Housing Need consultation: The (green) elephant in the room?

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Following the publication of the Housing White Paper (HWP) in February and the many, unanswered, questions it raised (see our commentary piece here), the Government has now published a further consultation document focussing on the following key elements:

  • Standardised OAN calculation
  • Effective and early co-operation between LPAs (statement of common ground)
  • Housing Mix
  • Neighbourhood Planning; and
  • Viability

Standardised OAN calculation

A standardised way of calculating objectively assessed need was mooted in the HWP and has been broadly welcomed within the industry.  As the consultation paper makes clear, the issue of housing need and how it is calculated is a constant source of delay and argument, particularly at Examination.  The complexities of the process mean that housing need assessment is often seen as some form of “dark art”, unfathomable to those without detailed expertise in the field.  The standard calculation is intended to speed up the development plan adoption process by removing the need to discuss the figure at Examination and is a step in the right direction.

However, there are problems with the methodology put forward.  The proposed formula does not directly take into account anticipated employment growth within an area, which is likely to be a source of argument at Examination.  As a result, the formula merely seems to widen the north-south divide by indicating the requirement for a significant uplift in housing provision in many parts of the affluent south, whilst suggesting a general reduction in provision in the north.  The housing uplift required is particularly acute in the South East, in areas where the Green Belt prevents significant growth for many authorities where the need is identified as being greatest.

The Government has reinforced its position of protecting the Green Belt.  This therefore begs the question of whether the housing uplift can be achieved in practice, when the political will is simply not there to address what is a significant constraint in any meaningful way.  Indeed, there has already been a backlash from backbenchers in a number of South-east constituencies (see Planning article here).  Until a more realistic approach is taken to Green Belt releases, or the rumours of the rebirth of Council housing are to be believed, the 266,000 dwelling target put forward is unlikely to be met, even with greater co-operation between authorities.

The paper has dangled a carrot, in the form of an assumption that an emerging plan is “sound” if housing numbers are increased beyond that imposed under the standard calculation.  In practice, such an approach is unlikely to be followed by many authorities, unless this would lead to significant infrastructure improvements in tandem.

Statement of common ground

The proposed Statement of Common Ground is intended to ensure co-operation between neighbouring authorities at an early stage (within 12 months (?)of publication of the revised NPPF), particularly in terms of how they will meet “housing and other needs” across boundaries.  This is fine in theory but, in practice, most authorities are already co-operating as part of ongoing Local Plan preparation/review.

Whilst the statements will not be individually examined by PINS, they will form part of the evidence base for each Local Plan Examination and be updated throughout the plan-making process.  It is therefore difficult to see how such statements will help to speed up t plan adoption, given that co-operation is already a key part of the process.

Neighbourhood Planning

The consultation paper is seeking views on whether local planning authorities should be expected to provide housing figures for designated neighbourhood planning areas (NPA), based on a simple formula using the population of the NPA and extrapolating a housing figure from this based on the overall population of the local authority area.

In our view, whilst such an approach is helpful, the formula is too simplistic. Such a formula also needs to take into account the presence of community facilities (e.g. schools, shops etc) in order to ensure sustainability.


The consultation paper highlights a perception that viability assessments are currently subject to “gaming”, with figures manipulated to meet developers’ requirements and agreements reached in smoky rooms behind closed doors.  The consultation paper proposes to make viability assessments “simpler, quicker and more transparent”.  It intends to achieve this by changing national planning policy to make it clear that planning applications that meet policy requirements set out in an adopted plan “should be assumed to be viable”.

However, the paper seems to be assuming that viability is not currently part of the plan-making process, or that developers do not take policy requirements into account when proposing schemes. This, in our experience, is simply not the case.  Most, if not all, authorities look to prepare evidence to back up emerging local plans, which assist in drawing up affordable housing and infrastructure requirements (e.g. infrastructure delivery statements). Similarly, developers will assess policy requirements (e.g. affordable housing thresholds, financial contributions) when deciding whether and when to take sites forward.  It is also the case that many authorities require viability assessments to be “open book” so all figures can be assessed to ensure transparency.

Markets and economies are constantly changing and viability often requires reassessment as a result. In reality, the proposals set out in the consultation paper are unlikely to change anything.


Whilst some of the proposals set out in the consultation paper are to be welcomed in principle, much of what is proposed is already happening in practice and is unlikely to make any significant difference to the speed of the plan-making process.  Without a fundamental reassessment of the role of the Green Belt, the significant uplift in housing required in the South East, seems unlikely to occur in practice.

In summary – as you were.

The closing date for comments is 9th November 2017.  If you would like to discuss any of the papers contents, please contact Andy Shepley.

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