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Source: ONS, Lichfields analysis Note: Copeland, Richmondshire and Blackpool removed
Indeed, areas with the most extreme affordability ratios, i.e. those local authorities where average house prices were more than 10 times local earnings, highlighted in the figure above, have among the biggest reductions in household growth compared with previous projections; alongside areas with the lowest affordability ratios, suggesting much less demand. And in some locations - many highly unaffordable - the new projections create seemingly perverse results; for example negative levels of household growth in Cambridge, and de minimis growth in Oxford[1]. If the result of the new projections was to reduce the amount of housing planned for in those areas, that would clearly be counterproductive to the public policy goal of increasing housing supply in the least affordable areas, and would make the 40% cap on the level of uplift similarly difficult to rationalise.
For areas not experiencing extreme affordability pressure, but which may have a need for housing for other reasons, such as employment, there is nothing in the standard method formula to account for this. However, the NPPF 2018 sets out clearly in Paragraph 81 the need for planning policies to “set out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth…[and] seek to address potential barriers to investment, such as inadequate … housing”.
Furthermore, recently updated Planning Practice Guidance (PPG) on Housing need assessment makes explicit that “The Government is committed to ensuring more homes are built and are supportive of ambitious authorities who want to plan for growth.” It goes on to establish that the standard method is only a minimum starting point, and circumstances may arise where actual housing need may be higher than the standard method figure. The PPG provides specific examples including where growth strategies and Housing Deals are in place, where need may be higher, as well as a range of back stops, including past delivery levels and recent SHMAs, which should prevent new, lower household projections unduly influencing housing targets in forthcoming local plans downwards.
This guidance perhaps lacks the ‘bite’ that some in the sector have been seeking to militate against what some local authorities have been doing: using the standard need method to reduce their estimates of housing need (examples include Richmondshire[2], Wirral[3] and Great Yarmouth[4]). However, local and strategic plans will be examined on this basis from January 2019, and they could face difficult examinations if their plans have a clear disconnect between ‘do minimum’ housing plans and ambitious employment growth visions.
More generally, we know the Government will be consulting on revisions to the standard method to recalibrate its approach to get back towards the 300,000 homes per annum figure. The question remains as to how they propose to do this. It will be important they get it right – it will be local plans produced over the next 2-3 years that will allocate the sites that will be delivering homes in the mid-2020s and thus be critical in meeting the Government’s aspirations.
[1] https://lichfields.uk/media/4495/lichfields_the_2016_based_household_projections.pdf[2] https://www.planningresource.co.uk/article/1492059/yorkshire-council-moots-slashing-annual-homes-target-180-15-wake-standard-method[3] https://www.planningresource.co.uk/article/1493928/threatened-wirral-council-rows-back-green-belt-releases-wake-new-household-projections[4]https://www.planningresource.co.uk/article/1491854/norfolk-council-proposes-2000-home-housing-target-cut-wake-new-standard-method
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