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A new non-negotiable locally determined Infrastructure Levy (IL) system is to be rolled out gradually across England. And gradually means gradually; the Government anticipates it would take several years until IL is required across England. So, while IL would be emerging in some areas, the community infrastructure levy (CIL) would continue to apply in others and CIL would not disappear at all at strategic level (specifically the Mayoral CIL in London, at present) or in Wales. The intentions are that IL rates would be a percentage of the final ‘gross development value’ (GDV) of a scheme or phase of a scheme, above a minimum levy threshold. Often, this would be the scheme’s GDV when sold, but in many instances a valuation will be required. Therefore, when a scheme is commenced, the final amount payable would not be known. Unlike CIL, IL financial or in-kind contributions would include affordable housing. How IL is to be spent would be set out in an ‘infrastructure delivery strategy’, which would be examined. The proposals should be viewed as changes to the developer contributions system, rather than simply the introduction of a new levy that would replace all other types of contribution. This blog provides an overview of the Levelling Up and Regeneration Bill’s Infrastructure Levy provisions and focuses on those aspects of IL more closely linked to development management. It also references the intended contents of the IL Regulations and associated policy and guidance, as announced by the Government alongside the Bill.   How will the IL relate to other developer contributions? Land value capture plus: S106 agreements retained IL would (largely but not wholly) replace CIL and the financial contributions secured via s106, including all types of affordable housing contributions. Notwithstanding the introduction of a levy designed to encapsulate key contributions, there would be “a process to “require” developers to deliver some forms of infrastructure that are integral to the design and delivery of a site”. The examples of integral infrastructure given are flood risk mitigation and a play area; so, the inference is that this would not be occasional use of s106, but rather that on-site scheme specific mitigation might be sought by local planning authorities (LPAs) via s106 or condition with some regularity. Essentially, the Government would like contributions to make development acceptable that would otherwise be unacceptable and capture some of the consequential uplift in land value. Furthermore, a notable contribution will be ‘biodiversity net gain’ (BNG), most likely from the end of 2023, where not already secured by a planning condition. Therefore, in London, for most major projects, there would be planning contributions via s106 agreement, as well as Mayoral CIL and London Borough IL or Development Corporation IL, in addition to the planning condition requirements – some of which could be non-financial contributions. Elsewhere in England there would continue to be two types of contributions, until such time as other areas are permitted to charge strategic CIL.   Controlling whether mitigation by condition or legal agreement is a reason for approval The Explanatory notes to the Bill say that the legislation: “[…] will also allow the Secretary of State to regulate on how IL will relate to planning obligations, to secure funding from developers to deliver mitigations to the impact of development in the area where such development occurs. The Bill seeks to control the use of conditions, section 106 agreements and section 278 agreements to provide infrastructure directly and to control whether that provision could be considered a reason for granting planning permission. This is presumably to allow local planning authorities to push mitigation measures towards IL – albeit that funding secured by IL would not necessarily be ringfenced. Clause 204ZI’s wording is broad and how it translates into the IL Regulations will be interesting: (2) IL regulations may include provision about the exercise of any other power relating to planning or development [in addition to the CIL Regulations, and sections 70, 106 and 278 of the Town and Country Planning Act 1990] A balance would need to be found between these proposed provisions to control the scope of IL mitigation and the Government’s (stated yet unclear) desire to use s106 agreements less, while requiring s106 agreements and condition in certain circumstances. In addition to or alongside the new infrastructure delivery strategies, the IL Regulations could require authorities to write a list of infrastructure to be funded by IL. According to the Bill’s explanatory notes, items not included on that list would be: “infrastructure that developers should expect to fund and provide outside of IL”. This sounds like a return to the CIL Regulations 123 lists as the Bill also provides “for setting out the circumstances in which IL can be spent on projects which are not listed”. This would probably lead to further items being secured by s106 agreement or condition.   The charging schedule and calculation of the chargeable amount Setting the rates and thresholds The Bill provides the Framework for the new Levy; Regulations are to determine how, when and on what basis it would be charged. The viability of schemes would be at the heart of rate setting. Clause 204A (2) of the Planning Act 2008 says: “In making the regulations, the Secretary of State must aim to ensure that the overall purpose of IL is to ensure that costs incurred in supporting the development of an area and in achieving any purpose specified under section 204N(5) (non-infrastructure items) can be funded (wholly or partly) by owners or developers of land in a way that does not make development of the area economically unviable”. As now, the charging authority would be able to set the levy rate and there could be more than one rate across an area. The rate would be a percentage of a site’s GDV, rather than on floorspace as with the current CIL. The authority must take into account certain factors when setting IL rates. These include viability changes caused by the introduction of IL, IL revenues that would be generated, any infrastructure delivery strategy and other matters that affect land value, including planning permissions and policies. They would not need to consider the actual and expected costs of delivering infrastructure, as they would with CIL. Factors that could be taken into account when setting the rates and thresholds include consideration of administrative costs, actual and expected costs of non-infrastructure items that would mitigate development, and potential sources of funding for those items and evidence in statutory documents. According to the Government: “The effect of this, compared to CIL, is to shift the focus of rate setting towards the capture of land value uplift, with the two chief constraints being the extent to which land value has increased and the viability of development in the area”. The IL Regulations would provide that a charging schedule could also set out rate changes that would occur over time, following specified events taking place. In addition, IL Regulations would either permit or require the charging authority to set a threshold below which IL would not be charged - or it would be charged at a reduced rate. The threshold would probably be set in value per square metre and the Bill’s explanatory notes indicate that there may be different thresholds in one charging schedule. The Government suggests that, when setting a threshold, the charging authority takes into account items like build costs, other costs and the existing use value of the land. Thresholds might perhaps be able to factor in contaminated land, by raising thresholds where there is a given level of site contamination?    Examination of Charging schedules The processes for drafting, examining and bringing an IL charging schedule into effect are to be broadly similar to that of a CIL schedule. The Secretary of State can direct a review of the charging schedule and appoint someone to do it if the authority does not. The legislation would also allow the Secretary of State to require rates or thresholds to be changed with immediate effect (e.g. to respond to a dramatic change in the economy).   Factoring in affordable housing There is intended to be a mechanism for ensuring that affordable housing is not squeezed out by other forms of infrastructure. When setting rates and thresholds, the authority must consider the “desirability of ensuring” that developer funded affordable housing and affordable housing contributions are maintained at a level that is equal to or exceeds the level of such housing and funding that had been provided over an earlier period of the same length. This will be measured in accordance with the IL Regulations. The ‘Further information’ policy paper produced by the Government says: “It is intended that a substantial portion of the value captured through IL will be delivered via on site affordable housing”. Furthermore, the Government says that it will: “Introduce a new ‘right to require’ to remove the role of negotiation in determining levels of onsite affordable housing. This rebalances the inequality between developers and local authorities by allowing local authorities to determine the portion of the levy they receive in-kind as onsite affordable homes”. Hopefully this process will benefit from review and appeal procedures.   Calculation and exemptions IL is expected to be based on final GDV, although the percentage rate of IL would be fixed on the day planning permission is first permitted – which, as with CIL, is not necessarily the date the development is granted. Given that IL applies to final development value, any amount payable on completion of the development or phase is deliberately a variable too; the Government intends charging authorities to benefit from an uplift in the market during construction. Equally, the variable nature of the charge means that the IL liability would drop if the value of the scheme dropped, without a need to renegotiate contributions. This ought to be a big shift from CIL. However, as many LPAs reissue CIL liability notices as commencement notices are submitted, leading to a stressful eleventh-hour debate on the CIL liability, and therefore scheme viability, this might not be such a huge leap. Given the uncertainty surrounding final liability, the IL Regulations will require a charging authority to provide formal IL estimates. It would be very helpful if these estimates could be subject of review and appeal, because a developer might not commence a development if there was a significant difference of opinion on agreed inputs.   IL liability where developments do not create floorspace The intention that IL will be charged based on the final gross development value of development, rather than the floorspace of development when planning permission is granted, could mean developments not currently CIL liable would be IL liable. The Government has confirmed that changes of use would be subject to IL. Deductions arisings from the thresholds At present, CIL exemptions mean that certain developments do not pay CIL at all, but if a development does have to pay, it pays the full amount. But when calculating the chargeable amount of IL, the scheme’s GDV that is below the stipulated minimum threshold would be deducted, no matter how big the scheme or what is proposed. The Government anticipates that the threshold would be set out on a value per square metre basis. Right to require and the in-kind routeway As noted above, the collecting authority would have a ‘right to require’ on site affordable housing and there would be an ‘in-kind routeway’ that certain development (presumably of a given scale) would be able to use to provide infrastructure in-kind. This is to be set up via the broad powers in clause 204Z. Exemptions and relief Clause 204Z also allows the IL Regulations to include exemptions and relief. The Government has referred to exemptions for residential extensions and annexes. Charitable relief would continue to be available. Given the promotion of self-build schemes elsewhere in the Bill, it seems likely self-builders will continue to benefit from relief.   Payment The arrangements Provisions relating to payment are planned to be very similar to those in the CIL Regulations, allowing for instalments and various types of payment in-kind. Payment on account would be permissible too – and it is critical that the IL Regulations get the extent to which this can be used, correct: “Payment by instalment or on account would allow for earlier payments. This would be used to allow the charging authority to require payments prior to the completion/occupation of the phase/development. This would mean that payment could be enforced […] at a point when the developer was in control of the site, rather than at a point when it has been sold on, for instance to a homeowner. Early payment may also be used to support the early delivery of infrastructure. However, as this would also increase costs for developers, and may risk overpayments, restrictions may be placed on the use of such an approach.” This means it won’t be as simple as a final sales value to a homeowner or other purchaser being submitted; there might be a need for a valuation on almost all schemes. Penalties The maximum penalties for all types of breach could be increased significantly, apparently to compensate for the ‘amalgamating’ of s106 and CIL. The maximum surcharge or penalty would not be permitted to exceed the higher of 40% of the IL amount and £50,000. There is surely an argument for not applying penalties or reducing them during pilot phases or even for the first year that IL is charged. Who would the charging authorities be? Charging authorities for IL would be the LPA, Homes England (where it is the LPA) or Mayoral Development Corporations, as now. The proposed New Town Development Corporations are to be given Mayoral Development Corporation powers, so they would be able to charge IL too. (See Ed Clarke's blog on the regeneration elements of the Bill, including the proposed Urban Development Corporations.) Charging authorities for CIL would be the Mayor of London and Welsh LPAs. The Bill allows for the IL Regulations to change the charging authority to a county council, a district or a metropolitan district council, or a London borough council; the explanatory notes to the Bill suggest that this for reasons of scale and efficiency in certain circumstances.   Infrastructure delivery strategies Local authorities would be required to publish infrastructure delivery strategies for the high-level priorities for spending of the levy. The strategy would be subject to independent examination alongside a charging schedule or local plan, and should be kept up-to-date. Therefore, it could not be produced and published as quickly as the current Infrastructure Funding Statements, which serve a different function. The Government says: “IL must be spent to support the development of an area by funding the provision, improvement, replacement, operation or maintenance of infrastructure, or for any other purpose specified in regulations”. The Bill includes a non-exhaustive list of infrastructure types and, if enacted, would permit the IL Regulations to change the items on that list and to stipulate the minimum spend on certain types of infrastructure and when funds can be spent on non-infrastructure items. Neighbourhood plans would be able to set out any infrastructure and affordable housing requirements, in addition to those in local plans (see Tom Davies' blog on the plan-making elements of the Bill). Given that IL would seek to encompass most types of infrastructure (except expressly that which is integral to the design of the development – e.g. play areas), it is not surprising that consultation with infrastructure providers when preparing development plans and when setting the levy is encouraged. If providers were consulted, there would be a statutory requirement to reply. At present, long IL shopping lists can be presented to LPAs by infrastructure providers and others who consider certain facilities or contributions should be secured via s106 agreement in order for a development to be acceptable. In future, balancing such requests against ensuring that the rate is set at a level at which developments would be viable would be a challenge. There is a strong risk that anything that might be considered potentially integral to scheme design would be removed from the potential list of infrastructure items to receive funding and requested via s106 in due course, which would still be in accordance with the IL Regulations. A payment towards one playspace across several chargeable developments but one planning permission might still be considered “integral”. Some of the projects looking for funding ought to seek/be provided with funding from elsewhere. There is a recent history of NHS trusts seeking payments that had not been anticipated by the LPA. Several late requests for healthcare payments were the subject of an unsuccessful challenge to the grant of planning permission recently. Addressing the rationale or otherwise for such funding upfront is to be welcomed. Borrowing against IL As expected, there are also powers to permit IL to be used to repay borrowing against future IL receipts.   A learning curve based on experience? The intention of the gradual roll out of IL, according to the Bill’s explanatory notes, is “so that IL regulations can be informed by how IL works in practice”. It would appear to be a pilot rather than a gradual roll out, but the pilot would need to be based on regulations; it suggests that DLUHC is anticipating several amendments to the Regulations based on user experience. This could be viewed as concerning, particularly for developers operating in a pilot area. Furthermore, given that IL is based on development value, it would be once payments are due that the problems arise. If a planning permission lasts for at least three years and can be completed on an indefinite timescale once implemented (for the moment), it may take some time for perverse outcomes that require correction to come to light. Even on a swift build out on a smaller site, experiences would probably take at least a year to start to emerge, which explains the long lead in time anticipated for IL by the Government. More positively, a gradual roll out is, of course, indication that the Government wants IL to succeed, acknowledges the teething (and adolescent) problems of CIL, and will be ready to respond as issues arise. With this in mind, and in the knowledge that IL would take some time to come forward, here are our initial thoughts on some key CIL-related asks/questions of the IL Regulations:   There needs to be a clear understanding of when the calculation should be made and what constitutes a completed development – the interface with the developer completion notices also proposed in the Bill must be clear. The LPA might not want to say a scheme is complete because certain conditions have not been complied with – would that also be an easy way of arguing that IL is not yet due? IL should permit the introduction of sub-phases post commencement, to reflect changes to how a site is coming forward and to avoid confusion arising where a chargeable development is partially built, and its value not certain, but also partially occupied. Sites granted planning permission before IL is introduced, which are then subject to a fresh planning permission for a broadly similar development, should remain in-CIL (or out of CIL) while the first permission is still extant. The intention being to avoid complicated comparisons of viability between the pre-IL vs IL scheme when the focus should be on the differences in two schemes. Other amendment provisions should be taken into account when designing IL; section 73, section 73B and section 96A (not currently dealt with by CIL so some LPAs unreasonably refuse to entertain a section 96A application that would alter floorspace). IL Regulations must explain clearly who notices must be served on and all parties receiving notices must have formally agreed to receive such notices; e.g. they should not be sent to the agent without first confirming this is correct. Key inputs to Gross Development Value should be formally agreed prior to development commencing. This is so that the inputs change only to reflect changes to the market post-commencement and not due to differences in opinion between the collecting authority and the developer, for example on precise floorspace figures. This is particularly important in respect of the right to require affordable housing on site. However, where the site is sold post permission, there must be scope to revisit right to require and associated assumptions, particularly where the purchaser is a registered provider or built to rent provider.   Next Steps In an open briefing to the planning and development sector, on 12 May, the Chief Planner said that it is expected that the Bill will be enacted at the end of 2022 or the start of 2023. One would expect the IL Regulations and associated guidance to be drafted and consulted upon alongside that process and adapted as the Bill is amended. Perhaps pilot authorities could therefore be charging IL this time next year? DLUHC’s open approach to engagement and consultation is to be welcomed and it is essential that the sector responds proactively so that shared insight produces a workable Infrastructure Levy system.  


The Levelling Up the UK White Paper, published on 2 February, describes the practical steps the Government will take that “will make this a better, fairer country for us all", according to the Prime Minister's foreword. The White Paper is not a consultation exercise; it is a series of missions against which the Government is to be measured, albeit the Levelling Up Minister said, in a written answer, that the Government intends to “continue to engage with a wide range of stakeholders and partners".     Edward Clarke's blog considers what the Levelling Up White Paper's missions mean for the development industry.   In terms of future changes to the planning system specifically, there are several statements that show the elements of planning reform that are still favoured and provide hints on timescales for announcements, which we set out below.   Overview The Chief Planner identified what she considers to be the key planning changes highlighted in the White Paper, in her February 2022 Planning Newsletter: “The simplification of local plans ensuring they are transparent and easier to engage with The consideration of new models for a new infrastructure levy A number of policies and powers to enable planning to better support town centre regeneration Improving democracy and engagement in planning decisions Supporting environmental protection through planning” The Planning Newsletter said that there will be further updates on changes to the planning system “in the Spring", albeit a day earlier the Net Zero Minister’s response to a written answer asking when a Planning Bill would be published was much less specific, and reflected the White Paper: “The timing, scope and content of any legislation required to deliver these [planning system] changes is under consideration, and further detail will be shared in due course". The anticipated Levelling Up and Regeneration Bill, which will contain whatever changes to the planning system/reform that require primary legislation, is not mentioned in the White Paper. The planning-related missions Planning-related matters and proposals are presented under the overarching mission 3.4 “Restore a Sense of Community, Local Pride and Belonging”. And then under two White Paper missions shorthanded “Pride of place” (which includes heritage) and “housing” (missions 9 and 10 respectively). The technical annex to the White Paper explains that the metrics for measuring success against both are in their infancy. Regeneration is one of three strands of the pride of place mission, the other being communities, culture, heritage and sport. The regeneration policy programme is focused on transformational projects (e.g. projects identified for Wolverhampton and Sheffield), high street rejuvenation and green spaces. The housing mission includes sub-missions of home-ownership and housing quality and planning reform – albeit changes to the planning system fall under other missions too. High street rejuvenation – LA powers to fill units The High Street rejuvenation’s section celebrates recently introduced permitted development rights, business rates relief and the High Streets Task Force. The White Paper refers to the intentions to “incentivise landlords to fill vacant units by giving local authorities the power to require landlords to rent out vacant properties to prospective tenants. This will tackle both supply and demand side issues to avoid high levels of high street vacancies and blight, and in turn increase the attractiveness and vitality of our high streets”. During the Oral Statement introducing the White Paper, the Levelling Up Secretary (SoS) said that this proposal builds on work by Jonathan Gullis MP. Jonathan Gullis has campaigned in Parliament for buildings not to be allowed to fall into disrepair. He is the sponsor of the Planning (Proper Maintenance of Land) Bill Private Members' Bill. This may provide clarificatory context when considering how far reaching the powers of the LA might be and when they should be used. Having said that, measures could of course go much further and might apply to all properties in a given location, rather than to certain use classes, although a wide variety of potential tenants might be put forward by the LA for Class E properties, given its breadth. On a larger scale: “[…] the UK Government will work with local leaders, the private sector and a range of government agencies and departments to focus on where government investment can be maximised – for example, in health and education facilities and in roads and railways; and where there are deliverable development opportunities – for example, vacant shopping centres or industrial premises”. A key part of regeneration proposals is ‘refocusing’ Homes England so that it uses its statutory powers to partner with local leaders and to unlock barriers – which links to proposed changes to CPO powers. Green space and Green Belt Green Belt is to be enhanced and maintained - with “further greening the Green Belt in England". Other plans for “green" spaces generally include bringing wildlife back, aimed at increasing public access while simultaneously delivering nature recovery; and securing further environmental improvements. The greening of Green Belt may be linked to repeated criticism that the Green Belt isn’t green. Support is not given to the principle behind a Private Members' Green Belt Protection Bill, which is to require local planning authorities to allocate new Green Belt land of the same size when removing Green Belt land; such a decision is still considered a local matter. Communities – including CIL This sub-mission pulls together various proposals that are intended to have a more localised role in the future, whether this is put forward in the White Paper or elsewhere. In this section there are also references to a review of neighbourhood governance, pilots of new models for community partnership and testing the proposed Community Covenants, which lead to an identified role for planning within Mission 9: Planning: Councils and communities will create new local design codes to shape streets as residents wish; widen the accessibility of neighbourhood planning, encouraging more accessible hybrid models for planning committees in England; and look to pilot greater empowerment of communities to shape regeneration and development plans. The ability to have a meaningful say on individual planning applications will be retained and improved through new digital technologies. The 'encouragement' of hybrid models for planning committees - but not expressly committing to legislate for them - is noteworthy and comes ahead of publication of the call for evidence or response to it. Support for virtual committees had been expressed by the SoS but not confirmed by the Government. A proposed UK Strategy for Community Spaces and Relationships would link to planning policy (UK-wide) in due course. Notably this, the third of four guiding principles of the Strategy, would be: “listening to communities – engaging with communities, local government and civil society to identify priorities, the assets that matter to local places, and the policies and actions needed to strengthen community infrastructure”. Neighbourhood planning hasn’t been front and centre for some time. Its mention in the White Paper comes alongside funding for pilot schemes to fund neighbourhood planning in deprived and urban areas or areas piloting a simpler approach to neighbourhood planning. There has also been confirmation from the (then) Housing Minister that “we are committed to retaining neighbourhood planning as an important part of the planning system, and we will set out our proposed way forward shortly”. The White Paper confirms that there will be neighbourhood portion to the new Levy, reconfirming that a new Levy is on the way and suggesting that the legislation behind it is likely to be similar to the much-tweaked existing CIL Regulations. According to the White Paper, the ways in which CIL can be spent locally will be explored while a new Infrastructure Levy is developed.  The Government is to “explore how the existing Community Infrastructure Levy (CIL) can be used to support neighbourhood and community activity where Parish Councils do not exist across England”. In the planning reform section, it is made clear that the new Levy is intended to increase land value capture and that affordable housing is to be provided via the Levy: “The current planning system enables some developers to benefit disproportionately and unfairly from the land they develop. This is why the UK Government is developing models for a new infrastructure levy which will enable local authorities to capture value from development more efficiently, securing the affordable housing and infrastructure communities need”. Planning reform, home-ownership and housing quality The policy programme for home-ownership and housing quality form part of the housing mission: a. making home-ownership a reality; b. improving housing quality; and c. reforming the planning system. That planning reform sits under the White Paper mission devoted to home-ownership and housing standards, is interesting in itself, given continued criticism that planning equals housing in the Government’s eyes: The mission discusses the wider benefits of housebuilding, including removing constraints of productivity by allowing labour mobility, restoring a sense of community, having a stake in society through home-ownership. The rhetoric is therefore on a housing system that works for everyone, rather than a planning system – which is recognised as being an element of the housing system objective. There is a continued reference to housing availability and the demand for/push towards home-ownership, hence a reference to First Homes. An important housing quality announcement is that there will be a Government appointed task force “launched shortly to look at ways better choice, quality and security of housing for older people can be provided, including how to address regional disparities in supply of appropriate and where necessary specialised housing". There is an acknowledgement that falling access to home-ownership and social housing has resulted in a doubling in the size of the Private Rented Sector over the past two decades and that many are in temporary accommodation. In February, Tom Walker, one of the authors of the White Paper told Local Government Chronicle (£) that there will be a Private Rented Sector White Paper in June, which may be relevant to planning, given this mission. There are references to planning and CPO powers beyond housing, and while the section quoted below is a bit of a round-up of planning related proposals not covered elsewhere in the White Paper, the intention to set a more positive approach to employment land in national policy is encouraging. “The UK Government will enhance compulsory purchase powers to support town centre regeneration; provide further support for re-using brownfield land for development; set a more positive approach to employment land in national policy to support the provision of jobs; and increase engagement with infrastructure providers in plan making to bolster productivity. Building on progress to date, wider changes to the planning system will secure enhanced social and economic outcomes by fostering beautiful places that people can be proud of; improving democracy and engagement in planning decisions; supporting environmental protection, including support for the transition to Net Zero; and securing clear benefits for neighbourhoods and local people”. Housing requirements and delivery - the south east vs everywhere else? While the Government is insistent that the south east will not be levelled down, there are references to diverting funds away from the south east and measuring successful delivery of missions by measuring against the south east. The White Paper says “UK Government investment in housing has been concentrated in areas where the private sector has already been investing most heavily, disadvantaging the North and Midlands”. With regard to making home-ownership a reality, funds already announced are to predominantly deliver housing outside of London/South East, where housing pressure is among the greatest. The majority of homes to be delivered via the £1.8bn brownfield land fund will be targeted on brownfield sites outside London and the South East. The £11.5bn Affordable Homes Programme will deliver up to 180,000 affordable homes, with 75% of these delivered outside London. While this says where investment is going, the intention that there will be a related outcome beyond funding allocations is there too. With reference to the Building Better, Building Beautiful Commission’s recommendations and communities to be developed in the future: “These attractive new communities, made possible by the UK Government’s investment, and the rebalancing of housing and transport investment, will reduce pressure on housing and on greenfield and Green Belt sites in overheated areas of London and the South East.” Many in the development sector have raised concerns that levelling up will mean a levelling down of areas with significant housing pressure. The Government has repeatedly sought to emphasise that this is not the case. And in November the SoS said in response to Theresa Villiers' request to “halt urbanisation and save the suburbs" that the way housing need is assessed needs to be updated and “every part of England—indeed, every part of the United Kingdom—will have to share in making sure that we can meet the housing needs of the next generation, but we are seeking to achieve a fairer and more equitable distribution of need across the country. In a January debate housing on housing and North Kent, the (then) Housing Minister reminded the House “housing need numbers, as calculated, are a starting point, not an end point" and, as such, housing numbers are decided locally. He indicated that the current standard method was devised to reflect the circumstances of the time: “We took a view a couple of years ago that, particularly given the pandemic, local authorities needed consistency and certainty, so we chose not to change the local housing need calculations for all but the 20 largest cities in our country". A further revised standard method formula continues to be anticipated by developers and local planning authorities. In the same debate, the Housing Minister indicated that the Government would still look at concerns around land banking, notwithstanding the outcome of the Letwin Review: Sir Oliver Letwin found a couple of years ago that land banking, as it is popularly described, is not a particularly prevalent issue. However, I recognise the concern of local communities and our colleagues about this particular challenge. That is why we have committed, as part of our future planning reforms, to look carefully at how we can, shall we say, incentivise developers to build out on the applications that already exist, rather than looking for more and more applications to be given on other sites. And in a later written answer said “where delays in starting or progressing sites may be avoidable and the Government wants to empower authorities with the tools to respond to such cases”. November 2021 Lichfields research for the Land Promoters and Developers Federation and the Home Builders Federation explored the extent to which the house building sector must scale-up their delivery to achieve the national 300,000 homes per annum ambition. It found the equivalent of English LPAs granting permission for an extra 4 to 5 medium sized sites per year, or alternatively 4 to 5 large sites which deliver each year over a longer period, would be necessary - in addition to LPAs continuing to approve its usual ambient level of permissions being granted. A Lichfields research piece for Barratt has found “existing housing mix policies will be based on evidence that pre-dates the pandemic and thus is unlikely to reflect the changing way in which people will now occupy their homes. This shift makes it more likely that the LPA’s review should conclude that the local plan must be updated to revise policies on housing mix, including to support provision of homes that are suited to working from home".