Example letter to Planning Policy Consultation Team - Sept 2024
Dear Planning Policy Consultation Team,
Here is my response to the consultation on the proposed changes to the NPPF et al.
A. My overriding “suggestion” regarding the proposals, is that they show the government is not attempting to plan for the homes we need. The changes seek to impose a housing target of 375,000 dwellings per year for every one of the 15 years of the local plans – 5,625,000 dwellings. These would typically accommodate over 12.5 million people, which in an era of deaths exceeding births in Great Britain, are all for nobody. It is no wonder that the targets are being set dissociated from household projections – they are nonsensical.
B. Similarly, 375,000 itself is an arbitrary number with no logical basis and it is inconceivable that the UK will ever build such a number. While social rented housing is in short supply there is no public money to invest, and it is evident that the private sector is not going to invest either – they are “land-banking” over 1 million approved plans as it is. This approach, to wish for house building as a band-aid for the economy, without any backing, is destined to fail. It is worth repeating despite it being obvious to all, because the siren voices of the self-interested still say otherwise, that the plummeting rate of house building has nothing to do with planning anyway – in the immortal words of Bill Clinton “it’s the economy, stupid.”
C. The homeless in Southport, Liverpool, Middlesborough, Leeds, Sunderland, Manchester et al, where the recent riots occurred not least because of lack of social rented housing, are being let down by this “levelling down” agenda of reducing housebuilding North of the Watford gap while disproportionately increasing it South thereof – where far fewer are homeless anyway.
D. Our shops and offices are less in demand, and we are seeing the hollowing out of our urban centres. The danger of them becoming slums and ghost towns is palpable. Where are the plans to fix this problem rather than concentrate on covering the countryside with concrete? I thought green space was good for the climate crisis, health and so much more, and not least that homegrown food was a priority. The government is sacrificing all these goals by these proposals.
Chapter 3 – Planning for the Homes We Need
E. I see this chapter’s title and the proposals themselves at complete odds with one another. In short, these proposals will ensure that houses built by the private sector will be the wrong houses in the wrong places.
F. I do not agree with removing all exceptions to the algorithmically derived housing targets for any area (Questions 1, 2 & 4). There have always been exceptions made for areas where, e.g., there are hard constraints like flooding areas or there are demographic differences or a lack of brown (and now even “Greybelt”) land, which would mean such development would ensure, e.g., the loss of protected land, fundamental loss of local character and identity and the respect of local communities. Similarly, it is wrong constitutionally to condemn any area to always fail by setting patently unachievable targets – e.g., what may seem possible for one or two years may be impossible when all 15 years of a local plan area accumulated together.
G. I do not agree with the presumption of the approval of planning applications, e.g., those on the Greenbelt, when an area cannot demonstrate a 5-year land supply (“5YLS”, Question 6). This is a backdoor means of imposing Greenbelt release clandestinely, notwithstanding local plans and so is undemocratic and wrong. It is unconscionable that any LPA grant approvals with a “tilted balance” i.e., with less benefit and more harm, in areas with other unbuilt approvals.
H. I do not agree with calculating the 5YLS from the new algorithmic housing target rather than the local plan target as now (Question 7) or adding any buffer to this under any circumstance ((Questions 8, 9, 10 & 11). Why waste all the time on local plans only to have them ignored?
I. I agree that the government should amend the NPPF to further support effective cooperation on cross-boundary and strategic planning matters (Question 12). However, such cooperation must be independent of the timing of local plan adoption (adopting a plan cannot be a means of avoiding cooperation – at present only LPAs without adopted plans must cooperate). Furthermore, the 5YLS calculations must include land available in adjoining LPAs.
Chapter 4 - A New Standard Method for Assessing Housing Need
J. I do not agree that the government should amend the Planning Practice Guidance to specify that the appropriate baseline for the standard method is housing stock rather than the latest household projections (Question 15). For the first time, housing targets are to be set with no reference to housing needs or household projections. Quite a departure and transparently illogical. New houses whether we need them or not! Another perhaps “unintended consequence” of this proposal is that by it houses are targeted where houses have previously existed not where anyone needs them or wants them – an inconvenient truth.
K. Using the workplace-based median house price to median earnings ratio, averaged over the most recent 3-year period for which data is available to adjust the standard method’s baseline, is nonsensical (Question 16). What have house prices and earnings in the area where your employer bases his PAYE returns anything to do with the assessment of affordability – at the very least both these should be based on where you live not where your company’s HQ happens to be. This “error” becomes particularly severe in an area with a high commuting population – I estimate that in my case this error alone more than doubles the “unaffordability” calculation. NB the ONS publish this data both workplace and residence based so there is no excuse!
L. I do not agree that these proposals give affordability an appropriate weighting within the proposed standard method (Question 17). The weighting is fallaciously based on the assumption that house mortgages are based on a single owner’s income (“4 times”, paragraph 19c of the consultation) and that such income is all PAYE income. This is completely wrong – most mortgages are based on household income and this baseline has been the usual yardstick for such calculations. The proposed approach ignores not least self-employed and other incomes like share-option, and director dividends, which are often not PAYE-based at all. So, any algorithm must use total household income as before, or else it becomes a laughing stock. Similarly, the measure makes no allowance for house value compared to mortgage – in the limit retirees with low incomes often own their houses outright… In summary, the planned approach places too much weight on this fallacious assessment of affordability.
The absurd results of this mutant algorithm are clear in my local area, Elmbridge, where it says houses are unaffordable; they cost 24 times one local income. The policy claims that building 30% more houses here over the next 15 years will reduce the average house price by 600%. However, a) if they are so unaffordable how then essentially all of them are occupied and b) as these new houses will be executive homes on the Greenbelt, our average price will rise not fall.
N.B., the policy is to increase housing numbers in Elmbridge by 1,443 per year every year for 15 years (21,643 houses), ~30% of the housing stock today. This is accommodation for c.47,614 people adding to our population of c.140,000. Who will build these houses anyway? Elmbridge is an area where deaths exceed births – therefore perhaps nobody will buy them. This is 3.2 times more houses per year than Elmbridge has ever built and note, every five years this number will also increase - under the policy the more Elmbridge builds, the more Elmbridge must build.
Chapter 5 – Brownfield, Greybelt and the Greenbelt
M. I do not agree with the proposed definition of Greybelt land (Question 23) as this is unlimited. Previous development of any amount or even just merely nearby qualifies any amount of Greenbelt land as Greybelt. At the very least the rule should be that any development will not exceed the linear area of or be in an area different to the prior development.
N. I agree that the government should make additional changes to the NPPF to ensure that owners do not degrade high-performing Greenbelt land to meet Greybelt criteria (Question 24). As a start, the Greybelt definition should disregard all development of the last (say) ten years.
I am also strongly against any suggestion that one piece of Greenbelt can be any more or less well-performing than any other. All Greenbelt is equally well performing – if only because all of it is performing the role of promoting urban regeneration. The government should not introduce subjectivity into the policy via arbitrary measurements of performance.
O. I do not agree that the government’s proposals support the release of land in the right places (Questions 28-33). While I see the merit of judicious reuse of previously developed and Greybelt land (properly defined), there can be no justification for releasing Greenbelt land for housing outside of the 15-year local planning cycle.
P. I do not agree with the government’s proposed approach to the affordable housing tenure mix (Questions 34-36). Firstly, “affordable” now means nothing, planning policy has devalued this word. I would restrict any release policy only to “Socially Rented Housing.” Furthermore, there can be no justification for releasing any Greenbelt land for market housing (or its synonyms like affordable rent or shared ownership housing) so the 50% target should be 100%. Experience shows terms like “BNG net gain” and “improved public access” are simply meaningless obfuscations, excuses for the unspeakable – the government should remove these and similar terms from the NPPF.
Q. I agree that the government should set indicative benchmark land values for Greenbelt land (Question 37). As this should always be at cost to the exchequer, there can be no justification for paying over the local agricultural land value for this land – so not an “indicative benchmark” but the actual price paid to the landowner.
R. I do not agree that contributions below the level set in policy should ever be acceptable (Question 41). Furthermore, development should never be subject to late-stage viability reviews, but payments made upfront. It is little wonder local government is teetering on the edge of bankruptcy given the latitude presently granted on such matters.
S. I believe all the “golden rules” should apply to all Greenbelt land, whether the LPA is releasing it by a new or has done so by any previous local plan (Question 43).
Chapter 9 – Supporting green energy and the environment
T. My main “suggestion” relating to the government’s proposals in this chapter (Question 86) is that there is a glaring hole in that there is no mention of a) better insulation of any new home or b) solar/wind generation installed on any new home. There is no time to waste in this climate emergency so omitting these vital and simple changes is simply unimaginable.
Thanks for listening and hopefully changing the proposed policies accordingly.
Best Regards,
Adrian Wise
