5 minute read
Cameron Austin-Fell (MRTPI) is a Chartered Town Planner and Director of Planning at RPS, a leading global multi-disciplinary professional services firm. Founded in 1970, RPS works across six sectors: property, energy, transport, water, resources, defence and government services.
Cameron works within the Planning Team which sits within the property sector and has a particular focus on strategic housing growth and supply. As part of this role, he is actively engaged in Local Plans up and down the country and is a key contributor to the discourse surrounding housing need and supply.
Damian Sullivan MRTPI from Sigma Strategic Land sat down with Cameron to find out more about this critical issue…
- Cameron, thank you for joining me in person for this Q&A session which is one of a series in which we discuss a wide range of housing matters that I’m sure will be of interest to our followers. Sigma Strategic Land (SSL) operates across a wide geographical area of Surrey, Sussex, Hampshire and outer London, as well as the home counties. However, our main focus is on Sussex and Surrey since we are geographically best placed to operate in these locations with our office located in Horsham. How do you see housing delivery working in Sussex and Surrey particularly in light of the recent changes to the methodology for the calculation of housing need and where does London sit in all this?
Well, it’s all change for this area! The home counties are poised to deal with the future or emerging problem that is London and how you deal with the historic undersupply of delivery here.
The calculation of the standard method is very different to what it was 12 months ago with the ‘mutant algorithm’. This was framed as control somehow being taken away from an area. The reality is very different. There is clearly a high housing need in Sussex and Surrey. But that's not because of some metric that doesn't bear any relevance to the area. There's a high need because we're looking at population projections, or household forecasts twinned with affordability ratios. This is related to how the area has grown in the past. And you need to uplift that to account for how severe your affordability pressures are. Consequently, these are very real issues for each of these areas.
Although the methodology was changed again in December last year, we can still see, on average, an uplift in what the Councils were previously dealing with under the old Local Plan regime. Consequently, for this entire area, there is a significant challenge in meeting the Government's growth aspirations going forward. But as you suggest in your question, perhaps for the first time there is an imperative to consider the position in London. In my opinion, this is going to be a central plank in achieving the Government’s ambition of delivering 300,000 homes per annum by the mid-2020s and how it can be resolved in this area. It is therefore going to be an instrumental change. How this area rises up to the challenge is key as to whether or not the 300,000 homes target will be met.
- In constrained Authorities such as Waverley or the South Downs National Park, is there a better way forward in trying to calculate housing need more accurately? When does a constraint become a significant obstacle to housing delivery?
Well, it’s quite interesting because the whole premise of the standard method was that Local Plans were taking far too long to be examined. We needed a simpler way. We needed to cut all these discussions about housing need out of the equation.
Meanwhile, it was important for environmental factors to be fed into the housing need equation and for these to be protected. But I think there is a different way of calculating housing need more accurately.
The Government has advocated that where exceptional circumstances exist, Local Planning Authorities can adopt their own approach. The question is whether Local Authorities will start to do this more often? Although it’s very early days, we have already seen at a local level, a contest of the Government’s standard method in authorities such as Central Bedfordshire Council and Aylesbury District Council. This is not from a Local Plan perspective but within an appeal environment. These Authorities have contested the use of the standard method over more local information that has been presented. This stems from the argument that population statistics are not factually correct. The Government has sought to rely on the most up to date population projections, but for reasons made clear over the past 24 months, the 2016 and 2018 projections have not been fit for purpose. They have provided very different results.
The 2014 population projections are much more stable and so have been used by the Government for setting the standard method. But it must be borne in mind that these projections are quite dated and bake in trends from the period 2009 to 2014.
What I think we’ll see is that if the output number is somewhat agreeable, Councillors will roll over and use that but if they wish to argue that the number cannot be met, they may take this alternative ‘exceptional circumstances’ route. Or they may, seek to use the standard method figure to argue the number down because there are certain constraints that limit the ability to meet their housing target.
For example, in the case of the South Downs National Park, you have got some key drivers that would push the standard method number down. But it has to be a balancing exercise and more holistic consideration is required of how much we want to work towards addressing the housing emergency in this country? This is about balancing housing growth versus what is actually important for the purposes of environmental protection. I do think that we will start to see a bit of clarity on the issue with the changes to the planning system and the zonal approaches under consideration.
The whole issue of delivering housing in the face of constrained Authorities – both environmentally speaking and spatially constrained – has been beset by difficulties and delays.
One of the notable cases is Brighton and Hove City Council (BHCC) which identified a housing need of around 30,000 dwellings in their 2016 Local Plan. But when all things are considered, they looked at their availability of land and only had enough land to deliver around 13,000 homes. So there’s a gulf, a shortfall of 17,000 dwellings. This is due to the spatial constraints of having a densely built-up area, combined with the National Park to the north and sea to the south and so it forms a barrier to moving forward. The Council had a starting point there of an Objectively Assessed Housing Need (OAHN) of 1506 dwellings per annum. But that’s the figure they moved down from. Under the new standard methodology, the figure is now 2,311 dwellings per annum.
This points to having key strategic arrangements put in place to ensure that this housing is going to be met elsewhere. Brighton and Hove CC is also one of the top 20 cities with an additional 35% uplift on its OAHN. It is interesting because we have already seen some Authorities with a similar uplift push back on this uplifted amount. My key concern here is that when you look at the 20 largest Authorities, you are looking at areas that are heavily constrained such as the Green Belt or in spatial terms such as Brighton and Hove.
We have already seen as part of the emerging Bedford Plan that they have already put their hands up and said they are simply not going to be able to meet this figure. I expect a number of other metropolitan areas will start doing the same. Therefore, whilst the standard method is a very clear starting point, there can be drivers including economic need that push the number up. But the reality is that it is only going to move downwards when Local Authorities find themselves quickly frustrated by lack of available land. It is a very interesting problem.
- SSL sees Sussex and Surrey as very much the cornerstone of housing delivery in England. Is there value for a strategic planning framework that secures the supply of housing and how do you see this working in practice?
I think if the Government is to realise its 300,000 dwelling per annum ambition, there needs to be more formalised arrangements in place under the most recent planning framework to come together to present spatial development plans. This will have a different emphasis than previous Local Plans.
We know that the Duty to Co-operate is going to be removed, but it’s not going to be left in a void, it has to be replaced by something else. I very much see this as a new wave of plan-making. It has the ability to really grasp the nettle and to create a template for authorities to work together in order to deliver cross-boundary needs. These usually relate to housing - sometimes infrastructure challenges are present - but the biggest failure to the plan-making system over the past few years has been the inability to deal with cross boundary housing need.
Take the examples of Sevenoaks, Tandridge, Wealden and St Albans. These and several other authorities have failed the Duty to Co-operate in their plan-making fairly recently. I am sure that the Government do not wish to see this happening as it is in their interest for Local Plans to be brought forward and become adopted. But it is quite clear that we should have strategic frameworks put in place in order to achieve greater Local Plan success going forward.
We are starting to see this collaborative approach with the coming together of a Joint Plan covering three or four authorities. For example, the Greater Manchester Plan and the London Plan. Where there are devolved planning powers covering a sub-regional scale, you have a greater ability and political drive to actually deliver on your housing targets. In my opinion, other Local Plans should follow these same principles. It is important for Local Authorities to commit at a very early stage regarding what your housing number is going to be and be honest about the constraints and say you are not going to meet the number and start calling out your neighbours to assist with that.
Even Authorities with constraints still need to take some accountability in this process. There are some overarching responsibilities over a region or even larger scale that a single Local Plan cannot serve. Strategic planning does fulfil that need.
In my opinion, the key to the success or failure of the new planning system is found in the new duty to co-operate.
Image credit: Ministry of Housing, Communities & Local Government, Planning for the future
- SSL finds that Local Authorities respond best to good place-making and adding value to the sustainability of a place. Do you think the intended distribution of housing brought through the standard methodology can accurately capture where it is actually needed the most? And do you think this will lead to good place-making?
If you look at the standard method and how it’s calculated, it does drive housing growth to where it’s needed the most. One of the key indicators is housing affordability to solving the housing crisis, but it is not the only one. There are actually plenty of factors involved here. If you look at how an area is forecast to grow, then certainly the standard method will put houses where they are needed the most in order to address the imbalances of supply and demand.
We do need to look at this through a placemaking lens because it is certainly the Government’s imperative at the moment. We have seen this through recent changes to the NPPF which is very much design heavy. It is now about how the Government will resolve that tension between growth and the placemaking agenda. It is not simply about the numbers anymore. We have seen recently with Christopher Pincher’s announcement about the OxCam Arc that it is about boosting the economy of a region and it is not just about putting a numerical target in place for housing growth.
Consequently, housing numbers are very important to understand in providing context about how an area is going to grow. But placemaking needs to be considered in the round, especially when you’re considering the carrying capacity of an area and how we are able to grow our towns and villages in a sustainable way. This comes downs to how an Authority looks at the spatial distribution of growth and this should form an active consideration on the matter.
- How do you see the Housing Delivery Test playing out in Sussex and Surrey Authorities over the next year or so?
The Housing Delivery Test (HDT) is the Government’s new favourite toy! But in terms of trying to encourage Councils to deliver more housing, the Government appears to want to do away with the five year housing land supply calculations and sit only behind the Housing Delivery Test. If that is the case, it’s not going to be good!
As of 2021, it is the first year where the transitional requirements for HDT have really started to come into place. We have 55 Authorities that have failed the housing delivery test i.e. they’ve fallen below the threshold and therefore the NPPF Para 11(d) presumption is engaged. But is it really engaged? Only if you look at the spread of those 55 Authorities, most of them are constrained by Green Belt.
So when HDT is out in full force, it is about whether it actually has any particular bite and whether it has the ability to work as a tool to deliver more housing growth. This is because the Government’s political priority remains more aligned with the Green Belt than the power to engage Para 11(d). This is something we have seen time and time again. This is not to say it is not an effective tool. I consider the Housing Delivery Test, just like any other policy instrument, might need to be amended to make it a stronger device aligned with what is going to be the new planning system.
- SSL secures land by way of promotion and option agreements before taking them through the planning process. Often this is over longer timescales where the housing land supply position of an Authority is simply unknown. How can RPS help manage these aims and objectives of our business and other SME developers?
Well in the past 18 to 24 months, developers are struggling to find land and land values are spiking on the back of that. The opportunities are becoming harder. It is therefore important to work out where Authorities are going to be in 5-10 years’ time in order to have a competitive advantage over other developers. There is a number of different ways I think that RPS can add value to that process.
One of them is modelling and forecasting and working out the Council’s housing land supply in the future. This is not simply looking at what has been published now, but looking at trajectories of land supply position and whether an Authority is reliant on larger sites, the effect of the standard method and any policy changes including emerging plans in neighbouring areas including the prospect of addressing unmet need. I think that when one looks at all these factors together, it is possible to understand the optimal time to present an application to the Council as no developer wants to go appeal unless they have to.
A lot of the work we see ourselves doing is kind of a ‘critical friend’ to an authority. We work with them to sort of try and highlight or expose some of the challenges that they're going to be facing over the next few years. We can help promote a particular site that could come forward to help deal with that problem before it exists. If a site is in a good location and all the technical issues have been addressed, then there is no reason why it can't come forward. The lack of supply or the presence of a land supply is certainly not a cap on development by any means.
- How do you see the main tensions of designations and constraints playing out against the need to increase the supply of housing? Are we any further forward in light of the known changes to planning?
I think that planning is going to remain highly politicised. But with the raft of planning changes we are expecting, I think we are going to be largely in the dark about what is going to happen until the end of this year. I don’t think it’s going to be a revolution; more of an evolution of the planning system. I don’t think it’s going to be as marked a change as previously envisaged. The political messages we are receiving now in the media means that it is going to be a watered-down proposal.
We have also seen recent changes to the NPPF causing concerns to Councils such as Horsham DC with the requirement to consider a 30 year vision in their Local Plans which is causing a hiatus to plan-making. That is absolutely the wrong thing to do. Instead, they should have worked it through the system and found a solution rather than causing more delay and uncertainty in the planning process. This is particularly relevant given that Horsham DC has been found wanting in their housing land supply very recently.
- Within the south east and predominantly Sussex and Surrey, there needs to be a range of constraints and designations to successfully navigate when looking to develop a site. How can RPS assist us in this regard?
One way RPS can assist is in the digitisation of planning. Rather than identifying the static kind of views of what the issues are on the ground, we use technology such as GIS in order to make complex, easy. This makes the process easier and quicker by helping you understand what the constraints are on the ground. But you can also use GIS in other interesting ways. For example, we can look at features such as disused railway stations, plot recent growth and activity and to work out how settlements are expanding and what they are in deficit of. We can also work out where key nodes on the strategic transport network are situated in order to build growth points in the future. We would advocate detailed site searches for clients such as SSL and help identify opportunities you might have missed, whilst exploring areas that add some value to the already comprehensive analysis you already undertake.
- To what extent does housing land supply come down to numbers, or is it a wider discussion around interpreting the numbers when arguing the case either at planning appeal or Examination in Public?
We have increasingly seen Planning Inspectors at appeal needing to be savvy about a Council’s housing land supply. What was a niche area in the past is now fairly commonplace. This is a precise signpost for how important housing numbers have been to the success and deliverability of a proposal. In every sort of application and appeal for residential development, there is increasingly being seen a grappling of the housing numbers debate.
But importantly, this is not necessarily going to result in an appeal win if you do not have a good site and scheme. That is, if the fundamentals of a case are not there and the development is not sustainable, then housing numbers are not going to be the “silver bullet” to the problem.
It is certainly very important to help demonstrate the immediacy of the housing problem, particularly if you're looking at the benefits of both market housing and affordable housing as you should be doing. However, more and more often now, we're seeing proposals that have been set within the context of an Authority’s shortfall of housing land supply, but have been dismissed on other issues. Therefore, housing land supply remains an important component of the development process. But you still need to ensure that proposals stack up by themselves.
- SSL looks for strategic opportunities across predominantly greenfield settings, but will also look at brownfield and urban centres. How do you see the south east potentially balancing the three key areas in terms of delivery and is the Covid-19 pandemic expected to delay completions to the extent that it becomes concerning?
The housing emergency is not going to be addressed by one type of site alone, it is going to require significant regeneration of urban areas and on brownfield sites. There is going to be the need for expansion of our sustainable towns and villages.
What we have seen over the past 18 months is the way in which we’ve come to view future housing need because it is one thing looking at numbers on a page and actually another looking at the type of houses people actually want.
Looking at the recent local market activity, there has been a significant move away from the city centre and urban living. People value more space and the opportunity afforded by suburban housing. If it is in a sustainable location, where people can work in an agile way, working at home and commuting into larger metropolitan areas have given them a better quality of life.
What this means is that the emphasis on brownfield regeneration is not going to change. But this shift in people’s movement due to Covid-19 might be the motivating influence to open the Government’s eyes about what to do with the Green Belt and whether there needs to be a commitment to a national or sub-national Green Belt review.
It is quite clear that this sort of delivery is not going to be met on urban sites alone and so we require a pragmatic view. Once again, an honest reflection is needed by Councils about whether there are any areas of lower sensitivity of Green Belt that could be released for housing. I know that people even within the Conservative Party like Jacob Rees-Mogg was advocating such an approach in the past.
Indeed, the political messages coming out of the media fairly recently is that there is a lot of support from the younger generation to develop on the Green Belt in order to help people buy their first home. We may therefore see a bit of movement to what has been historically a bit of a stone wall policy approach from the Government.
From the perspective of SSL, there needs to be that balanced portfolio of sites. There will be a continuing need to look for those good Green Belt sites to come forward at some point in the future. But you should look for shorter term opportunities on brownfield sites in more urban areas that would garner greater political support in the short term.
So, all are important strategies I would say Damian, there's no one single solution to this.
Thank you Cameron for such an incredibly insightful Q&A. I’ve certainly learnt a great deal about housing land supply and dissecting the housing emergency. I now open up further discussion from our readers! Thank you again for your time.
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