Planning matters

Amongst the myriad ministerial announcements pre-empting (and eventually included within) the recent Budget, was a government pledge of a further £1.4 billion to meet a target of rebuilding 50 schools in England per year. Against a backdrop of pressure on the public finances, Labour was also in part responding to concerns that only 23 of more than 500 schools on the School Rebuilding Programme have been completed so far by ambitiously ramping up progress towards 50 rebuilds per year’. [1]

Launched by the previous government in 2021, the School Rebuilding Programme carries out major rebuilding and refurbishment projects on school and sixth form college buildings across England, with buildings prioritised according to their condition.[2] Whilst perhaps not at the pace anticipated by some pundits, the Programme is delivering and, as of the September 2024 term, Lichfields has obtained planning permission for new campuses for Whitley Bay High School and Farringdon Community Academy in the North East of England, working with the Department for Education as part of a well-established team led by contractor BAM Construction and Ryder Architecture.

Whilst it is therefore clearly promising that new additional funding should see the Programme accelerated, its remit is currently focused solely on the most dilapidated existing school premises. This is understandable from both a political and financial perspective, but Lichfields’ work across the planning system, and our understanding of the current agenda for reform (as reported elsewhere on these pages), suggests that the government’s aspirations for a step change in terms of housing delivery and Local Plan adoption will also have major implications for the nation’s school provision.

Fundamentally, the Department for Education (DfE) is responsible for ensuring that there are sufficient new school places to meet local needs, whilst the government is also driving forward an ambitious housing agenda to increase housing delivery, home ownership and the creation of new communities. The relationship between infrastructure provision (including high quality school places) and new housing delivery is critical in meeting these objectives in a sustainable manner.

In August 2023, the previous government updated its non-statutory guidance on delivering school places to support housing growth. A key aspect of this was the publication of a new methodology to assist in estimating pupil yield from housing developments[3]. This is intended to assist local authorities in developing and applying long-term evidence of pupil yield from housing developments, to inform local plans and planning decisions, and justify developer contributions towards education. With significant planned increases in Local Plan housing targets required to achieve the government’s ambition to deliver 1.5 million homes over this parliament, the system is, however, sure to be stretched.

To some extent, a healthy, functioning system of Local Plan preparation would ensure this problem takes care of itself. As mentioned above, Lichfields has worked alongside contractors such as BAM Construction on a number of new projects under the DfE’s existing School Rebuilding Programme, including securing planning permission in January 2023 for the redevelopment of Farringdon Community Academy in Sunderland. This development is an excellent example of the DfE’s funding programmes and pupil yield data working in tandem with an up-to-date Local Plan to deliver a state-of-the-art new facility for the City’s existing and future communities. The development involved the demolition of most of the existing main school buildings and the construction of a new state-of-the-art teaching block and a swimming pool; providing over 10,000 m² of new accommodation.

At feasibility stage, the DfE identified aspirations within the City’s recently adopted development plan for significant housing growth in the local area. Specifically, the ‘South Sunderland Growth Area’ (SSGA) was identified as a target for growth and a priority for housing and economic development, with aspirations for a new sustainable community to the south-east of the school site. Within the SSGA, development is expected to deliver approximately 3000 new homes, including 10% affordable housing. As a result, the new school proposals sought to accommodate a Published Admissions Number of 60 additional pupils per year to future-proof the scheme for planned housing growth. New housing and schools play a fundamental role in supporting the health and wellbeing of communities, and with the opening of the Community Academy in September, the new accommodation provides much needed modern and fit-for-purpose teaching facilities to deliver the highest performance standards for generations to come.[4]

Much rests on the publication of the government’s revised National Planning Policy Framework (still anticipated later this year) and its instruction to local planning authorities to upscale their ambitions in relation to housing delivery. The draft NPPF in July also instructed stakeholders to “give great weight to the need to create, expand or alter early years, schools and post 16 facilities through the preparation of plans and decisions on applications” and, teamed with a significant and welcome boost to the finances of the School Rebuilding Programme, there remains hope this can be realised.

Please get in touch with Lichfields’ Health and Education team if there are any points raised in this blog which you would like to discuss or are perhaps relevant to your own projects or Local Plans. You can see the full range of our recent education projects within our Sector Guide (Education Sector Guide).

It’s one year since Lichfields’ blog appraising Reading Borough Council’s (RBC) Local Plan Partial Update (draft LP November 2023) and the “big squeeze” facing Reading to accommodate its increasing development needs within tight spatial constraints. That blog questioned whether RBC could meet its needs without a fundamental change in its approach to permitting tall buildings, and the Council’s recently published updated draft plan partially answers this.

Reading still is not (yet) a city, but it remains one of the top places to live in the UK and has been ranked the fifth best city for “good” economic growth in the UK, within the 2024 Good Growth for Cities report. Reading is defined nationally within planning guidance as one of the 20 largest “Urban Centres”, meaning that it is subject to a 35% uplift on its baseline housing need.

In the context of the borough’s continued growth, RBC has now published its draft Local Plan, the “Pre-Submission Draft Partial Update” (PS Plan), which outlines the proposed strategy and policies for development in RBC until 2041, and responds to previous consultation comments.

The updated PS plan has been published against a political backdrop and planning context which has undergone substantial changes since consultation on the earlier draft LP November 2023.

As a new Labour Government (now politically aligned with the leadership of RBC) pursue a national housebuilding target of 1.5 million new homes over this parliament, the role planning has to play in achieving this is receiving significant attention. A series of reforms to the planning system were consulted on shortly after the election, including revisions to the National Planning Policy Framework and an update to the Standard Method for calculating local housing need.

The “standard method” was first introduced in 2017 but gained notoriety in 2022 when proposals to change it in 2020 gained significant media attention and earned the pejorative “the mutant algorithm”. The latest update to the Standard Method proposed in 2024 would substantially increase the baseline housing need for the vast majority of local authorities in the Thames Valley– including Reading as shown below.

Additionally the draft NPPF proposed various transitional arrangements. These effectively mean that council’s with emerging Local Plans which have reached pre-submission stage (as RBC’s now has) can progress local plans on the basis of the current lower Standard Method housing need, so long as the local plan’s housing requirement is not more than 200 dwellings below the higher housing need figure resulting from the draft Standard Method.

Table 1 puts this into context, showing that the proposed housing provision figure underpinning the emerging PS plan (item e) represents an increase on the housing need planned for within the existing adopted local plan (item a).

 

Despite RBC carrying out their own housing need assessment which identifies a local housing need of 735 dwellings per year (item d), the PS plan recognises the need to exceed this figure, in order to “continue to address the housing crisis and to reflect national policy”. Therefore the pre-submission plan 2024 proposes a target of 825 dwellings per year (item e), which reflects RBC’s assessment of the borough’s housing residential capacity for the plan period to 2041.

However, this still lags behind the housing need figure calculated by the existing standard method (item b), and significantly behind the need figure generated by the draft standard methodology (item f) consulted on by the new Labour Government. Such is the governments drive for housing, RBC will have to provide “exceptional circumstances” for why the new Local Plan falls short of the higher standard method housing need (b) even if it progresses in advance of the NPPF being amended.

With the new Labour Government’s clear focus on housing delivery and the key role urban areas such as Reading have to play, how does RBC’s PS plan seek to accommodate increasing housing needs, and does it go far enough given the shortfall identified against national requirements?

Within the PS plan, Central Reading remains the primary focus for housing with 59% of the homes proposed in Central area across the plan period (approximately 8,700). However a fundamental change to this approach in the PS plan (and perhaps the skyline of Reading) is the widening of spatial areas in which “tall buildings” (defined as 10 storeys of commercial floorspace or 12 storeys of residential or above) may be acceptable.

The adopted Local Plan restricts the construction of “tall buildings” to three specific clusters around Reading Station, west of St. Mary’s Butts and along King’s Road in the easter part of the town centre. This approach has been largely complied since the local plan’s adoption with no tall buildings being permitted outside of designated clusters.

The PS plan proposes to introduce “areas of less suitability for tall buildings” which despite this curiously negative phrasing, widen the areas where tall buildings can be considered acceptable, subject to assessment of detailed effects. The majority of these new areas of greater flexibility represent extensions to the existing Tall Building clusters, but the Oracle and surrounding area falls within an entirely new proposed designation.

Alongside this apparent flexibility for tall buildings, the PS plan proposes a minimum density for residential development in the town centre of 260 dwellings per hectare (dph) subject detailed considerations. Whilst 260 dph represents an increase from the proposed figure in the draft LP November 2023 (200 dph), it is considerably lower than the average density achieved in the town centre (334dph) over the past decade of 2013-2023 as noted by RBC in the draft LP November 2023.

Additionally, 31 new site allocations are also proposed within the PS plan to provide new homes, with half of them within Central Reading. The PS plan also recognises the needs for emerging housing types with policy on “Purpose-Built Shared Living Accommodation” (also known as Co-living), which has seen a growing market in major cities across the UK in recent years.

Alongside new housing provision, the PS plan proposes new policies reinforcing sustainability requirements including:

Restricting demolition of existing buildings unless fully justified, including diverting construction waste away from landfill to minimise environmental footprint

Introducing an Urban Greening Factor Assessment requiring proposals to demonstrate how varying levels of green cover will be delivered on site, dependant on the scale of the proposals

The PS plan will be consulted on during November and December 2024 during which time it will be possible to make representations on all aspects of the plan, from the level of housing provision proposed to the detailed policies affecting development. After this consultation stage, RBC will review the consultation comments and if they consider that no major changes to the plan are required, it will be submitted to the Secretary of State, anticipated to be in February 2025. The examination process which follows (expected to be May/June 2025) will involve a number of public hearings, to assist the government Inspector’s assessment of whether the plan is “sound” and legally compliant.

The PS plan is an interesting test case for how far a Labour led council can and should contribute to the now Labour government’s pro-growth agenda. Currently the plan’s shortfall in proposed housing against both the existing standard method, and draft standard method proposed by the new Labour government is representative of the challenge of government to reach the 1.5million homes across this parliament even within Councils of the same political persuasion.