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Round and round in (almost) circles – initial thoughts from the North East on the new new new (!) Standard Method
The issue of housing need and the number of homes being planned for is really important and it’s great to see it getting more airtime and column inches in the mainstream media. But has this led to yet another kneejerk reaction that will result in harmful outcomes for the North East? When reading the news of the Government’s latest proposals for the Standard Method, I was reminded of an episode of The Thick of It where beleaguered MP, Nicola Murray, pleads “That WAS a U-turn! If I do another U-turn it’s an O-turn.” The latest iteration of the Standard Method, which has been causing consternation (albeit for different reasons) amongst planners, developers, MPs and the general public since its proposal in 2017, will largely return to the approach suggested previously, with a single modification that falls considerably short of those which its various critics advocated during the recent consultation. As set out in Lichfields’ recent blog, the Government has now announced that the Standard Method will largely remain that which was first introduced in 2017. The only difference is that an uplift of 35% is applied to the 20 largest cities across England. For the vast majority of LPAs, including 65 of the 72 LPAs in the North, there will be no change in their housing need figure. As a result, it is hard not to feel that a great deal of time and effort has been expended to arrive back at somewhere very close to where we started out over three years ago – and there was broad consensus that that approach wasn’t fit for purpose! How does the Standard Method work and why is this a problem in the North? The formula which underpins the new (SM3 - the third and what now seems likely to be the final) version of the Standard Method uses the 2014-based household projections to identify a demographic baseline for each local authority (LPA), which is then uplifted to address local affordability and is finally capped (if needed) based on the age of the LPA’s Local Plan. The ‘cities and urban centres uplift’ is then applied to this figure. The problems (particularly for the North) with basing the Standard Method on the household projections, has been extensively discussed by Lichfields. The projections are based on historically low population growth which was followed by suppressed household formation rates experienced during the 2008 recession. As a result of the projections being based on past trends, these are perpetuated in future projections. This is acute in the North, where the recession had a particularly significant impact. Given that the newest version of the formula is, for most LPAs, unchanged, it is unsurprising that these issues remain. The increased age of the projections still being used in the SM only compounds these problems. As a result of the artificially and excessively low baseline, the affordability uplift is largely irrelevant for most northern LPAs, where affordability ratios are typically lower than in the South of England. The third stage of capping the resulting Standard Method figure is irrelevant in the North, as the Standard Method outputs are lower than housing requirements set out in Local Plans. An opportunity missed? SM3 results in an overall national figure of 297,600, which is closer to, but still below, the Government’s target of 300,000 new homes each year. It is also significantly less than the figure of 337,300 dwellings per annum generated by the version of the formula consulted on in August 2020 (SM2). The reason why that figure was so high was to ensure that even after some LPAs had justified the use of a housing requirement lower than their SM2 figure, the 300,000 home target could still be achieved. The difference between the two methods is stark in the North; SM3 results in a figure of 47,500 dpa, higher than the figure of 43,300 dpa generated by SM1 (the current version of the Standard Method), but significantly less than the 49,800 dpa identified by SM2. More significantly, and worryingly, the SM3 figure is over 20% less than the average number of homes actually delivered across the North in each of the past three years - 59,600 dpa. Figure 1 Comparison of Standard Method approaches for the North Source: Lichfields In the North East, the discrepancy between SM3 and past delivery levels is even greater; SM3 results in a total of 6,625 dpa, compared to the average delivery levels of 9,815 dpa, a decrease of 32%. Indeed, SM3 exceeds past delivery levels in only two of the 12 North East local authorities (Gateshead and South Tyneside), even with Newcastle’s ‘cities and urban centres’ uplift. Table 1 Comparison between original Standard Method, August and December proposals and past delivery Source: Lichfields (Figures correct as of Dec 2020) SM2 was considered a moderate improvement on the original approach when applied in the North East (although a number of issues remained unaddressed). The major difference was that the revised approach used the higher of the 2018-based projections or 0.5% of existing stock as the baseline. As a result, the proposed figure across the North East was significantly closer to past delivery rates than when projections alone are used (as in SM1 and SM3).  Additionally, a stock-based approach provides a much more stable method to identifying a baseline position, as it is based on the number of existing homes in an area which does not experience the significant fluctuations observed through projections, which are updated every two years. Finally, SM3 reverts to using the 2014-based projections, despite the fact that two sets of projections have been released since. In their rationale for retaining the current (SM1) approach, the Government state that although use of the 2018-based projections has been carefully considered, “due to the substantial change in the distribution of housing need that would arise as a result, in the interests of stability for local planning and for local communities” the 2014-based projections should be used instead[1]. This approach seems counter-intuitive given the importance of using up-to-date evidence, including within the Standard Method itself (affordability ratios) and does not seem like a long-term solution as we move further away from 2014. In the North it causes decline rather than stability. 20’s plenty…or is it? As shown in Table 1, in the North East only Newcastle sees a difference in SM3 when compared with SM1. For every other LPA, the Standard Method is back where it started, with all the associated problems. This is because only Newcastle is within the 20 cities to which the 35% cities uplift is applied. Looking more broadly, seven (Newcastle, Manchester, Liverpool, Leeds, Bradford, Sheffield and Hull) of the 20 cities are found within the North. The uplift is only applied to the LPAs which contain the largest proportion of the population for each of the 20 cities identified (with the exception of London, where an uplift is applied to all Boroughs). This approach is problematic for a number of reasons, as discussed in my colleague Harry’s blog. Specifically in the North East, Newcastle is part of a much larger functional economic and market area that extends into Gateshead, which shares a local plan with Newcastle, and North Tyneside. Both areas play key roles in supporting the wider city. However, under the proposed method, these authorities will receive no uplift to their housing need figure. Although Newcastle appears able to accommodate the entirety of the uplift, concerns have been raised previously about the proportion of housing delivered in Newcastle that is student accommodation and city centre apartments compared to family housing. It is also unclear why the Government has chosen 20 cities and a 35% uplift. At face value, both would seem to be arbitrary figures. Why not apply a lower percentage uplift to a larger number of cities, which would help to ensure figures remained deliverable, whilst maintaining the Government’s aspiration to direct more growth to cities and urban areas? This might have the added benefit of directing a greater proportion of the national housing need to cities in the North, supporting the Government’s levelling up agenda. Finally, the Government’s strategy behind the SM3 is that the urban centres are the most sustainable locations for large amounts of new housing, they have the largest supply of brownfield land and often the most acute affordability problems. That appears laudable in theory but, in reality, there could be problems: Is there enough brownfield land to meet these needs? Is it in the right locations? Is it suitable for the type of housing that is needed? Can it be developed viably? If plenty of suitable, viable and available brownfield land exists, why has it not already been developed? 14 of the 20 cities are constrained by Green Belt[2] or Metropolitan Open Land. Newcastle took the bold decision in their Core Strategy to release land from their Green Belt which has supported their recent healthy supply and balanced the city centre student and apartment accommodation with family housing. Can the physical and social infrastructure cope with this additional concentration of demand? Will there be sufficient supply to address the affordability in other areas? Will there be sufficient supply to address the other reasons why more housing is needed? In the North these are often more significant than affordability.  One size simply doesn’t fit all One of the key criticisms levelled during the consultation on SM2 in August 2020 was that imposing centralised local housing need figures, dictated by national Government, would significantly weaken local democracy by taking decision-making away from local people and Councils. Further criticisms highlighted the apparently arbitrary inputs to the formula. It was also stressed that reliance on a single formula was no substitute for local knowledge and expertise taking into account constraints and opportunities and does little to address the vast range of housing challenges and local strategies in different areas of the country. In the North East, many discussions focused on the continued absence of an economic uplift factor within the formula, reflecting the importance of providing sufficient quality and choice of housing to support the North’s economic aspirations by attracting and retaining young people. SM3 does nothing to address these problems. It still only takes account of a very narrow range of factors (if anything the removal of a stock component is a backwards step for the North East). It focuses solely on affordability, which, though a key factor, is just one of a number of challenges that drive housing need and, particularly in the North, fails to recognise other factors which are at least as important. It applies a one size fits all approach and imposes a housing need figure on local Councils. It uses arbitrary inputs and, indeed, has increased these. Lastly, far from ‘levelling up’, it continues to funnel housing development towards London and the South East, at the expense of the North East. After three attempts, is it time to accept that local housing needs simply cannot be calculated using a simple national formula? A broader debate is needed to consider alternative approaches that recognise the importance of this country’s rich local diversity and actually facilitates ‘levelling up’.    [1] Government response to the local housing need proposals in “Changes to the current planning system”[2] Local authority green belt statistics for England: 2019 to 2020 | #planoraks: Well, now we *really* need to talk about the Green Belt  

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Bedspace: a framework used to assess the need for Purpose Built Student Accommodation
Most university locations across the UK have seen an influx of Purpose Built Student Accommodation (PBSA). In response many Local Planning Authorities now require developers to demonstrate the need for this development. How can Bedspace help? Bedspace strengthens the justification for PBSA by:  Presenting evidence led quantitative analysis of current and past trends in student growth and student accommodation preferences; Analysing the supply pipeline as well as the potential future capacity for further PBSA, cognisant of both past trends and of university growth ambitions; Detailing the potential economic impacts generated during construction of the development and after its completion; and Presenting this assessment in a planning application document which has proven track record with Local Authorities. Who is it for? PBSA Developers: Demonstrating the need for PBSA in a given University location or informing early investment decisions; Local Planning Authorities: Understanding student accommodation needs in their area and providing robust evidence for emerging development plans; and Higher Education Institutions: Understanding the mix of student accommodation in their area and informing expansion of their accommodation offer. Bedspace features two examples of student base data in local authorities, one of which is Oxford City Council (OCC). The need to deliver general housing, whilst ensuring student accommodation is provided for during the plan period, is acutely relevant to OCC, and thus presented an interesting case study. It has been identified that in the catchment area of Oxford City there are 32,295 students, split between its two universities; Oxford University (19,265) and Oxford Brookes University (13,035)[1]. If the city’s student population was to increase in line with past growth rates over the last 10 years, there could be an additional 965 students by 2025. Unsurprisingly, our evidence also shows that in Oxford, university halls of residence are the preferred accommodation type (over 50%). With 25% of students living in private rented accommodation, private sector halls represent only a very small fraction of the share (3%). The Council’s recently adopted Local Plan (June 2020) recognises that the success of Oxford’s economy is shaped by the presence of its two universities. The Local Plan identifies that provision of good quality, well managed student accommodation will continue to be required in Oxford. However, this type of land use often competes with sites for general housing. The Local Plan therefore places restrictions on the locations suitable for student accommodation and limits its occupancy to students at one of the two universities on academic courses of over a year. OCC’s approach has been to include a threshold cap for both universities within the Local Plan. This restricts the number of students permitted to live outside the university provided accommodation. Furthermore, in the OCC area, the growth, redevelopment or refurbishment of education floorspace is linked to student accommodation provision (i.e. the provision of accommodation must be in step with the expansion of student places). The above, coupled with the requirement to provide an affordable housing contribution on student accommodation schemes (25 or more students/10 or more self-contained units), as well as payment of CIL (which is applicable to both education and student accommodation floorspace in the OCC area), presents a challenging situation for PBSA. However, the unique nature of OCC’s threshold strategy for the universities is long established. The Local Plan Inspector noted in its Examination Report (May 2020[2]) that “…..the threshold system has been tried and tested in Oxford in previous plans and is a workable means of balancing the housing needs of the very large student population against the city’s many other housing needs and land uses. It is also a system that, subject to the specific threshold numbers, has been developed by consensus.” Given the importance of the universities within the area, supply for student accommodation needs to be met to ensure growth of these important institutions can continue. The Local Plan’s aim is to balance support for the two universities while continuing the prioritisation of general housing. This difficult balancing act is applicable to local authorities across the UK. Clearly PBSA is one of many competing land uses that Local Authorities have to contend with when seeking to meet its housing requirements. The shortage of appropriate sites within the city is a factor in land supply for housing. For example, Oxford has a rich history with large swathes of the city core within or adjacent to Conservation Areas, many listed buildings and other heritage assets. This is common across several of the UK’s university towns and cities. By nature, student accommodation would ideally be located in areas accessible to the city centre as opposed to outer suburbs, which may be more suitable for general housing provision. If students living within private rented accommodation could be housed in PBSA, private housing could be released back into the general rental market. The National Planning Practice Guidance (NPPG[3]) confirms that all student accommodation can in principle count towards contributing to an authority’s housing land supply based on: the amount of accommodation that new student housing releases in the wider housing market (by allowing existing properties to return to general residential use); and / or the extent to which it allows general market housing to remain in such use, rather than being converted for use as student accommodation. PBSA development could go some way to assist with these challenges, allowing institutions to focus investment in teaching facilities and the “student experience” rather than provision of accommodation. New PBSA development presents a fresh opportunity in terms of the way it can be used, which will be increasingly important in an uncertain market (See Arwel Evans' blog). This flexibility could help with other competing land uses, not just for general housing sites. For example, PBSA space can be rented on a short-term basis to visitors outside of term time, helping to address a shortage of visitor accommodation. Bedspace can help navigate some of the current uncertainty in the market and provide a robust evidence led argument, helping to guide investment decisions to where PBSA is most needed. Please do not hesitate to get in touch to discuss further. [1] HESA Student Record 2018/19 (figures do not sum due to rounding)[2] https://www.oxford.gov.uk/downloads/file/7288/inspectors_report_-_oxford_local_plan_2036[3] https://www.gov.uk/guidance/housing-supply-and-delivery Paragraph: 034 Reference ID: 68-034-20190722

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