We’ve now submitted our full response to the Housing White Paper, following a major consultation with our branches since the Government launched the wider public consultation in February. The context has, of course, changed massively since then.
A considered response
When the White Paper was published, it was assumed that most of the changes would be implemented later in the year, mostly through alterations to the National Planning Policy Framework (NPPF). Few, if any, of those involved with preparing it were expecting a general election on 8 June.
Whoever forms the next Government is likely to find that the White Paper contains plenty of valuable analysis. We welcomed the approach of the White Paper in that it acknowledged that housing problems are multi-faceted. They are not simply a matter of perceived restrictions in the availability of land, despite the arguments to the contrary from some developers and think-tanks.
The White Paper is, however, much more tentative when it comes to real solutions to both the problems in housebuilding, as well as the challenge of integration with the Government’s environmental commitments. More needs to be done to make sure that the environment is given equal footing in discussions about sustainable development. There is still confusion over the interpretation of ‘sustainable development’, and in planning it has become a much devalued and almost worthless term. We have real concerns that the White Paper will lead to policies for Green Belts and Areas of Outstanding Natural Beauty being weakened, as I’ve blogged before, rather than maintained as the Government has repeatedly promised. This concern was echoed again last week (24 April) in a report by the House of Commons Communities and Local Government Committee.
The whole question of how local housebuilding requirements should be calculated – the so-called ‘objective assessment of need’ or OAN - has now been ducked until after the election. Since the introduction of the NPPF in 2012, the Government has been wilfully vague on this issue. This has allowed housebuilders and land speculators to dominate the agenda with their own massively inflated assessments of ‘need’ in order to justify profitable development in countryside locations.
There are encouraging proposals to make greater use of rural ‘exception sites’ for affordable housing to meet rural social need rather than market demand. But these in turn have the potential to be cancelled out by proposed policies encouraging market housing on any small site that becomes available in a town or village.
CPRE strongly supports the White Paper emphasis on full coverage of up-to-date plans. But this has become harder to achieve in practice in recent years, due to successive budget cuts, as well as a wider policy climate that gives advantage to developers and land speculators. Our branches work closely with local authority planning departments across England. What particularly struck me about talking to these groups was that, time and again, they emphasised a worrying, and increasing, level of weakness in local authority staffing and wider financial resources.
Overall, CPRE is positive about proposed moves to do more to get planning permissions implemented, such as greater use of completion notices and information about building rates. But it is critical that local authorities have the resources to fully scrutinise planning applications and rates of development, and to challenge the claims made by developers. In addition, local authorities should also set housebuilding levels that can be serviced in a sustainable fashion, in particular by a good choice of transport options.
Worse still, the proposed housing delivery test appears to be based on the belief that releasing more land for development will automatically result in more homes being built, and that this in turn will lead to more affordable average house prices. Such an approach has never proved workable in England, despite sustained high levels of land release for development since the 1950s. And experiences elsewhere, particularly Australia and Ireland, show that simply allowing more planning permissions will achieve little. As it is here, developers manage the release of land with planning permission to keep prices high, while the priority must be public investment in affordable housing to meet social need.
The real action now moves from the White Paper to the party manifestos. CPRE’s own manifesto calls for, among other key priorities, stronger landscape protection and further investment in urban regeneration. How will the parties respond?