How planning by appeal cost Thanet one of its few remaining woodlands

A poor photograph but the damage to this piece of woodland is all too evident

This admittedly awful photograph shows what remains of one of Thanet’s last snippets of woodland.

With just 4.4 per cent tree canopy cover on the isle, Thanet is one of the least wooded districts in England – this was perhaps a contributory factor in the district council’s decision in August 2015 to refuse plans for 153 houses at Grade II-listed Westwood Lodge.

In explaining its decision, the council said: “The proposed development would result in a significant incursion of the built form into the Green Wedge, which would reduce the separation between settlements and result in a substantial loss of openness and established woodland habitat.”   

In these days of ‘planning by appeal’, however, Westwood Cross Developments did indeed appeal the council’s decision and in February 2017 the Planning Inspectorate duly approved the Broadstairs scheme, which entailed the felling of 150 Category C sycamore trees.

The inspector said the council’s position was weakened by its lack of a five-year housing supply.

Turning to the Green Wedge – the council’s long-standing policy that aims to keep open countryside between the three main towns of Margate, Ramsgate and Broadstairs – the inspector said:

“Further loss of trees within the site, and the introduction of additional dwellings, would be partially visible. However, as the woodland visible along the northern and eastern site boundaries would be largely retained, its distinctive landscape qualities would not be prejudiced.”

The original developer Places For People Homes had pulled out of the scheme, but it was taken up by Rooksmead Residential working with L&G Modular Homes, which has been building the properties at an off-site factory before they’re moved to Thanet.

Property management company Love Living Homes subsequently launched the shared-ownership development, which includes two-, three- and four-bedroom properties.

The plans had included the planting of 450 trees, along with wildlife corridors, but it’s difficult to see how the natural environment has won out on this one.

Wednesday, June 29, 2022

Laying the building myth to rest

And the build goes on… but it’s not of much use to local people wanting a home

In this concerning piece, Richard Thompson, CPRE Kent planner, spears the ridiculous notion that simply building more houses will make them more affordable. He highlights that this concept underpins the standard methodology for calculating housing, which, if left unchallenged, will lead to yet more sacrifice of greenfield land to unaffordable market housing without the needed delivery of truly affordable housing.

An article published in the county’s media as winter drew to its close highlighted the absurdity of government thinking that private-sector housebuilding alone would solve the housing affordability crisis.

The fact is, while ever-more houses are being built, the gap between house prices and earnings is still increasing, while much-needed affordable housing is simply not being built.

A stark example of this national policy failure at the local level can be found by looking in detail at the provision of affordable housing in the Canterbury district over the last 10 years.

Within Canterbury district, the average cost of a new-build dwelling has increased from £160,476 in September 2011 to £317,381 in September 2021. That’s almost a doubling of prices in 10 years.

Unsurprisingly, this market price is not affordable for most Canterbury residents. In fact, Canterbury City Council itself considers an income of more than £75,000 would be required to buy a house at this price without assistance.

It believes this equates to only 2 per cent of the population of Canterbury. Or, put another way, 98 per cent of Canterbury residents cannot afford a new-build home on the open market in the district on their incomes alone. Assistance therefore comes via affordable home-ownership ‘products’ such as Help to Buy and shared-ownership schemes. These all fall within the formal planning definition of affordable housing as set out in the National Planning Policy Framework (NPPF). However, many of these affordable home-ownership products are still not actually affordable to most Canterbury residents.

The table below assesses each of the different affordable home-ownership products against the income required to afford them and then considers what percentage of the district would not be able to afford these products.

Affordable Home Ownership Options SchemeIncome RequiredHouseholds Unable to Afford (all households)Households Unable to Afford (private renters)
Help to Buy: Equity Loan (20%)£67,01895%98%
Help to Buy: Shared Ownership (50%)£60,41993%97%
First Homes (30% discount)£52,56790%94%
Help to Buy: Shared Ownership (25%)£50,79090%93%
Rent to Buy (80% of median rent)£23,32332%46%

Yes, you have read correctly – it is the council’s own assessment that 98 per cent of Canterbury residents who currently rent are considered unable to afford the government’s flagship Help to Buy: Equity Loan scheme. Across all the schemes, at best, only 54 per cent of current renters would be able to afford the ‘cheapest’ rent-to-buy route to home ownership.

For those left, the only option is to rent. However, paying open-market rents is deemed unaffordable for 45 per cent of households in Canterbury.  

For this group, there are two types of rental products that fall within the formal planning definition of ‘affordable housing’. The first is affordable rent, which in Canterbury is some 86-97 per cent of the cheapest market rents, ie not necessarily that affordable and subject to usual market price rises. The second is the social rent, which is set according to a complex formula but is typically between 50 per cent and 60 per cent of market rent. This is the cheapest route to accommodation and in Canterbury is about £435 a month.

It is unsurprising then that the council considers the most pressing affordable housing need for Canterbury is for the genuinely affordable social rent homes. It considers 231 social rent homes are now required a year. There is then a lesser need for affordable home-ownership products (156 required a year) and then affordable rent homes (77 required a year). In total that’s 464 affordable homes required a year in Canterbury.

However, Canterbury City Council, like most Kent councils, does not generally build houses. Rather, the current model is that a developer is expected to use a small proportion of the financial gain it gets from a grant of planning permission to provide a certain number of affordable houses alongside the market houses it sells. In Canterbury, the target is that 30 per cent of all homes built should meet the NPPF planning definition of affordable (though until 2017 was set at 35 per cent for the Canterbury Urban Area).    

So how many affordable homes have been provided in Canterbury under this model over the last 10 years? The next table sets out how many of each type of affordable house has been built over this period and quite clearly shows it to be nowhere near enough.

YearAffordable rentAffordable home ownershipSocial rentTotal
2011/12183393144
2012/13105358121
2013/1410105070
2014/15400040
2015/162030050
2016/173810048
2017/18936045
2018/191937056
2019/20405544139
2020/213522057
Total239286245770

That’s barely a current year’s requirement of social rent homes built in total over the last 10 years. Amazingly, in six out of 10 years not a single social rent home was built. With an overall total of 6,097 new homes having been built within the Canterbury district across this period, that equates to 12.6 per cent affordable homes built across all types against the target of 30-35 per cent.     

So why are the required affordable houses not being built by the development industry? For many, the main reason is that current government policies allow levels of affordable housing to be reduced if a development is not deemed ‘viable’.

In the simplest terms, a development is not deemed viable if it can be demonstrated a developer would make a profit of less than 15-20 per cent once all set costs are accounted for. Significantly, one such set cost is an agreed premium to buy the land by the developer that is usually 20 times the existing value of the land though can be as much as 40 times! Added to this, the greater the perceived need for housing, the lower the ability of the council to negotiate, particularly if the council is subject to the ‘tilted balance’ presumption in favour of granting planning permission.

While the intricacies of viability appraisals are a topic of concern in themselves, the fact is housebuilder profits are soaring all the while the current system is not delivering affordable homes on the ground.

In 2021, when not a single social rent home was built in Canterbury, the four biggest UK housebuilders – Persimmon, Berkeley, Taylor Wimpey and Barratt Homes – reported pre-tax profits of £784 million, £504 million, £492 million and £264 million respectively.

If we delve into this a little deeper, we can see it is developer profit margins alone that have soared over the last 10 years, with the costs of buying development land and cost associated with physically building houses broadly staying the same. This can clearly be seen in the below chart taken from housebuilder Persimmon’s 2021 financial results presentation dated March 2, 2022. The chart gives a total cost breakdown of an average Persimmon new-build home showing that the gross profit element has gone from accounting for £20,763 of the cost of a new-build house in 2010 to £74,481 per house in 2021. That’s more than a tripling of profit margins.            

Despite this, the development industry maintains the problem is simply that not enough homes are being given planning permission. The argument goes that if they were given more permissions to build more houses, then of course more affordable houses would be delivered and market housing would become more affordable.

While the above record in Canterbury suggests otherwise, this argument is flawed for other reasons.

For starters, it can be argued that there is already sufficient planning permission or land available to build on. In Canterbury, there is either an existing planning permission or an identified Local Plan land allocation for 12,334 new homes. Specifically with respect to affordable housing, as of March 2021, there were 1,757 social/affordable rental units with permission in the pipeline. This is more than double the number of affordable homes built in Canterbury over the last 10 years. Despite this, Canterbury has just failed the government’s Housing Delivery Test for not building enough houses, meaning the district is now subject to the presumption that planning permission will be given even if in conflict with the adopted Local Plan. As has been pointed out by CPRE Kent, this is absurd.

There is also the small matter that housebuilders are quite simply not going to build at a level that over-supplies a local housing market, forcing them to reduce prices and lower profits.

The absorption concept was most recently highlighted by Sir Oliver Letwin in his government-commissioned independent review of buildouts. Here he found the “fundamental driver of buildout rates once detailed planning permission is granted for large sites appears to be the ‘absorption rate’ – the rate at which newly-constructed homes can be sold into (or are believed by the housebuilder to be able to be sold successfully into) the local market without materially disturbing the market price”. Alongside this, there are practical constraints such as the current labour and materials shortages.

However, and perhaps most significantly, it is housing market demandrather than need that drives affordability. Currently this demand is being fed as much by monetary policy and financial markets as by physical shortages. Low interest rates and readily available mortgage credit, coupled with state assistance policies such as Help to Buy equity loans, are arguably allowing those already in the position to buy a house to offer ever more. They are often bidding against others in a similar position, pushing the market prices up in the process. Meanwhile, those not already in a position to buy get left even further behind.

So why does this matter?

At the superficial level, CPRE Kent and other similar organisations are often accused of denying local communities much-needed housing when we object to yet more greenfield land being lost to market housing. Taking the Canterbury example, however, the council itself is accepting the new-build market housing dominating the supply is simply not affordable to most existing residents in the district. For those existing residents, they are losing greenfield land important to them to satisfy a wider market demand rather than for their direct benefit.

At the far more important level, though, this matters because the government’s current standard method for calculating how many houses a district needs is linked directly to housing affordability within that district. That is, the bigger the gap between new-build house prices and median earnings in a district, the higher the housing number for that district is. And the government rationale for this is that by building more houses, the cost of housing will come down…

This problem is increasingly urgent. The government affordability data are released on an annual basis, with the 2022 data due on March 23, just before we went to print. On release of these data, housing targets for each council can change overnight. With it reasonable to assume that the gap between house prices and earnings is likely to have widened over the last year for much of Kent, the consequences for the county could be dire.   

The need to revisit the standard methodology for calculating housing is urgent. The need to rethink how we deliver truly affordable housing in a way that doesn’t sacrifice greenfield land to bolster developer profits is arguably even more urgent.  

‘Affordable housing’ schemes

The formal planning definition of affordable housing is set out in Annex 2 of National Planning Policy Framework (NPPF) and, at almost 500 words long, is rather complicated and hard to understand.

The below non-exhaustive list, however, sets out the most popular schemes that currently fall within this formal planning definition of affordable housing:

Type or tenureDescription
Social rent  These properties are provided by local authorities and some registered providers. The rent for these properties will be set at a level dictated by the national rent regime. Social rented properties are the most affordable and what people usually understand as being meant by ‘council housing’.  
Affordable rent  These properties are provided by local authorities and registered providers and are subject to a control that in theory requires the level to be no more than 80% of local market rent. In practice and, as demonstrated in Canterbury, this is not always the case.  
Shared ownership  Previously known as ‘part buy, part rent’, households buy a share of the property and the remaining share is rented. In time, future shares can be purchased and the property could be bought outright/subsequently sold at market rates (though some restrictions might apply in very limited circumstances).  
Shared equity  The applicant purchases a share in the property and no rent is paid on the remaining share, but the purchaser is able to buy further shares in the property until it is owned outright. The house can subsequently be sold at market rates.  
Help to Buy equity loan  The government provides households with an interest-free loan of 10% or 20% of the cost of a new home for a period of five years; purchasers require a mortgage and at least a 5% deposit. The house can subsequently be sold at market rates  
First HomesFirst Homes is a new scheme designed to help local first-time buyers and key workers on to the property ladder by offering homes at a discount of 30% compared with the market price. It is intended that the discounts will apply to the homes forever.  
Build to Rent and Rent to Buy  These properties are usually built as blocks of flats. The property is rented for a set period during which time the tenant saves enough for a deposit to purchase the property at the end of the rental term.  

References

[1] www.kentonline.co.uk/kent/news/32-per-inch-who-are-pricey-kent-new-builds-for-261858/

[2] UK House Price Index – HM Land Registry Open Data

[3] Canterbury City Council Housing Needs Assessment 2021 –https://drive.google.com/drive/u/0/folders/1BCdWC6ME7X_b6szgA1E5knDlsta1ooTY

[4] again taken from the September 2021 Canterbury Housing Needs Assessment

[5] See – https://lichfields.uk/media/6509/fine-margins_viability-assessments-in-planning-and-plan-making.pdf

[6] Canterbury Authority Monitoring Report 2020-2021

[7] Sir Oliver Letwin’s final report – www.gov.uk/government/publications/independent-review-of-build-out-final-report

Thursday, May 5, 2022

Petition: change the housing methodology that’s costing us greenfield land

The government is using out-of-date growth projections as it pushes through its assessment of housing need

There can’t be many of us who are unaware of the government’s ‘standard methodology’ that is artificially inflating the numbers of houses to be built on greenfield sites.
Many local authorities are being forced to remove protection from large areas of countryside when in truth there is no need.
In response, a petition has been set up calling for the methodology to be changed. Entitled ‘Change the Standard Method for calculating local housing need’, campaigners state:
“We call on the Government to change the standard method for calculating local housing need. The current method uses growth projections from 2014, which we believe is out of date and more recent data should be used to calculate the baseline amount of housing needed.”

  • If you would like to sign the petition, click here   

Wednesday, May 4, 2022

Laying the myths to rest: Canterbury crisis shows how desperate government policy and housebuilder attitudes are making homes unaffordable… and destroying our countryside

Canterbury: house prices have spiralled out of control… and it’s time to acknowledge just why (pic John Fielding)

In this concerning piece, Richard Thompson, CPRE Kent planner, spears the ridiculous notion that simply building more houses will make them more affordable. He highlights the critical need to revisit the standard methodology for calculating housing if we are to rethink how we deliver truly affordable housing in a way that doesn’t sacrifice greenfield land.

An article on Kent Online this month highlighted the absurdity of government thinking that private-sector housebuilding alone will solve the housing affordability crisis.

The fact is, while ever-more houses are being built, the gap between house prices and earnings is still increasing, while much-needed affordable housing is simply not being built.  

A stark example of this national policy failure at the local level can be found by looking in detail at the provision of affordable housing in the Canterbury district over the last 10 years.   

Within Canterbury district, the average cost of a new-build dwelling has increased from £160,476 in September 2011 to £317,381 in September 2021 [1].

That’s almost a doubling of prices in 10 years.

Unsurprisingly, this market price is not affordable for most Canterbury residents. In fact, Canterbury City Council itself considers an income of more than £75,000 would be required to buy a house at this price without assistance [2].

It believes this equates to only 2 per cent of the population of Canterbury. Or, put another way, 98 per cent of Canterbury residents cannot afford a new-build home on the open market in the district on their incomes alone.

Assistance therefore comes via affordable home-ownership ‘products’ such as Help to Buy and shared-ownership schemes. These all fall within the formal planning definition of affordable housing as set out in national planning policy in the National Planning Policy Framework (NPPF). However, many of these affordable home-ownership products are still not actually affordable to most Canterbury residents.

The table below assesses each of the different affordable home-ownership products against the income required to afford them and then considers what percentage of the district would not be able to afford these products [3].

Affordable Home Ownership Options SchemeIncome RequiredHouseholds Unable to Afford (all households)Households Unable to Afford (private renters)
Help to Buy: Equity Loan (20%)£67,01895%98%
Help to Buy: Shared Ownership (50%)£60,41993%97%
First Homes (30% discount)£52,56790%94%
Help to Buy: Shared Ownership (25%)£50,79090%93%
Rent to Buy (80% of median rent)£23,32332%46%

Yes, you have read correctly – it is the council’s own assessment that 98 per cent of Canterbury residents who currently rent are considered unable to afford the government’s flagship Help to Buy: Equity Loan scheme. Across all the schemes, at best, only 54 per cent of current renters would be able to afford the ‘cheapest’ rent-to-buy route to home ownership.

For those left, the only option is to rent. However, paying open-market rents is deemed unaffordable for 45 per cent of households in Canterbury.  

For this group, there are two types of rental products that fall within the formal planning definition of ‘affordable housing’. The first is affordable rent, which in Canterbury is some 86-97 per cent of the cheapest market rents, ie not necessarily that affordable and subject to usual market price rises. The second is the social rent, which is set according to a complex formula but is typically between 50 per cent and 60 per cent of market rent. This is the cheapest route to accommodation and in Canterbury is about £435 a month.

It is unsurprising then that the council considers the most pressing affordable housing need for Canterbury is for the genuinely affordable social rent homes. It considers 231 social rent homes are now required a year. There is then a lesser need for affordable home-ownership products (156 required a year) and then affordable rent homes (77 required a year). In total that’s 464 affordable homes required a year in Canterbury.

However, Canterbury City Council, like most Kent councils, does not generally build houses. Rather, the current model is that a developer is expected to use a small proportion of the financial gain it gets from a grant of planning permission to provide a certain number of affordable houses alongside the market houses it sells. In Canterbury, the target is that 30 per cent of all homes built should meet the NPPF planning definition of affordable (though until 2017 was set at 35 per cent for the Canterbury Urban Area).    

So how many affordable homes have been provided in Canterbury under this model over the last 10 years? The next table sets out how many of each type of affordable house has been built over this period and quite clearly shows it to be nowhere near enough.

YearAffordable rentAffordable home ownershipSocial rentTotal
2011/12183393144
2012/13105358121
2013/1410105070
2014/15400040
2015/162030050
2016/173810048
2017/18936045
2018/191937056
2019/20405544139
2020/213522057
Total239286245770

That’s barely a current year’s requirement of social rent homes built in total over the last 10 years. Amazingly, in six out of 10 years not a single social rent home was built. With an overall total of 6,097 new homes having been built within the Canterbury district across this period, that equates to 12.6 per cent affordable homes built across all types against the target of 30-35 per cent.     

So why are the required affordable houses not being built by the development industry? For many, the main reason is that current government policies allow levels of affordable housing to be reduced if a development is not deemed ‘viable’.

In the simplest terms, a development is not deemed viable if it can be demonstrated a developer would make a profit of less than 15-20 per cent once all set costs are accounted for. Significantly, one such set cost is an agreed premium to buy the land by the developer that is usually 20 times the existing value of the land though can be as much as 40 times! [4]  Added to this, the greater the perceived need for housing, the lower the ability of the council to negotiate, particularly if the council is subject to the ‘tilted balance’ presumption in favour of granting planning permission.

While the intricacies of viability appraisals are a topic of concern in themselves, the fact is housebuilder profits are soaring all the while the current system is not delivering affordable homes on the ground.

In 2021, when not a single social rent home was built in Canterbury, the four biggest UK housebuilders – Persimmon, Berkeley, Taylor Wimpey and Barratt Homes – reported pre-tax profits of £784 million, £504 million, £492 million and £264 million respectively.

Despite this, the development industry maintains the problem is simply that not enough homes are being given planning permission. The argument goes that if they were given more permissions to build more houses, then of course more affordable houses would be delivered and market housing would become more affordable.

While the above record in Canterbury suggests otherwise, this argument is flawed for other reasons.

For starters, it can be argued that there is already sufficient planning permission or land available to build on. In Canterbury, there is either an existing planning permission or an identified Local Plan land allocation for 12,334 new homes [5]. Specifically with respect to affordable housing, as of March 2021, there were 1,757 social/affordable rental units with permission in the pipeline. This is more than double the number of affordable homes built in Canterbury over the last 10 years. Despite this, Canterbury has just failed the government’s Housing Delivery Test for not building enough houses, meaning the district is now subject to the presumption that planning permission will be given even if in conflict with the adopted Local Plan. As pointed out by CPRE Kent just last month, this is absurd.

There is also the small matter that housebuilders are quite simply not going to build at a level that over-supplies a local housing market, forcing them to reduce prices and lower profits.

The absorption concept was most recently highlighted by Sir Oliver Letwin in his government-commissioned independent review of buildouts. Here he found the “fundamental driver of buildout rates once detailed planning permission is granted for large sites appears to be the ‘absorption rate’ – the rate at which newly-constructed homes can be sold into (or are believed by the housebuilder to be able to be sold successfully into) the local market without materially disturbing the market price” [6]. Alongside this, there are practical constraints such as the current labour and materials shortages.

However, and perhaps most significantly, it is housing market demand rather than need that drives affordability. Currently this demand is being fed as much by monetary policy and financial markets as by physical shortages. Low interest rates and readily available mortgage credit, coupled with state assistance policies such as Help to Buy Equity Loans, are arguably allowing those already in the position to buy a house to offer ever more. They are often bidding against others in a similar position, pushing the market prices up in the process. Meanwhile, those not already in a position to buy get left even further behind.

So why does this matter?

At the superficial level, CPRE Kent and other similar organisations are often accused of denying local communities much-needed housing when we object to yet more greenfield land being lost to market housing. Taking the Canterbury example, however, the council itself is accepting the new-build market housing dominating the supply is simply not affordable to most existing residents in the district. For those existing residents, they are losing greenfield land important to them to satisfy a wider market demand rather than for their direct benefit.

At the far more important level, though, this matters because the government’s current standard method for calculating how many houses a district needs is directly linked to housing affordability within that district. That is, the bigger the gap between new-build house prices and median earnings in a district, the higher the housing number for that district is. And the government rationale for this is that by building more houses, the cost of housing will come down…

This problem is increasingly urgent. The government affordability data are released on an annual basis, usually in March. On release of this data, housing targets for each council can change overnight. With it reasonable to assume that the gap between houses prices and earnings is likely to have widened over the last year for much of Kent, the consequences for the county could be dire.   

The need to revisit the standard methodology for calculating housing is therefore urgent. The need to rethink how we deliver truly affordable housing in a way that doesn’t sacrifice greenfield land to bolster developer profits is arguably even more urgent.  

References

[1] UK House Price Index – HM Land Registry Open Data

[2] Canterbury City Council Housing Needs Assessment 2021 –https://drive.google.com/drive/u/0/folders/1BCdWC6ME7X_b6szgA1E5knDlsta1ooTY

[3] again taken from the September 2021 Canterbury Housing Needs Assessment

[4] See – https://lichfields.uk/media/6509/fine-margins_viability-assessments-in-planning-and-plan-making.pdf

[5] Canterbury Authority Monitoring Report 2020-2021

[6] Sir Oliver Letwin’s final report – https://www.gov.uk/government/publications/independent-review-of-build-out-final-report

Tuesday, February 15, 2022

Enough is enough! Scrap the Housing Delivery Test and stop rewarding developers’ failure to build homes already approved

There are already enough houses with planning permission or allocated within an adopted Local Plan for “another Maidstone” to be built in Kent in the next five years

Richard Thompson, CPRE Kent planner, lays out how disastrous governmental planning policy is desperate news for Kent

The publication of the 2021 Housing Delivery Test results, combined with existing lack of five-year housing supplies, now puts Kent in the frankly ridiculous position where 11 out of its 13 councils are being punished for developers’ failure to build homes already approved.
The Housing Delivery Test is a backwards-looking assessment that compares how many houses having been built in a council’s area over the last three years against the government-set housing number for that area. The result is given as a percentage of homes built against this target, with increasingly severe punishments the lower this percentage is.
The National Planning Policy Framework five-year supply test is a forward-looking assessment of whether enough houses have been granted planning permission, or are allocated within a Local Plan, to ensure this same government-set housing requirement is likely to be built.
The point is, both tests see the imposition of a housing target on a council and then punishes it for not meeting this target. However, the reasons the targets are missed are largely factors completely outside of their control. That is, it can grant as many planning permissions and allocate as much land as it can, but unless it starts physically building the houses itself, it is at the mercy of market forces.
Private housebuilders will, however, only ever build at a rate that the local housing market can absorb. They are not going to build at a level that over-supplies a local housing market as this would force them to reduce prices and lower profits. They are also currently subject to practical constraints such as labour and material shortages.
As of March 31, 2020, (from when the most up-to-date Kent-wide numbers available) some 64,611 new houses either had planning permission or were allocated within an adopted Local Plan and were expected to be built within the next five years. For context, that’s already enough houses for another Maidstone planned for Kent over the next five years.
Yet this is not deemed enough.  
Because of either the Housing Delivery Test or the five-year supply test, nine of Kent’s councils are subject to the most severe of punishments: an automatic presumption that speculative planning applications will be granted, even if they are contrary to democratically adopted Local Plans. 
Of the remaining four councils, two must produce action plans setting out how they are to increase housebuilding in their areas. The full 2021 Housing Delivery Test results, along with the last published five-year supply figures, are shown below:

Area NameHousing Delivery Test: 2021 measurementCurrent five-year supply (years)Consequence
Ashford118%4.54Presumption
Canterbury65%5.13Presumption
Dartford105%5.63None
Dover88%5.56Action plan
Folkestone and Hythe85%5Action plan
Gravesham57%3.27Presumption
Maidstone170%5.6None
Medway67%1.78 – 3.03Presumption
Sevenoaks62%2.89Presumption
Swale78%4.6Presumption
Thanet78%4.23Presumption
Tonbridge and Malling63%2.89Presumption
Tunbridge Wells97%4.83Presumption

The real-world consequences for Kent of this absurd policy are stark. Councils across Kent are rushing through ever-increasingly unsustainable Local Plans in a fruitless endeavour to beat the presumption punishment. In Kent, this often entails allocating ever-increasing housing numbers on greenfield land, which is more profitable and hence more likely to developed quicker, making them more attractive to councils needing to boost housing delivery in the short term to meet the five-year supply test.
In the meantime, speculative applications are being allowed either by councils or at appeal (because of the current presumption punishment), causing anger and disenfranchisement among local communities.
And it is not just us saying this. In calling for the Housing Delivery Test to be suspended, Canterbury City Council chief executive Colin Carmichael has stated “it cannot be right to punish councils that are working hard to do what the government asks even when most of the levers councils need to pull are out of their control”.
We agree. Only it’s not just the councils that are being punished, it’s the people of Kent who have lost a democratic voice to oppose speculative development. It is Kent’s special countryside that is being sacrificed to this developer’s charter. 
And the government wonders why the people of Kent are so angry with the current planning system.

Wednesday, January 26, 2022

Another 1,500 houses added to the Thanet mix

How Humber’s Mill might look (pic Axis Land Partnerships)

Just when you thought Thanet couldn’t be any more over-developed, along come plans for another 1,500 properties on greenfield land.

The Humber’s Mill scheme will cover 166 acres west of Nash Lane, Margate, and has been put forward by Axis Land Partnerships, a “land promotion and development company” that apparently “offers a mutually beneficial partnership approach to promoting land for development”.

Together with the housing development, the proposals also include a primary school, cafes, shops and “significant green infrastructure including a country park”.

The site is allocated for development within the Thanet Local Plan.

Monday, January 24, 2022

Maidstone Local Plan consultation: last chance to make your thoughts known

Maidstone Borough Council aims to build more than 80 per cent of its housing allocation on greenfield sites

Residents have until midnight Sunday (December 12) to comment on Maidstone’s plan for 17,746 houses in the borough, 82 per cent of which are to be on greenfield sites.
CPRE Kent is dismayed Maidstone Borough Council is persisting with a spatial strategy prioritising allocation of greenfield sites ahead of brownfield sites.
This includes 5,000 houses in Lenham Heath and 2,000 houses at Lidsing on greenfield sites under the guise of ‘garden settlements’.
The council openly accepts the strategy is based on a clear political desire for garden settlements, which seems to be being put above all other considerations.
This is despite its own consultants telling it that this is the least sustainable option and will have a significant negative effect with respect to climate change.
We think this is wrong and have made this known in our response.
The consultation ends on Sunday, December 12, at 23.59 and we would strongly urge residents to make their opinions known if they have not already done so.

•          CPRE Kent’s detailed comments on the Local Plan can be found here

•          The council’s consultation document can be found here

Friday, December 10, 2021

Canterbury: the council cornering itself into a position where 20th-century solutions are being applied to 21st-century issues

Much of the still-beautiful environment of Canterbury and its countryside will be lost if the city council follows its ‘preferred option’

The deadline for comments on Canterbury City Council’s public consultation on its preferred option for its new Local Plan closes at 9am on Monday, August 9. The deadline has been extended by a week in response to glitches with the council’s online consultation portal.
CPRE Kent has submitted comments on behalf of its members objecting to the council’s preferred option of building 14,000-17,000 homes – which is 8,000 more than required under the government’s standard methodology for calculating housing numbers, for the period to 2040.
We have advised the council that a careful balance needs to be struck between taking economic advantage of Canterbury’s heritage and undermining it with too much and with inappropriately sited development.
Unfortunately, like many of the residents in the Canterbury area, we have had difficulty interpreting the full implications of the council’s development proposals.
The written summary details for the preferred option makes no reference to the provision of the proposed two new roads/bypasses – to the north-west and south-east of the city – referring obliquely to “upgrade of the A28 to allow traffic to bypass the city centre” instead.
CPRE Kent has questioned whether addressing congestion and pollution on the ring road by building a pair of bypasses will be effective – bearing in mind that it would appear that a high proportion of this traffic is generated by local people travelling into Canterbury for work, leisure, shopping and education.
Building up to 8,000 more dwellings than required to fund a roadbuilding programme to bypass the city centre will, CPRE Kent believes, place undue burden on local communities, the countryside setting of Canterbury, the Area of Outstanding Natural Beauty and surrounding Areas of High Landscape Value.
We have pointed out to the council that development to this degree would have an adverse impact on dark skies, tranquillity and best and most versatile agricultural land – which has a vital role to play in absorbing carbon and preserving biodiversity, including the biodiversity in soils. Once it is built over, soil biodiversity is lost. 
Sadly, the council seems to have cornered itself into a position whereby 20th-century solutions are being applied to 21st-century issues.

  • To learn more and contribute to Canterbury City Council’s consultation on the Local Plan, click here
  • To read more about development pressure and planning in Canterbury, click here

Tuesday, August 3, 2021

Gravesham Green Belt: fight for it or lose it!

Downs Road, Istead Rise, where 165 homes could be built

Local people are being urged to fight for the Green Belt in Gravesham.
Below is a list of the sites under threat and Alex Hills, Gravesham chairman of CPRE Kent, is making clear what is at stake.
“Many of these sites are on prime farmland, which is much needed for food supply,” he said.
“The proposals will result in villages merging, while no account has been taken of the impact of the new Thames crossing or the planned theme park.
“Many of the locations have poor public-transport links and the infrastructure is not there to support the developments.
“The sites in Meopham and Istead Rise will increase traffic on the A227, which is already facing at least a 10 per cent increase in traffic from the new Thames crossing.
“Further, these developments would destroy important wildlife habitat.
“Please, if you want to protect the Gravesham countryside, write to your MP and your ward councillor.”
Proposals in the Gravesham Local Plan Regulation 18 (Stage 2) Consultation could see 425 new homes in Higham, 275 in Istead Rise and 1,705 in Meopham, plus commercial development.

Sites under threat:

  • Land west of Wrotham Road (Site B), next to Helen Alison school, Hook Green, Meopham. Meopham North: 120 dwellings
  • Land at Longfield Avenue, New Barn, Istead Rise: 25 dwellings
  • Willerby Farm, 2 Downs Road, Istead Rise: 10 dwellings
  • Land west of Walmers Avenue, Higham Shorne, Cobham and Luddesdown: 40 dwellings
  • Land north of Steeles Lane, Meopham DA13 0QQ (behind houses south side of the green). Meopham South: 95 dwellings
  • Land north of The Drove Way, Istead Rise (behind the island): 75 dwellings
  • Land west of Norwood Lane, Meopham (Churchways, Meopham). Meopham North: 150 dwellings
  • Former Tollgate Hotel, Gravesend: commercial
  • Land adjacent to Higham station: commercial
  • Canal Road, Higham: 10 dwellings
  • School Close, Hook Green, Meopham. Meopham North: 15 dwellings
  • Land to the south of Green Lane and east of Wrotham Road, Hook Green, Meopham (opposite Camer Parade). Meopham North: 350 dwellings
  • Land at and adjoining Buckland Farm, Chalk Road, Higham: 40 dwellings
  • Land north of Camer Road, Hook Green, Meopham (Norwood Lane to Sole Street). Meopham North: 520 dwellings
  • Land north of Melliker Lane, Hook Green, Meopham. Meopham North: 160 dwellings
  • Land between Melliker Lane and Longfield Road, Hook Green. Meopham North: 180 dwellings
  • Land to the north, east and west of Three Crutches. Higham/Shorne, Cobham and Luddesdown: commercial
  • Rose Farm, Downs Road, Istead Rise: 165 dwellings
  • Land to the east and south of Lomer Farm, Wrotham Road, Meopham (behind Cricketers Drive): Meopham North 115 dwellings
  • Land between Lower Rochester Road, Hermitage Road and School Lane, Higham: 85 dwellings
  • Land between Taylors Lane and School Lane, to the north of High View, Higham: 250 dwellings 
  • You can learn more from Gravesham Borough Council’s Local Plan Core Strategy Partial Review and Site Allocations Document and Development Management Policies Document here  

Friday, November 6, 2020

How the Chancellor’s ‘mini-Budget’ missed the mark on transport and housing

‘We are urging the government to scrap the planned road spending and put this money to much better use’

CPRE, the countryside charity, has said that Chancellor Rishi Sunak’s ‘mini-Budget’ missed the mark on transport and housing.
The Chancellor had been aiming to revive the economy through his A Plan for Jobs mini-Budget, announced earlier this month, but Tom Fyans, CPRE campaigns and policy director, said: “While we have seen promising starts on energy efficiency and shoring up rural hospitality businesses, the Chancellor has missed major opportunities to begin building back better when it comes to transport and housing investment.”
Mr Fyans addressed several issues in the mini-Budget:
On existing homes: “The £3 billion announced on energy efficiency is a good start but must be swiftly followed by a National Retrofit Strategy that CPRE has been calling for in our new report Greener, Better, Faster and a plan for longer-term investment. Decarbonising our homes and buildings is essential to preventing runaway climate change. We expect to see further investment in reducing emissions from our existing homes via the £9bn for energy-efficiency schemes promised by Boris Johnson in the Conservative Party’s general election manifesto at the end of last year.”
On new homes: “We understand the Chancellor wants to reboot the construction sector, but he’s pulling the wrong lever with a Stamp Duty holiday. By investing in social and genuinely affordable housing instead, he could drive up build rates and provide the homes that are so desperately needed, especially in rural areas. We cannot accept that private rentals in nine out of 10 rural areas are unaffordable for care workers. We urge the government to begin investing in homes for our heroes and tackling the housing crisis.”
On transport: “Any serious claims to a green recovery are being completely undermined by the out-of-touch £27bn road-building plans that will drive up emissions and will likely not be needed with homeworking on the rise. In the mini-Budget we did not hear one mention of public transport, the low-carbon alternative to the private car that is so desperately needed, especially in disconnected rural areas. We are urging the government to scrap the planned road spending and put this money to much better use. Diverting some of this funding to a dedicated rural transport fund would have a dramatic impact connecting up towns and villages with affordable, convenient and low-carbon public transport.”
On rural economies: “The Chancellor was absolutely right to highlight hard-hit rural businesses in the hospitality industry and we welcome the ‘eat out to help out’ vouchers. We can all play our part in supporting local businesses as we emerge from lockdown. Our hope is that these vouchers will help get small rural restaurants, pubs and cafes back on their feet as lockdown eases and holiday season begins, with many of us choosing to go on a staycation here in the UK rather than venturing abroad.”

Friday, July 31, 2020

Thanet finally sees a Local Plan on the horizon… and an awful lot more housing

Manston airport is to be safeguarded for aviation-related uses

Thanet might be close to having a Local Plan.
A seemingly interminable saga (see here, herehere, herehere and here) appears to be nearing a conclusion, with the two inspectors examining the draft Local Plan informing Thanet District Council on March 23 that the document has an ‘appropriate basis’ to be adopted as long as a list of modifications is included.
There is also a requirement that the Plan be reviewed within six months of adoption.
The inspectors’ report has now to be considered by full council, with adoption anticipated by summer, depending in part on the Covid-19 lockdown.
The Plan, which covers the period to 2031, was submitted for examination on October 30, 2018, with public hearings held between April 2 and July 18 last year.
The Report and the recommended Main Modifications to make the Plan ‘sound’ can be viewed on the council’s website. Social-distancing restrictions mean no paper copies of the document are available for inspection at Thanet Gateway, but it can be viewed online.
One of the most contentious features of the draft Plan has been housing numbers and this makes provision for at least 17,140 new homes up to 2031.
Manston airport is to be safeguarded for airport-related uses, with future use and development at the site to be determined through early review of the Plan.
The recommended main modifications all concern matters discussed at the examination hearings.
After the hearings, the council prepared a schedule of the proposed main modifications and where necessary carried out a sustainability appraisal of them. The main modifications were subject to public consultation from December 11 last year to January 27, 2020.
After considering the representations made on the proposed main modifications, the inspectors have recommended that these be included.

In summary they are:

  • Introduce new Policy SP01a, which supports the principle of development in the urban area and designated villages
  • Introduce new Policy SP01b, which requires the council to complete a review of the Plan within six months of adoption
  • Modify the stepped housing requirement in Policy SP11
  • Clarify which sites are allocated for residential development in the urban Area (Policy HO1) and the rural settlements (Policy HO11)
  • Modify the development principles for strategic housing sites and include land at Shottendane Road as a strategic housing allocation (Policy SP18A)
  • Amend Policies SP19 and SP20 to provide clarity regarding the type and size of dwellings and the thresholds for the provision of affordable housing
  • Include a requirement in Policy HO22 to identify and allocate sites for gypsy and travelling communities as part of an update to the Plan
  • Introduce a new policy (Policy SP05) concerning development at Manston airport
  • Modify Policies SP02, SP03 and E01 to support new economic development within settlement boundaries, clarify how much land is allocated for employment uses and provide criteria to assess proposals for the reuse of employment land and buildings
  • Modify Policy SP21 to support economic growth in rural areas
  • Delete unjustified and undeliverable transport routes from Policy SP47
  • Modify Policies SP22, SP25 and SP26 to provide effective criteria for development in Green Wedges, and for proposals likely to lead to increased recreational pressure on the Thanet Coast and Sandwich Bay SPA and Ramsar Site
  • Modify the town-centre policies (SP06-SP10 and E04-E06) for clarity and effectiveness
  • Support the extension of the Queen Elizabeth The Queen Mother Hospital through Policy SP37
  • Clarify how new medical facilities will be provided at Westwood and where new primary and secondary schools will be located through changes to Policies SP38 and SP40
  • Provide effective criteria to consider proposals for foster homes and childcare facilities, and the retention of family homes in Policies HO24 and HO26
  • Delete Policy CM04 relating to the expansion of Minster cemetery
  • Update Appendix B to reflect the latest position concerning site delivery

Other main modifications are also recommended to ensure that the Plan is justified, effective and consistent with national planning policy.
A striking feature is the proposed housing trajectory. The inspectors’ modification MM27 Table to Policy SP11 provides for the following average annual housing numbers:
2011/2012 – 2015/2016: 311
2016/2017 – 2020/2021: 600
2021/2022 – 2025/2026: 1,200
2026/2027 – 2030/2031: 1,317

The figure for 2011/2012 – 2015/2016 is based on actual completions averaged over the five-year period.
The modification requires a doubling of completions for the next-five year period 2016/2027 – 2020/2021. This has not been achieved in the first three years. 
For the years 2016/2017 – 2018/2019 only 993 dwellings were built. That averages just 331 per annum. Little more than that was achieved in the first five-year period.
So to average 600 dwellings per annum over the five-year period in the next two years, 2,007 dwellings will need to be built.
That is an annual average of 1,004 and three times that which has been achieved in the previous three years. Given the Covid-19 lockdown and the predicted slowdown in the global economy, it is highly unlikely that these levels will be achieved this year or next year. 
This means that in the last two periods more homes will need to be completed than required by the trajectory, suggesting an increase in housebuilding not seen here before and only in recent years experienced in growth areas such as Dartford.

  • Read the 63-page inspectors’ report here
  • See the recommended main modifications (to make the Plan sound) here

Wednesday, April 15, 2020

There’s a petition against housebuilding levels in Maidstone… and you can sign it!

Plans for a garden community at Lenham Heath have not gone down well

As the fightback against the development onslaught on Kent builds, a petition is being sent to Maidstone councillors asking them to stand up to housebuilding targets set by national government.   
The petition, set up by Peter Burton and titled Enough is Enough: Maidstone’s Housing and Infrastructure, requests councillors:

  • Challenge and campaign against national government’s housebuilding targets
  • Rethink the building of garden communities, which threaten places such as Lenham Heath, Marden and Langley
  • Do not accept new housebuilding levels that are unsustainable for the borough of Maidstone
  • Complete a full infrastructure assessment before the Local Plan Review and ensure all historical infrastructure issues are rectified across the borough before any projects commence
  • Be transparent and engage parish councils and local communities before any final decisions are made with regards to planning and new developments

If you would like to sign the petition, click here

Gravesham residents form group to fight council’s housing proposals

Shorne is one of Gravesham’s more attractive villages (pic Roy Dinnis)

In response to Gravesham Borough Council’s proposal to build 8,000 homes in the borough, many of which are planned to be built on the Green Belt, residents have formed an action group to examine and fight the proposals.
They have formed a group under the auspices of CPRE (Campaign to Protect Rural England). It has four aims:
• To defend the Green Belt
• To challenge the number of homes to be built
• Raise public awareness of air-pollution issues and how air quality can be improved
• Campaign for all new houses in Gravesham to be zero carbon
The challenges facing Gravesham are vast, but if we can all work together they have a greater chance of being resolved.
Alex Hills, chairman of CPRE Kent’s Gravesham committee, said: “We are holding a public meeting at Istead Rise Community Centre – all concerned residents should attend.
“This will be on a Friday towards the end of March and once the date is confirmed it will be published.
“Please email info@cprekent.org.uk or visit our website, cprekent.org.uk, for information.”

Monday, February 10, 2020

Massive increase in housebuilding: a developing tragedy for the Tunbridge Wells countryside

Countryside at Brenchley (pic Gabrielle Ludlow)

Tunbridge Wells Borough Council is in the process of completing its Local Plan, a key part of which is meeting a housing target in line with government methodology. This will mean a huge increase in housebuilding.
Under the new formula imposed by the government, the borough will be required to build 13,500 dwellings by 2036 more than double the number required under the previous Core Strategy.
Many housing developments have already been permitted on valuable Area of Outstanding Natural Beauty (AONB) and Green Belt land, such as at Brick Kiln Farm, Cranbrook, resulting in the loss of part of one of the finest remaining medieval landscapes in Europe. 
The proposed new ‘garden village’ (or new town) at Capel has already been announced, but this is the tip of the iceberg: smaller developments will happen across our rural areas.

A chance to protect the AONB and Green Belt missed
The planning system allows TWBC to protect the Green Belt, but in the case of Capel it appears it has chosen not to do so. This is despite the council’s Green Belt Study identifying “release” of this broad area from the Green Belt as causing a very high level of harm to the Green Belt (Tunbridge Wells Green Belt Study Stage 2, Land Use Consultants, 2017).
Paragraph 11b and Footnote 6 of the National Planning Policy Framework (NPPF) 2019 provide an exception to the requirement to meet housing ‘needs’ where the application of policies in the NPPF protecting Green Belt, AONB, irreplaceable habitats, heritage assets and areas at risk of flooding provide a strong reason for restricting development.
Some 70 per cent of the borough is designated as AONB and 22 per cent as Green Belt, while Flood Zone 3 covers almost 7 per cent. This compares with some 25 per cent of England that is National Park or AONB, and 12.5 per cent of England that is Green Belt.

Land lost based on incorrect housing need forecasts 
There is a prevailing false assumption that simply building more homes, of any kind, will bring down prices. Councils are placed under ever-increasing pressure to meet unrealisable housing targets, compelled to release more land for development and grant more planning permissions, even while many sites (such as the brownfield cinema site in Tunbridge Wells) that already have permission are not built out.
Last year, the final report of Sir Oliver Letwin’s review of build-out rates found that the largest housebuilders were consistently delivering expensive homogenous homes only as fast as the open market could absorb them without lowering prices.
This business model deliberately and explicitly fails to result in the reduction in house prices assumed by those who advocate unconstrained market housebuilding as a solution to the affordability crisis.
It does not and cannot deliver the kind of homes that communities need; rather, it will continue to cover the countryside in poor-quality, piecemeal development.
Worse still, because the ‘standard method’ for estimating local housing need is based on the relationship between house prices and incomes, building more expensive homes, especially in rural areas, leads to an increase in the apparent demand for housing calculated using this method and the cycle of unaffordable speculative housebuilding continues.
The most recent figures from the Office for National Statistics on housing affordability in England and Wales show worsening levels of affordability over a five-year period across most of the country, despite the consistent weakening of the planning system.
At present, the planning system actively reinforces market trends. The standardised method for calculating ‘objectively assessed need’ for housing in each local planning authority area, which takes household growth projections as a baseline and adjusts them according to market signals, concentrates growth and investment in areas that are already economically buoyant and have overheated housing markets.
In the long run, this simply stokes more demand, further inflating rents and house prices, straining local services and exacerbating the oppositional nature of the planning process. Moreover, it further unbalances the national economy.
Government planning policy, as set out in the revised and updated 2019 National Planning Policy Framework (NPPF), prioritises driving up the overall quantum of homes delivered over other considerations, including tenure mix.
It also holds local authorities to account for things outside their control, such as the failure of the volume housebuilders to build out sites quickly.
The introduction of the Housing Delivery Test (recently failed by 108 authorities) places councils under such pressure to deliver more homes that it is difficult for them to reject proposals for inappropriate developments, including those that do not comply with local affordable housing policies.
Moreover, many applications that initially propose to meet local affordable housing requirements are later renegotiated by developers on the grounds of viability.
CPRE’s 2018 research with Shelter found that rural sites where a viability assessment was used saw a 48 per cent drop in the number of affordable homes delivered.
CPRE’s report on the State of the Green Belt 2018 demonstrated that building on the Green Belt was not solving the affordable housing crisis and would not do so.
Last year, 72 per cent of homes built on greenfield land within the Green Belt were unaffordable by the government’s own definition.
Of the 460,000 homes that were planned at the time of the report to be built on land released from the Green Belt (a figure that doesn’t include the 4,500 additional houses now planned for Capel and Paddock Wood), the percentage of unaffordable homes would increase to 78 per cent.
Local authorities with Green Belt land have enough brownfield land for more than 720,000 homes, the report found, much of which was in areas with a high need for housing and existing infrastructure.

Land lost due to low-density housebuilding
TWBC may do its best to put homes on ‘brownfield’ sites, and on areas outside the Green Belt or AONB, but the target is so high that many houses will have to be on Green Belt or AONB land.
An important way to reduce the amount of land required is to maximise the density of each development.
There are two reasons this is difficult in practice. The first is that it is more profitable for developers to build big houses with plenty of land. Secondly, neighbours, faced with a planning application, often ask for the number of homes to be built on a site to be reduced, minimising the impact.
We all need to realise the result of that: another piece of land will need to be sacrificed to take the houses not built here.
The Campaign to Protect Rural England and TWBC both recognise 30 homes per hectare as a fair target for new developments.
Many of the planning applications received are for 15-20 homes per hectare. This means that up to twice as much land is needed for the same number of homes.
Somewhere else? No, your village will have to provide some of the land.  Future generations will ask why we sacrificed land in this way – land that might still be green.
There is another reason density is important. The borough desperately needs more affordable housing. Many parish councils have heard from residents that their children are being priced out of the area, and the supply of new affordable homes in the villages is way below the need. Low density simply means more expensive housing.
Higher-density housing does not need to be ugly. Some of the most desirable properties in our area are terraced cottages on village streets: the high-density housing of the past. There are clusters of homes in converted buildings around old farmyards that use land very efficiently. Even in modern developments a village atmosphere can be created with terraces, while maisonettes and other three-storey developments can be an attractive part of the development.
Higher-density development makes public transport more viable.
Some sites are not suitable for higher-density housing. The answer in most cases is not to accept the low density but to leave the land green.
Over the planning period, the amount of land sacrificed by low-density development could be up to 1,000 hectares – 1,400 football pitches.
We suggest that an opportunity cost should be applied to proposals for low- density development: the land to be sacrificed in the future. A five-hectare plot built at 15 to the hectare has sacrificed 2.5 hectares of land that might still be green.
Meanwhile, despite clear government guidance that “where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities, and ensure that developments make optimal use of the potential of each site” (NPPF para 123), TWBC has been granting planning permission on many sites at low densities.
For example, on a partially brownfield site in the Green Belt at Five Oak Green the borough council is applying to grant itself permission for three four-bedroom and two five-bedroom market houses on a half-hectare plot, a rate of a mere 10 dwellings per hectare, with no affordable housing (19/01586/OUT Land West Of Sychem Place Five Oak Green).
Future generations will ask why we both sacrificed land in this way – including some of our most precious landscapes – and failed to build the homes our young people need.

Monday, July 22, 2019

Setting up the planning system to fail

Here come the diggers!

Richard Bate, planning professional and long-time CPRE Kent supporter, delivers a withering analysis of government housing policy

How often have you heard it said that if only the planning authorities would release more land for housing, then the builders would build more houses and prices would come down?
This is the fundamental belief across the government at present. To the Treasury this is the simple law of supply and demand. Furthermore, given that the market knows best and the planning system gets in the way of the market, it must be right to pull the teeth of the planning system. This is what the government has been doing.
The inconvenient reality is that housebuilders do not wish to reduce house prices discernibly.
At the site level they anticipate particular sale prices for particular products, subtract construction costs, financing and profit, and bid for the land as a residual cost.
If house prices come down, profits erode and enthusiasm to build deteriorates. That’s what happens in recessions. Strategically, businesses do not deliberately flood their own market with the objective of reducing their own sale price.

Release more land for housing?
Giving builders more land may help them to supply more houses, but only up to a point.
Firstly, there has to be a market at their chosen sale price. The government has generously aided this process through Help to Buy and other mechanisms, enabling purchasers to pay inflated prices.
The Chartered Institute of Housing has shown recently that more government subsidy is being ploughed into home ownership than into ‘affordable’ (sub-market) housing to rent. It’s hardly surprising house prices don’t come down.
Secondly, ‘more land’ has ceased to be the solution, because builders can’t use it fast enough. Data commissioned by the Local Government Association shows that planning permissions each year far outstrip completions, that unimplemented permissions are rising, and the period from permission to completion is lengthening.
Third, the greater the choice of sites available to builders, the more they can cherry-pick the financially attractive ones – often greenfield sites rather than recycling the urban sites the planning system would largely prefer. So planning is already less effective.

How many houses?
Despite plenty of planning permissions, annual completions in all tenures are below the estimated growth of some 230,000 a year in numbers of households in England.
Government policy is for the completion of 300,000 dwellings annually, almost twice the number achieved in 2017. You can guess its preferred means of achieving this aspiration: release more land!
To arm-twist planning authorities, the government changed the rules on housing need and supply in February this year.
Housing need is to be calculated by a new ‘standard method’. This is based on the well-established (but still volatile) household projections prepared by the Office for National Statistics every two years.
The 2016-based projections were generally lower than the 2014-based projections, so the government has decreed that the older set will be used. Never mind not using the most up-to-date information if it is inconvenient to the outcome…
The housing need figure for each authority is then adjusted to take account of affordability (a specific ratio of house prices to incomes). All but about five local authorities in the country have affordability ratios above the threshold at which, under the government’s method, their housing need figures will be raised. (The local housing need figure is capped at 40 per cent above the average annual housing requirement set out in existing Local Plans.)
The policy therefore builds into planning practice the government’s belief that releasing more land will bring down house prices.
Unsurprisingly, there is no mention of the degree to which affordability ratios are expected to fall for a given stimulus of land supply. The number of plots that must be provided will generally be well above the number of dwellings needed to match the household projections, so land must be made available for households that are not projected to exist.
Each authority must supply land for at least five years’ worth of building at the required rate.
The government wants ‘concealed’ households to obtain more readily their own homes and households to form that have allegedly been deterred from forming by the shortage of dwellings.
This is more economic gibberish.
The concealed and unformed households are in that position because they cannot afford to buy or rent on the open market and would be unable to obtain subsidised housing, so their needs will only be met by greatly increasing the provision of sub-market housing, ideally traditional social housing.
That is irrespective of the volume of land release. The extra sub-market housing planned is far short of real needs.

Is it all planning’s fault?
The government’s coup de grâce is on housing delivery. Instead of being assessed for their land supply, local authorities will be assessed on the number of dwellings built in their areas. This is despite local authorities barely building any houses these days: that’s the task of builders.
When housebuilding rates in a local authority fall below 85 per cent of its assessed requirement, the government assumes (again) that this is for want of land. The authority will then be obliged to find a 20 per cent extra ‘buffer’ of additional deliverable housing sites.
On current figures, that affects 86 councils in England: in Kent – Gravesham, Medway, Swale and especially Thanet. The instruction to release more land for housing at repeated stages in the process inevitably threatens more countryside, with builders likely to play the system to achieve that result.
The government is setting up requirements that it must know are wholly undeliverable for many local authorities. When housing supply falls short of the new proposed ‘needs’, the  government will berate the authorities and claim it’s all the fault of their planning practices.
That will make it easier to impose yet another round of significant weakening of planning powers – which are obviously getting in the way of housing the nation.
Meanwhile, the original culprit, high house prices, which could be tackled by policies on the ‘demand’ side rather than the ‘supply’ side, will go unchecked. Further, the government has announced its intention to fuel the fire with yet another extension of Help to Buy, beyond 2021.

Wednesday, May 1, 2019