Planning matters

With less than a week until polling day, Lichfields’ manifesto coverage turns to town centres. Given the ground needed to be covered in Electoral Manifestos, and the common across-party focus on the delivery of new homes, pledges for the high street do not feature significantly. However, town centres continue to face significant structural and economic challenges, with change coming quicker than any taxation or policy developments designed to support them. Insofar as there are measures proposed to protect town centres, we have delved into these below.

The most significant ‘call to arms’ of the major parties is for business rates reform. Pushed for by the industry for many years, the Conservatives have pledged to enable local authorities to retain business rates locally, whilst Labour have called for a full review and reform of the business rates system in a way which is revenue neutral but implemented in a fairer way. The Liberal Democrats have proposed to go even further by replacing business rates with a Commercial Landowner Levy. However, whilst full of good intentions, these pledges are so far light on detail. We know, more widely, that there is clearly currently limited scope to reduce tax receipts overall if government spending is to be maintained.

The Labour Party have stated that they want business rates reform to ‘level the playing field’ between bricks and mortar shops and online shops. As shown in Figure 1, whilst the rate of growth in online spending has slowed since the pandemic – and it should be acknowledged that a proportion of this spending is taking place through physical retail outlets, it is still significantly higher than, for example, at the 2017 or 2019 elections.

Business rates have compounded the challenge presented by online retailers for town centre stores. Research undertaken in 2022 by real estate advisory firm Altus Group suggested an eight-fold difference in business rate costs between high street and online shops. It is therefore vital that the manifesto pledges on business rates are followed through in a proportionate and supportive manner.

Labour are also proposing to bring in measures such as a “right to buy” community assets on empty high street premises. Their manifesto also acknowledges the benefits to town centres of addressing ‘side issues’ such as tackling anti-social behaviour and shop lifting, as well as supporting a roll out of banking hubs and working with post offices to offer local services. Whilst unlikely to deliver significant investment in themselves, these proposed measures should be welcomed, as key to maintaining town centres’ attractiveness and relevance.

Alongside their pledge to reform business rates to support small businesses and the high street, the Conservatives also pledge to increase the number of places covered by their “long term plan for towns” to over 100, which would all receive £20m of levelling up funding, although it is unclear how much of this funding would be focused upon the high street.

Alongside talk of the election manifestos, it is worth mentioning that the High Street Improvement Plans Bill, which benefits from cross party support, had made quick and positive progress through both Houses before parliament was dissolved. Before the dissolution, the Bill was facing a third reading in the Lords, before being returned to the Commons for any amendments and, finally, Royal Assent. Subject to support from the new Government, this could be taken forward after the Kings Speech, if it passes within a year of the First Reading (i.e. before 6 December 2024).

As covered by in our previous blog, if successful, the Bill would require each Local Planning Authority (LPA) to designate at least one ‘High Street’, with an ‘Improvement Plan’ to be prepared for each one. LPAs would need to consider the High Street Improvement Plan when exercising its planning functions and carry out periodic reviews of the condition of those high streets.

The Labour Party have talked a strong game on the planning reforms they intend to deliver in their first 100 days in charge, should they form the new Government. Whilst much of this will focus on housebuilding and cutting ‘red tape’, as economic and social hubs, it is important that the high street remain central to planning policy. Town centres need to adapt to survive and thrive, be it through re-purposing buildings for new uses or through evolving their offer. This requires political will to drive policy change and, where applicable, new/additional funding.

As suggested in our previous blog, one intervention that could be enacted quickly by the new Government (whichever colour they may be) would be to require the use of Area Action Plans (AAPs) to provide a more tailored approach to planning policy in town centres. Such document would form part of the adopted development plan, bringing weight and certainty, both of which are key for investment decisions. They could also bring together all key stakeholders in a town centre to form an ambitious but deliverable plan for their area.

The political recognition of high streets and town centres in both the manifestos and the passage of the above bill is welcome. However, the lack of detail on these measures reflects the focus on the more eye-catching issues of housing delivery and reform of the planning system more generally. For retailers and other stakeholders, some of the reforms proposed, alongside the potential enactment of the High Street Improvement Plans Bill could offer much-needed support, helping to revitalise town centres and local economies. It is essential that policy makers do not forget the high street and grasp the mettle post-election.

It’s certainly not news that as our population ages, the importance of providing suitable housing for older people becomes increasingly crucial, and with over 65s making up 80% of all household growth[1] it is vital they are given proper consideration when planning for housing and other needs. Five years ago our original research looked at how the planning system was addressing the needs of older people, finding that the vast majority of local plans did not clearly engage with older people’s housing needs. It made a series of recommendations about how this could be improved.

Our updated research provides a refreshed and more in-depth look at how local plans, both adopted and emerging, address the housing needs of older people, to see what has changed. In short, things are moving in the right direction, but there is still a significant way to go.

This time, we looked at three key parts of the plan-making process:

• Evidence base – our research looked at whether the evidence base for housing included a reference to the needs of older people, and if so whether this referred to care homes;
   
• Local Plans – our research looked at whether the local plan quantifies the need for older people’s housing, either within a policy or in supporting text, so that the overall scale of need is clearly identified. It also looked at whether the plan’s general policy on housing mix refers to the needs of older people and whether the plan contains a standalone policy addressing the needs of older people (and if it did, whether this includes reference to care homes and whether it requires there to be evidence of need). Recognising the role that accessible housing more generally can play, our research also looked at whether the plan includes a policy requirement for wheelchair accessible housing. In terms of affordable housing, we also looked at whether plans were clear on whether affordable housing contributions for elderly housing are required. Finally, we considered site allocations; firstly, if the plan contains strategic allocations, whether these refer to the needs of older people, and secondly whether the plan contains standalone allocations for housing for older people; and
   
• Monitoring – our research looked at whether the local authority monitored delivery of housing for older people (for example, in the Annual Monitoring Report) and if so, did this include care homes.

For these, we compared plans adopted pre-2012 NPPF, plans prepared under the 2012 NPPF, plans prepared under the 2018 NPPF and emerging [submitted] plans (all of which are being prepared under the 2018 NPPF[2]), shown in Figure 1 below.

By all measures, plans are moving in the right direction, with:

• More authorities assessing needs within their evidence base;
   
• More plans quantifying need, including standalone policies for older people’s housing, and requiring wheelchair housing; and,
   
• More reference to older people’s housing in both strategic and standalone allocations.

However, significant progress still needs to be made in order for the planning system nationally to begin delivering the scale of older person’s housing that is likely to be needed, with the evidence base still not fully translating into a suite of policies which would support significant scale specialist housing delivery.

With only 20% of emerging plans making allocations for housing for older people (up from 8% prior to 2012), it could take decades for all (or even the majority of) plans to make allocations for housing for older people. Current guidance sends a somewhat mixed message, stating that it is “up to the plan-making authority” to make allocations but also that allocating sites “may be appropriate where there is an identified unmet need for specialist housing” – which is the case for virtually all authorities, as shown in their evidence base. A significant change in guidance could be necessary to place much greater urgency on the need for allocations and rapidly increase the number of plans making allocations.

Our findings and key recommendations across each of the areas of plan-making are shown in Figure 2.

Understanding how older people’s needs are being addressed in plan-making is key to assessing the effectiveness of national policy and guidance, and helping identify areas for future change and improvement. In short, whilst we have found that older people’s housing need almost always now features in the evidence base in plan-making (albeit in varying levels of detail), the way this is fed through into policies in the plan varies considerably, with significant scope for improvement still remaining.

So, are things likely to continue improving in the future? Whilst the 2023 NPPF includes additional references to the types of housing older people may require (retirement housing, housing with care and care homes), the overall thrust of paragraph 63 – to “assess and reflect needs within planning policies” – remains the same as it was in the 2018 NPPF. Although emerging plans that we assessed (prepared under the 2018 NPPF) suggest trends are slowly moving in the right direction, without any change to underlying policy and guidance it is still uncertain  whether the 2023 revisions to the NPPF will result in any material shift in how plans address older people’s needs.

The challenge of providing adequate housing for an ageing population is significant but not insurmountable, and the insights and recommendations from our research could lead to substantial improvements in housing provision for our ageing population. By strengthening the evidence base, providing greater clarity and direction within local plan policies, and ensuring effective monitoring, local authorities can better meet the needs of older people, but this must also be met with engagement from other stakeholders. An imminent potential change in government – and potential change in NPPF – could represent an opportunity to bolster older people’s housing needs and make an important contribution to the aim of significantly boosting housing supply in the next five years.