Surprise, surprise! Kent’s environment suffers the failings of flawed government planning policy

The diggers and cement-mixers could be coming your way… but only if it suits the developers

Richard Thompson, CPRE Kent planner, shows how developers benefit from their own failure to build houses while our communities lose ever more green space

While the Housing Delivery Test might seem a dull and dry topic, often buried in the darkest, deepest recesses of a council’s website, its consequences should not be ignored. 
When CPRE Kent reported on the 2019 Housing Delivery Test results, it was a bleak picture. Well, last month the 2020 Housing Delivery Test results were published. And the situation for Kent has worsened yet further.
The test works by comparing how many homes have been built in each council district against how many homes the district is deemed to have needed over a three-year period (though reduced this year for a month to allow for the impact of the Covid-19 pandemic). 
These homes-needed figures will either come from a council’s Local Plan if it was adopted within the last five years or, more commonly for Kent, be based on the government’s ‘top-down’ standard method formula for calculating housing numbers.
If at least 95 per cent of the homes deemed needed have been built within a council’s district over that period, the council is regarded as having passed the test.
More than 85 per cent though less than 95 per cent, the council is put on the naughty step and has to write an ‘action plan’ in which it promises to try harder.
If less than 85 per cent though more than 75 per cent, the consequences become serious as an extra 20 per cent is added to the number of homes that will need to be built in that district. This makes it increasingly hard for councils to demonstrate they have a five-year supply of houses – and where a council cannot demonstrate a five-year supply it becomes subject to the “presumption in favour of sustainable development.
If fewer than 75 per cent of homes deemed needed have been built, that council area automatically becomes subject to the “presumption in favour of sustainable development. This means that if a site can be considered to deliver ‘sustainable development’, then planning permission should be granted, even if there is no support from the council for housing in that location or the site sits outside the Local Plan.
As set out in the table below, the combination of the 2020 Housing Delivery Test results and accepted lack of five-year supply by councils now means the majority of Kent is subject to the presumption.
Further, Canterbury, Dover and Folkestone and Hythe are all in precarious positions should developers seek to challenge the five-year supply position (note that both Canterbury and Tunbridge Wells only just avoided falling into the 20 per cent buffer requirement because of the Covid adjustment).

What does this mean in practice? Only that the majority of Kent is now at increased risk of speculative planning applications for developer-led interpretations of ‘sustainable development’.
CPRE Kent has long campaigned that the standard method for calculating the number of homes is a blunt instrument that fails to recognise local constraints and actual housing needs. Yet the revision made to the standard method in December 2020 is likely to further increase pressure on Kent to take some of London’s deemed increase in housing need.
It is also our view that the Housing Delivery Test and five-year supply requirements are fundamentally flawed.
The reality is that the supply of homes is all but controlled by the housebuilders, who clearly will only build what the local market will absorb. Yet if this building rate falls below these unreasonable targets, often the only response a local authority can have is to grant yet more planning permissions or allocate yet more land for increasingly unsustainable development.  
And so the cycle continues.  
Or, put another way, while the development industry is rewarded for failure to build houses with an increasing suite of sites where ever-greater profits may be made, communities suffer the real-world consequences of yet more precious green spaces being allocated for development.   

Friday, February 12, 2021

Overwhelmed by the development onslaught? This piece sheds a little light on what’s going on…

A countryside under siege (pic Susan Pittman)

Many of us are aware that our natural environment is threatened like never before. We experience it through the constant grind of cement-mixers and bulldozers, but sometimes the bureaucratic process is not so clear. Here planning expert and CPRE supporter Michael Hand casts some light on what is driving the current onslaught.

We are under relentless and unparalleled pressure to accommodate significant growth, in particular to meet the demand for new housing.
However, many developments are concentrating on three- and four-bedroom executive homes and not enough ‘affordable’ housing is being delivered.
Much of the South East is experiencing pressure for this unprecedented growth in housing, driven by the ‘housing crisis’ and associated government policy to increase the delivery of new homes by setting higher targets for local authorities to meet.
As guardians of the countryside, local members of CPRE Kent have a key responsibility in upholding the core values of the organisation and defending the beauty of the county against poor-quality and inappropriate new developments.
There are 13 Local Planning Authorities (LPAs) in Kent and in many Local Plans have not been adopted.
This void in the planning framework has resulted in opportunistic and speculative applications (by companies such as Gladman Developments Ltd) seeking to exploit councils’ inability to demonstrate a five-year supply of housing land.
The effect, already adverse, has been exacerbated by a recent change by the government to the National Planning Policy Framework (NPPF) through publication of a revised version on February 19.
Key changes include an amendment to specify that 2014-based population projections will provide the demographic baseline for the standard method of calculating local housing need rather than the lower 2016-based household projections, which could be used as a reason to justify lower housing need.
This clarification followed the publication of a major revision of the NPPF on July 24, 2018, which, inter alia, clarified the definition of ‘deliverable’.
To be considered deliverable, sites for housing should be available now, offer a suitable location for development now and be achievable with a realistic prospect that housing will be delivered on the site within five years.
As a consequence, it may be harder for LPAs to provide a five-year housing-land supply, as for example Local Plan allocations cannot generally be used in the calculation, except where “clear evidence that housing completions will begin on site within five years” exists.
The 2018 revision also introduced the Housing Delivery Test for LPAs, a failure in delivery of which kick-starts the “presumption in favour of sustainable development”.
The first round of Housing Delivery Test results was published in February this year, with 108 councils falling short and 86 required to add more land for housing to Local Plans as a result.
For a number of authorities, this confirms the need to apply a 20 per cent buffer to their housing requirement, with potential ramifications for their ability to demonstrate a five-year housing land supply.
A result of these changes is that speculative applications will still be common practice in the future – and that is why CPRE Kent needs to keep building a strong presence to monitor and respond to inappropriate development proposals.

Wednesday, May 15, 2019