some local authorities will feel the need to take account of these changes before finalising their plans rather than adopting the plan first and altering the relevant policies subsequently.
Q22. What are your views on the assumptions and data sources set out in this document to estimate the impact of the proposed changes? Is there any other evidence which you think we need to consider?
Given the abolition of annual monitoring reports at the local level and the discontinuation of the compilation of many data sources, it will be difficult to estimate the impact of the proposed changes which are likely to have differential impacts in different spatial contexts (e.g. London / south east v midlands / northern England; urban v rural etc. etc.).
Q23. Have you any other views on the implications of our proposed changes to national planning policy on people with protected characteristics as defined in the Equalities Act 2010? What evidence do you have on this matter?
No further comments.
January 2016