Planning matters

Local plan making seems to be in a perilous state. A slew of local plans have been withdrawn, ‘shelved’, stalled, or are not taking on the feedback of local plan inspectors in recent weeks and months. One can look at this trend as symptomatic of the political and resourcing difficulties faced by the planning system. However, these delays have a real social and economic impact.

In recent months, the following 11 authorities have either stalled, delayed, or withdrawn their local plans: 

The emerging  hiatus in local plan preparations has been well covered (for example Simon Ricketts, Zack Simons, and a Planning Resource article). Many of the delays – particularity in the South East of England – are linked to the vexed issue of housing needs. There is a current uncertainty over how the Government intends to address the question of how many homes and where they should be provided, with rumours of a new local housing need methodology (or indeed getting rid of it altogether) which may (or may not?) reduce figures in constrained authorities in the name of ‘levelling up’. This comes on top of the perennial difficulties of planning in areas of Green Belt, uncertainty over potential changes to the planning system associated with the planning ‘White Paper’, and local political pushback on development.

Under a plan-led system, the delivery pipeline of new housing is to a large extent reliant on housing allocations made in the new local plans. If local plans are delayed, then so too are homes (as equally are commercial developments and infrastructure). Delayed homes are homes not available for purchase, rent or available to meet local affordable housing waiting lists. Delayed housing schemes also won’t generate wider economic benefits arising from their construction, household spend, and council tax receipts.

 

To quantify the effect of these delays on housing supply and corresponding economic impacts, we have reviewed each of the 11 local planning authorities’ emerging local plans listed above (be that a Reg 18 or Reg 19 draft, or a recently withdrawn plan). For each plan we have calculated how much housing is (or was) proposed on new allocation sites and their expected contribution within each respective plan period. Of the 11 authorities, only eight had published a plan with specific allocations so our analysis is limited to these LPAs (and thus excludes St Albans, Sheffield, and Arun).

From our review, there are currently 69,161 homes held up in the system across these eight authorities; most of which are in Dacorum and the fewest in Castle Point. Assuming that each allocation would deliver policy compliant levels of affordable housing, this means there are at least 21,471 affordable homes held up[1]. This total figure does not include any windfall allowances as it is assumed such sites may well come forward irrespective of a new local plan.

An alternative way of looking at the impact is to compare the figures in the stalled Local Plans against recent rates of delivery, on the (optimistic) assumption these would continue absent an up-to-date plan. Each of the eight LPAs needs to try and prepare a plan that addresses a higher level of housing need than that for which they previously planned. Adopting this approach – comparing the ‘stalled plans’ against the rate of net additions over the past three years, the stalling of the plans means forgoing approximately c.40,000 homes.

 

Of course, it may be that recent rates of completions cannot be sustained without new allocations. This is because past delivery will include delivery from past allocations that the emerging stalled plans were intending to replace; therefore, the 40,000 figure represents an optimistic estimate.

 

We have applied Evaluate – Lichfields’ economic benefit assessment framework – to each of the LPAs providing us with estimates of the economic benefits of the 70,000 homes in the proposed housing allocations. It does not capture the additional economic benefits from associated community infrastructure (i.e. schools and health centres), commercial development (retail and business uses), and green infrastructure associated with these allocations. For each LPA, we have applied a localised housing mix (taken from the relevant authorities SHMA) and assuming policy-compliant levels of affordable housing will be delivered.

The results of the analysis are set out in the table below. The near 70,000 homes have an estimated combined construction value of £10.14billion (at 2022 prices, calculated on the costs of each region the LPA is in). This level of investment would support thousands of direct jobs and indirect supply chain jobs with an annual economic output of £1.9billion (GVA).

For local economies, there will also be a particular hit as expected housing delivery no longer comes forward. In total, residents of these new homes would support over 9,000 retail and service jobs just by their expenditure. Not all of this expenditure will be ‘new’ as some existing local residents will move into these new developments; however, it serves to show the amount of potential spend is being held up which will be generated once these homes are delivered. Finally, for Local Authorities they are missing out on a significant quantum of Council tax. At today’s rates, once all these homes are built the eight Council will be missing out on nearly £146m per annum. This could be spent on maintaining and improving services across each Council area.

 

 

Taken together, the above shows some of the real costs of local plan delay from an analysis of just eight LPAs. It is only ‘some’ because we have not accounted for the additional benefits of commercial and other developments (which of course secure jobs which many authorities chase). Moreover, we don’t account for the wider social impacts of housing forgone. Each allocation represents social infrastructure – be it schools, health centres, community space, green space, sports provision – all not delivered. The consequences of households not forming, or people living in inadequate living conditions is a further cost.

Whilst one can readily recognise the realpolitik drivers of stalled local plans – and accept that the current system has notable imperfections – it also the case that many of the areas affected are among those with the worst problems of housing affordability in the country and in locations where new housing could help support revival of local high streets. Delays thus carry economic and social negatives that are real; harming existing and future residents. The scale of impacts from just eight local plans also points to the need to arrest the contagion and get the planning system moving again; if the system as a whole grinds to a halt, the adverse consequences will be of national economic significance.

 

 

The Build to Rent sector is booming. But is the boom reflected in local plan policy across London?

Research by the British Property Federation earlier this year found that the Build to Rent (BtR) sector pipeline grew by 8% in 2021, and showed construction in regional cities in the UK outpacing London. There has been notable investment activity driving investment levels in BtR upwards in the last two years, with various acquisitions and deals listed in this article and many pension funds diversifying into the BtR market.

But where BtR will be focused is informed by planning policy; perhaps the most important public policy issue that impacts the location and implementation of BtR.

The birth of BtR within the UK can be traced to 2012 as part of the legacy of the Olympic Games in London with the conversion of the East Village into rental properties. As BtR has evolved, so too has national and strategic planning policy which seeks to control – and mostly support – this specific housing product. The National Planning Policy Framework (NPPF), associated Planning Practice Guidance (PPG) and the London Plan have all released BtR-specific commentary to clarify the nuances and requirements of what is still a relatively new sector with differing planning requirements.

The NPPF (2021) definition sets out that BtR is: “Purpose built housing that is typically 100% rented out. It can form part of a wider multi-tenure development comprising either flats or houses, but should be on the same site and/or contiguous with the main development. Schemes will usually offer longer tenancy agreements of three years or more, and will typically be professionally managed stock in single ownership and management control.”

Meanwhile, the London Plan (2021) qualifies the criteria BtR schemes in London must meet (Policy H11): all units being self-contained and let separately with longer tenancies available to all tenants; being held under a 15 year+ covenant with a clawback mechanism to ensure the covenant is not broken; having unified ownership and unified management with an on-site presence.

The Plan explicitly requests that boroughs “take a positive approach to the Build to Rent sector to enable it to better contribute to the delivery of new homes”.

But how is this strategic support reflected at the local level by London Boroughs?

We have undertaken research to understand how the 32 London boroughs are responding to the growth of the sector and the strategic obligation to support the asset class in their local planning policy.

 

As with many policies issues across London, the picture is mixed:

• There are six authorities with explicit policies that support BtR in adopted Local Plans, where developments adhere to other plan policies and controls.
  
  
• Six authorities have draft policies supportive of BtR.
  
  
• Six authorities reference support of BtR in their supporting text and five authorities reference general support of high quality PRS schemes though without explicit reference to BtR.
  
  
• Only LB Islington’s draft Local Plan policy is expressly against BtR development in the Borough, stating the ‘PRS development model does not have a tole in meeting identified housing need in Islington.’
  
  
• 11 authorities do not make reference to BtR in the Local Plans at all.

Our research shows that there are more boroughs with a supportive approach to BtR than not and, as a general rule, it appears the central boroughs are more supportive to BtR or have a policy position, generally aligned with the London Plan.

Moving forward, we expect the position shown in our map to change as Local Plans are reviewed and are required to demonstrate conformity with the London Plan. However, as planning policy often seeks to counter a sector’s proportionate growth in the property market (think London student housing), there may also be an increase in the number of authorities who seek to limit BtR as a response to the increase in the number of schemes.

What is clear is that BtR is a sector which will continue to mature and evolve over time. How planning policy responds and adapts to this will be key to the future direction of the sector.

The map below demonstrates an overview of our findings[1] - hover over each borough to find out more.

For further details of this borough-level research and our experience and intel in the BtR sector, please do get in touch.