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Standard Method Mortuus Est

Standard Method Mortuus Est

Matthew Spry 12 Oct 2022
Standard Method RIP. The writing was on the wall during the summer Conservative leadership campaign when both Liz Truss[1] and Rishi Sunak[2] argued against the idea of “top down”, “Whitehall-inspired” and, famously, “Stalinist” housing targets. Change was seemingly affirmed on 8th September when Simon Clarke, the new Secretary of State said[3]: “We need to move away from the culture of top-down housing targets which have done so much to poison the relationship between individual communities and government on the question of how we build the houses that we need.” In truth, the Standard Method has been in purgatory for months; a host of local planning authorities had cited its expected demise in deciding to abandon plan making[4] contributing to a situation where 59% of the country does not have an up-to-date local plan, and with no sense that Government would intervene to deliver on its December 2023 deadline. This has had significant adverse economic costs (our analysis of eight abandoned local plans found that 69K homes would be lost, costing the economy £1.9billion of economic output (GVA) annually. Housing delivery is now heading in the wrong direction[5]:  Starts on site (April to June 2022) down 15% on the same period last year  Net additional dwellings in 2020-21 down 11% on 2019-20  280,000 homes granted permission in the year to June 2022, down 16% from the 334,000 in the same period last year. Capital Economics is now forecasting a further fall in starts of 38% to just 110,000 in 2023 and 2024, before a small recovery to 130,000 in 2025[6]. This would be a function of the current economic-crisis (on sites already with permission that stall or build out more slowly), but the reduced bank of permissions, particularly in the stronger markets[7], means this market cycle fall starts from a lower base. In the context of current economic headwinds, the Guardian[8] was briefed on the contents of a new planning policy “reset”: "Government sources also said the target of building 300,000 new homes a year by the mid-2020s had quietly been abandoned. They said it was unlikely to be officially abolished, as it had been a 2019 manifesto pledge, even though Truss hit out over the summer at “Soviet-style targets”. But blue wall Tory MPs in the south-east of England are pressing for a firm commitment that the nationally imposed housing target will be dropped, and are wary of further planning reforms that would lead to a significant increase in development. They are seeking to ensure local authorities maintain a “master veto” over developments before pledging their support to Clarke’s plan. This would keep any drastic new developments to areas that want them – but potentially limit the plans to turbocharge housing numbers." Despite this, the Times reports that the 'reset' is not intended to reduce new supply[9] but "to boost house-building and drive economic growth." But how? In this blog I look at what the removal of the Standard Method might mean for housing delivery, consider the role of housing targets in plan making, and provide a few concluding thoughts on factors that might be considered in shaping the detail of a new policy.   What will removal of the Standard Method mean for housing delivery? The answer – obviously - depends on what, if anything, replaces it. And here there is no real clarity.  In her interview in the Telegraph[10], the now Prime Minister was reported as saying: “I want to abolish the top-down Whitehall-inspired Stalinist housing targets; I think that’s the wrong way to generate economic growth… The best way to generate economic growth is bottom up by creating those incentives for investment through the tax system, simplifying regulations.” Ms Truss wants to amend Mr Johnson’s Levelling Up Bill to legislate for new low-tax “investment and building zones”. The centralised targets are a “Labour approach”, she says. “It’s not Conservative.” The views of her Secretary of State were reported[11] as: “he wanted ‘to build more houses’, but do so ‘in the right way’, by ‘accelerating development of brownfield sites’ and ‘building beautifully’. He said: ‘We want to grow organic communities, not impose cardboard boxes across our shires. As with investment zones, local consent will sit at the heart of our plans.’ In comments made to the Times at the weekend, Clarke implied that greater incentives for local communities to accept development were likely to replace the compulsion for housing contained in the “top down” housing numbers. He told the Times that he wanted to “create incentives for residents to support development”. He said: “What I would like is to have a system … whereby if you’re a resident of X community there is something in it for you about a new settlement in your area.” However, the specific incentives and simplified regulations are awaited and – due to difficulties with “the detail” - proposals have been pushed back to November[12]. In an indicator of possible thinking, the Government’s approach to fracking is reported to involve offering households “up to £1,000 to approve provisional fracking in their area. The proposal being floated is for companies ... to go door-to-door to convince residents to green-light the move. Cash incentives could be offered, with exploratory drilling allowed to go ahead if more than 50 per cent of households in the local vicinity give their approval.”[13]. This gives new meaning to the old expression of ‘buying a permission’, and – were a similar approach to apply to housing schemes (of which, unlike with fracking, there are literally thousands every year) raises practical questions as to how this process would relate to the local plan making and development management process[14]. Similar questions arose with the concept of Land Auctions[15]. The Secretary of State is reportedly suggesting further permitted development (PD) changes[16] and a relaxation of Green Belt rules for brownfield development[17]. The evidence for what this will yield is not yet apparent, but our analysis in May 2014 suggested brownfield sites in the Green Belt had a capacity of just 23,000 homes. On all brownfield land, the maximum capacity of land on brownfield registers amounts to less than 93,000 homes a year even were every site viable, not all of it will deliver the homes with gardens that many families want, and it is not concentrated in areas where affordability pressures are greatest. The last attempt at a brownfield-led planning policy resulted in annual net housing additions falling to 132,000. Stepping back from the current policy maelstrom, the past 30 years tells us something about what life without the Standard Method could look like: Between 1991 – 2005 (pre-Barker[18]), policy twisted and turned, but an overarching characteristic was that, although housing need and targets were relevant to plan making, they were ‘soft’: not defined by the crisis of affordability, mostly based on unvarnished household projections, shaped by the 60% target for use of brownfield land, and with less focus on deliverability. Housing output suffered accordingly. Annual stock growth was around 0.75%. In the period 1997 – 2003 when ‘brownfield first’ was at its zenith, it was lower still. Across the whole period, supply was on average 150,000 - 160,000 homes per annum, undershooting the official projections of household growth in that period.  After 2005 (post Barker), the focus turned to how supply could address affordability and whilst the targets were hotly debated, there was – particularly with the NPPF - increased emphasis on meeting need, on Green Belt reviews in strategic and local plans, and on a deliverable supply of land. The annual stock growth in that 15-year period was around 0.85%. Strip out the five years of the financial crisis and the annual output was 0.9%. In the ‘peak’ years of the 2012 NPPF (with the ‘tilted balance’ given force and advent of expanded PD rights) and it was just shy of 1%, securing 230,000 - 240,000 per annum.  This tells us that output is driven not just by housing need and targets, but by how these sit as part of a wider policy environment, including on plan making and delivery (and of course, economic cycle). If the replacement for the Standard Method is a vacuum or some kind of ‘soft’ target, it will – despite all the talk of incentives and de-regulation – likely lead to a much-reduced level of housing provision. Why? The current (2018-based) household projections envisage formation of just 164,000 new households each year (baking in trends of household suppression and assumed lower migration). In plan making, ONS local projections would likely be an influence for most LPAs. Whilst some might seek to exceed their figure[19], absent clear guidance on addressing market signals, affordable housing need or economic growth, most would see it as a maximum to then be moderated by perceived or actual constraints. If there was not an adequate mechanism for Green Belt review or addressing unmet need in our under-bounded, constrained big cities (Birmingham, London, urban South Hampshire, Leicester, etc) then output would be suppressed. If the ‘tilted balance’ policy was not applied with force to areas with out of date local plans, we can reasonably expect the national total would fall well below 160K, perhaps down to 140K.  Quite simply, one could easily predict no real bounce back from Capital Economics’ predicted economic downturn. Any boost from de-regulation or permitted development in a world without clear targets might simply see LPAs reduce the scale of their planned allocations as they would say they were no longer 'needed'. At the most optimistic, one might see output in a 'no-target' world go as high as, say, 185K if there was a major funding and delivery effort to support brownfield regeneration akin to the early 2000s (and a strong market for the particular form of housing it provides), a permissive approach to other forms of housing development that was treated as windfalls and not to be offset against other planned provision, and a strong commitment to plan making.  Reflecting on this uncertain picture, it is worth turning to why housing targets have a role in plan making more generally.   The role of housing targets Most planning systems involve some quantification of how much development is needed or desired in an area. This is because it helps the decision maker with judgements over how the impacts and benefits of development are balanced, how large developments should be, how many should be provided and where, what infrastructure is needed to support them, and if they warrant public sector investment. Without an assessment of need and obligation to set targets, experience tells us that many Local Planning Authorities who are, at best, ambivalent about housing delivery, will simply stop new homes being provided. A good example of why ‘need’ is relevant comes, ironically, from the Government's Investment Zone Expression of Interest process[20]. In question 2.5 on residential sites, bidders are asked to “set out here the estimated impact of the site over 10 years. What evidence is there that the site will drive additional or accelerated housing supply?”. Among the metrics requested is “the level of unmet housing need currently in your MCA/UTLA/Freeport”. Right now, the level of unmet need will be based on, you guessed it, the Standard Method. A recent attempt to construct an intellectually coherent alternative to the use of housing targets – but not at the expense of addressing the housing crisis - is the prospectus advocated by the Policy Exchange in its 2020 paper – Rethinking the Planning System for the 21st Century[21] which advocated: “Calculations of economic and housing ‘need’ should no longer be used (or required) to allocate land uses in a local area. The supply of new homes, offices and other types of use should no longer be capped by local planning authorities in local plans or by site allocations. Zonal designations should be separate from any concept of ‘need’. Instead, they should be dependent on metrics that determine whether land has good access potential, whether new development would cause environmental disturbance and the potential for an existing built development to expand.” In essence, under this approach, rationing of land would not be based on releasing only that deemed necessary to meet a quantified level of need, but simply on whether the land was, per se, deemed suitable for development. The implications of this are readily apparent when one looks at a typical strategic housing land availability assessment (SHLAA) and sees how the housing capacity of sites considered “suitable” is typically greater than what is required to meet an area's assessed need over a 15-year period. Whilst the Policy Exchange approach seems politically unlikely, it is possible that those who sought abolition of the Standard Method to cut housing supply may in time reflect that they should be careful what they wish for[22]. Where do we go from here? If a need and target-based approach is to remain in some form (and it is an 'if'), what factors need to be considered in arriving at a new policy approach? How should need be derived? At what spatial level should judgements be made over how it is met? And how far should national policy expect need to be met through plan making and decision taking? Some preliminary thoughts to conclude:  History tells us that Government has always faced political difficulties when it was seen to ‘own’ specific 'top down' housing target figures[23].  The political reality (at least for now) might be some reversion to a method where plan makers generate their own estimate of need, based on evidence, with clear parameters for the relevant factors to take into account, the agreed data sources, and a much-streamlined approach aligned to the digitalisation of the planning system. An estimate of need looking beyond official household projections (as currently formulated) is an imperative if the housing crisis is to be overcome and the approach needs to be stable and predictable.   A new approach to housing need must be accompanied by a reinvigoration of the evidential justification for housing supply as part of the solution to the housing crisis. Whether we need a headline national target is moot, but the role – identified by Barker and the NHPAU - of supply in addressing affordability, especially in the least affordable areas, would benefit from a refresh. This also can remind us that most comparable European countries - large and small, crowded or sparsely populated - regularly build many more homes per capita each year and are mostly the better for it.   The NPPF 2012 was based on meeting locally-derived Objectively Assessed Need (OAN). Its political genius – initially - was that Government was not directly implicated in either need or local targets, whilst setting a real expectation that whatever figure arose should be met through plan making and the requirement for a five year housing land supply. To some extent, it worked. However, it suffered from the length of time it took for local plan-making (often held back by hotly contested calculations of OAN), and there was local push back to on how speculative housing applications filled the vacuum where plans were supposed to be[24].  Areas will likely need to retain – as now – the ability to determine how much of their need they can accommodate based on the relevant factors in their area (under the 'tilted balance' or similar), but this ought to be governed by a clear expectation that needs are met across housing market areas with an effective governance mechanism for achieving that.  The concept of need and targets is only as good as the ability of the system to generate positive plan making; this means plans formulated at the right spatial scale to address strategic planning issues (duty to cooperate issues, constrained urban areas and the like), a streamlining of the plan-making system and its outputs to increase productivity (as suggested by the LURB), digitalisation of the process, better resourcing, and the right mix of carrots and stick for plan making bodies, including a political drive.  Targets must be accompanied by an effective approach to deliverability, so strategies are achieved by a realistic supply of sites, be that through five year housing land supply and/or the proper scrutiny of housing trajectories in local plan making.  It is a false dichotomy to assume that planning focused on boosting supply must be at the expense of wider policy objectives around quality, design, place making, infrastructure delivery and securing net zero carbon, all of which can be part of the framework. As we reflect on the short life of the Standard Method, proper attention must now turn to what should replace it. With political will, we have the planning tools available to deliver a more effective approach to planning for the homes we need, but prolonged uncertainty or a target vacuum will make it much more difficult for supply to bounce back from the inevitable downturn.        [1] Widely reported, but as set out in Housing Digital– see here[2] In the pages of the Daily Telegraph - see here (£)[3] In an interview on LBC – see here[4] The tale of woe is well summarised by Zack Simons here and Simon Ricketts here [5] As shown in the DLUHC September 2022 publication Housing supply: indicators of new supply, England: April to June 2022[6] As reported in Building – see here[7] See Figure 4 on Page 14 of Taking Stock: The geography of housing need, permissions and completions[8] From the Guardian – see here[9] From the Times - See here (£)[10] From the Telegraph – see here (£)[11] In BD Online – see here[12] As reported by the Times – see here[13] In the Telegraph – see here[14] See, for example, how it would square with the provisions set out in the PPG ID: 21b-011-20140612 which says that: “Whether or not a ‘local finance consideration’ is material to a particular decision will depend on whether it could help to make the development acceptable in planning terms. It would not be appropriate to make a decision based on the potential for the development to raise money for a local authority or other government body.”[15] See Planning Resource article here[16] Government figures suggest PD rights delivered just under 14,500 homes in 2020-21, down from 19,500 in 2018-19 – see here[17] Presumably relaxing NPPF para 159 (g) in which, in order to be “appropriate” in the Green Belt, limited infilling or the partial or complete redevelopment of previously developed land must “not have a greater impact on the openness of the Green Belt than the existing development” or “not cause substantial harm to the openness of the Green Belt, where the development would re-use previously developed land and contribute to meeting an identified affordable housing need within the area of the local planning authority.”[18] Kate Barker Review of Housing Supply (2004)[19] In 2017, our five year review of plan making found that local authorities with adopted plans (excluding Birmingham and London) exceeded the then household projections for their area by 22%.[20] The Investment Zone Expression of Interest is here[21] Policy Exchange – Rethinking the Planning System for the 21st Century[22] Especially with Mr Airey (the author of the document) recently appointed as special advisor at DLUHC – see here[23] See, for example, the push back to the NHPAU Supply Ranges of the late 2000s, the hostility to setting of housing targets through RSS/RS, the debacle over the mutant algorithm, the prior difficulties the Government had updating the Standard Method with new household projections, and the rejection of the 2020 White Paper’s suggestion of top down ‘binding’ targets[24] The problem was diagnosed by the Local Plans Expert Group  

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A brownfield-based planning policy? The lessons of PPG3
The Prime Minister’s Conservative Party conference speech confirmed speculation that a change in direction is afoot on planning reform[1]. Diminished is the thinking that led to the White Paper and the ‘mutant algorithm’. Ascendant is ‘levelling up’ and directing development to brownfield sites[2]. The Daily Telegraph headlined its report of the speech with “PM pledges no homes on green fields”[3] However literally we should interpret the PM’s rhetoric[4], the tilt towards brownfield and away from greenfield is worthy of exploration. It may be a response to the politics of the past twelve months, but it is not a new policy outlook, having echoes of the brownfield-first policy of the Labour Government in the late 1990s, that culminated in Planning Policy Guidance Note 3 (PPG3) in 2000. The current BBC documentary series on New Labour tells the political story of that era[5]. Unsurprisingly, its planning agenda is not centre stage, but might a review of PPG3 help frame consideration of the latest brownfield zeitgeist? This blog looks back at the genesis of PPG3, unpacks its core elements, and sketches out what happened to housing delivery.   Emergence of the policy New Labour came to power in 1997 with a focus on urban renaissance, but it went with the grain of the agenda from the previous Government[6] which had already suggested an “aspirational target” of 60% of new homes on brownfield land[7]. In 1998, Deputy Prime Minister (DPM) John Prescott published Planning for the Communities of the Future[8]a policy statement which introduced the idea of ‘brownfield first’, described as: “a sequential and phased approach to the development of all sites, which means there will be a general preference for building on previously-developed sites first, especially in urban areas” This was not a ‘brownfield only’ policy: “The principle of reusing previously-developed sites is, at first sight, the most sustainable option. However, reuse of land (and buildings) is only one aspect of sustainable development. Other aspects relate to the resource and energy implications, including reducing the need to travel. Not all previously-developed land is equally attractive to develop in sustainability terms. … Thus, in sustainability terms, some forms of greenfield development may be more attractive, such as extensions to urban areas in public transport corridors… This suggests that criteria may be needed for deciding a sequence for development at regional, and particularly local, levels. This means using a more sophisticated approach to the choices of both the form and phasing of development, with the clear aim of creating more sustainable patterns of development.” On how this related to meeting housing needs, Government was cognisant of affordability, but sought to downplay the idea of the 4.4m households by 2016 as a binding target, by introducing “plan, monitor and manage”. In his statement to Parliament, the DPM said: "The dilemma is clear cut and affects us all - how to accommodate more households and, at the same time, protect our precious countryside, without rents, house prices or homelessness spiralling upwards. It is not just a matter of how many households but where they will live…. In order to achieve greater flexibility, we are determined to get away from a simplistic 'predict and provide' approach in housing, as we have done for road building. We will treat the household projections as guidance, not house building requirements. Moreover, we will allow for greater flexibility in adjusting regional and local plans to ensure local provision is meeting local need over time…” [9] In 1999, the Government consulted on a draft of PPG3, which introduced the sequential approach. That summer, the Urban Task Force reported[10]. PPG3: brownfield-first planning policy PPG3 was published in March 2000[11]. It comprised a number of core elements: Housing targets were to be set at a regional level based on a “realistic and responsible approach to future housing provision, assessing both the need for housing and the capacity of the area to accommodate it” (No tilted balance then!). Growth was to be directed to “areas where previously-developed land is available … in preference to developing greenfield sites.” Land supply was underpinned by a brownfield target of 60% “in order both to promote regeneration and minimise the amount of greenfield land being taken for development” with urban capacity studies used to identify the potential of brownfield land. In identifying sites for allocations “authorities should follow a search sequence, starting with the re-use of previously-developed land and buildings within urban areas identified by the urban housing capacity study, then urban extensions, and finally new development around nodes in good public transport corridors.” Site selection was based on criteria in Paragraph 31 of the PPG3, but deliverability was not one of them. Brownfield sites were to be preferred to greenfield release unless they performed “so poorly” as to preclude their use for housing. The phased release of sites was to be determined in local plans based on the sequential approach, with plans required only to identify land for the first five years (and no requirement for it to be deliverable, as now), with plans to be “updated is reviewed and rolled forward at least every five years”. The only concession to deliverability was the where it said: “it is essential that the operation of the development process is not prejudiced by unreal expectations of the developability of particular sites nor by planning authorities seeking to prioritise development sites in an arbitrary manner.” Guidance was produced to assist in this process.[12] Enforcement of the policy included the Town & Country Planning (Residential Development on Greenfield) Direction 2000, requiring local authorities to refer planning applications on greenfield sites of at least 5ha or 150 dwellings - including on existing local plan allocations - to the Secretary of State for him to decide whether he wanted to make the determine the application following a public inquiry. In the first ten months of PPG3, the Secretary of State had ‘called-in’ 20 greenfield housing applications under the Direction or as a departure, with a further nine pending a decision[13]. What was the impact? In 2003, Lichfields was commissioned by ODPM to carry out research on the implementation of PPG3[14]. We found an inconsistent picture across the country as to how well the policy was being applied. Half of local authorities had reviewed their greenfield allocations, and most had either completed or were underway with urban capacity studies, but there was far slower progress on local plan preparation, with only 13% of local plans and 35% of structure plans adopted. A third of local authorities – particularly in the South East – had not begun preparing local policies (in effect they banked the restrictions on greenfield release as early as 1998 without putting in place a strategy to respond to housing needs). The Study found that barriers to implementation of PPG3 included the slow pace of local plan production and lack of resources. Plus ça change. A historic perspective on the brownfield-first policy is provided by Andrew Prichard, former manager of the Regional Planning Body in the East Midlands[15]. He found: Regional Planning Guidance targets for housing provision aggregate to around 150,000 homes[16] but with a different regional distribution: numbers were higher in the North East, Yorkshire and Humber and the West Midlands. In the North West, the Government cut housing targets by 15% to reduce greenfield development. In the South East, the Government split the difference between the SERPLAN intentions and the conclusions of Professor Stephen Crow (Inspector) who had “demolished” them. The proportion of brownfield increased (CPRE reported it to be 67% by 2005). However, net housing additions fell from 156k per annum in 1998 to a low of just 132k in 2001 despite “increasing economic buoyancy”. House building was clearly not keeping up with household growth, with shortfalls of 90,000 homes alone in 2001 and 2002. The figures for net housing additions 1998 – 2003 are shown in the Table below. Source: DLUHC: Table 109 Dwelling stock: by tenure and region, from 1991 (figures may not sum due to rounding) Whilst the rate of completions nationally had recovered by 2003, there was still a 7% reduction in the south, and national supply was historically low. London was the principal driver of increase. Andrew Prichard comments: “The extent to which PPG3 was responsible for the mismatch is of course difficult to fully establish. However, it represented a very significant shift in locational policy for developers and land owners and was strongly enforced by central Government. Research by Savills in 2004 indicated that the immediate effect of PPG3 was to ‘restrict greenfield availability rather than increase the availability or capability of development of brownfield sites’ – which in turn had implications for land prices and housing supply.” The Barker Review of Housing Supply Interim Report (2003) observed that: “The sequential test introduced in PPG 3 requires local authorities to release land for housing development in an order of preference that prioritises brownfield sites. It is not the intention of the policy to restrict land supply but some local authorities appear to have overinterpreted it to the detriment of housing being delivered. Indeed research from ODPM supports this point, arguing that local planning authorities understand ‘brownfield first’ but also erroneously believe PPG3 says ‘greenfield never’. The ‘prematurity of sites’ is often a reason for the refusal or delay of applications for housing developments. However, priority sites may not always be immediately available or suitable for development. In some local authorities, this policy is used to block development rather than actively manage the release of land.”[17] A change in direction By 2003, there was a shift. The DPM launched Sustainable Communities: Building for the Future, with plans to “tackle the housing shortage, especially in London and the wider South East by creating conditions in which private house builders will build more homes of the right type in the right places” [18]. This approach included the four new growth areas[19]. Barker’s final report (2004) said the planning system should be more responsive to market signals[20]. On the brownfield first policy, it recommended that: “PPG3 should be revised to require local planning authorities to be realistic in considering whether sites are available, suitable and viable. Any site which is not available, suitable and viable should be disregarded for the purposes of the sequential test.” In 2006, PPG3 was replaced by PPS3[21]. This maintained the 60% brownfield target, but crucially brought back the requirement for a rolling five-year land supply of deliverable sites and set a requirement for developable land for years 6-10 and, where possible, 11-15. By 2008, housing supply was 40% above its 2003 level. This policy was carried forward into the NPPF (2012) alongside the presumption in favour of sustainable development. This dual approach – of allowing local authorities to select brownfield sites in preference to greenfield, but still ensure they have a portfolio of sites that will secure a sufficient supply of housing in reality – remains part of the current policy framework[22]. Ten lessons for today This canter through one aspect of New Labour history tells us something about the factors this Government should consider if it is genuinely contemplating a more overt brownfield-focused policy: Even at its zenith, PPG3 was never a brownfield only policy, even though some Councils sought to interpret it as such. Plan makers were able to choose to release greenfield land for housing. Such a policy (that takes effect as soon as there is an expectation of a change[23]) will result in an immediate reduction in new housing supply, with the greatest downward impact in the south of England, where affordability problems are greatest. A brownfield-based policy does not, in of itself, make brownfield land more deliverable for housing. Barker’s interim report found that 69% of all National Land Use Database brownfield sites were not suitable for housing development and over half of the suitable land was in an existing use.[24] There is no evidence there is enough brownfield land, in any region, to deliver anything close to 300,000 extra homes per annum[25]. CPRE’s annual review of brownfield land[26] identifies capacity for 1.3m homes (1.1m of which was on brownfield registers, and 0.6m already consented). Registers can be a helpful indicator of brownfield potential, but crucially a) local authorities’ assessments of site deliverability are not independently tested; and b) they measure capacity looking ahead 15 years. At best it would equate to less than 87,000 homes per annum. In the north of England, the brownfield register capacity equates to just 44% of the Standard Method over that period[27]. In London, the South and Midlands, it is less than a quarter. Relying on brownfield land alone is likely to reduce the supply of affordable housing rather than increase it. The CPRE analysis also highlights that brownfield capacity is not a silver bullet for putting more growth in the north. Of the 1.1m homes capacity on brownfield registers, 55% are in London and the South of England, compared to 45% in the midlands and the north (almost exactly in proportion to population). PPG3 relied on regional planning to do the hard work of strategic spatial choices. Unless the Government chooses to introduce a new strategic planning tier, attempts to skew housing targets towards brownfield areas, and to the north of England, will require a further recalibration of the Standard Method. Directing housing targets to urban areas does not itself drive up the supply of brownfield land. The December 2020 changes to the Standard Method added 35% to the housing need figure for the 20 largest cities, but it is already clear there is no realistic prospect of this being met; plan makers in London, Leicester, Southampton, Bradford are among those already stating they do not have the land capacity to meet the inflated figure[28]. The practical limitations to the flow of brownfield development help explain why, throughout the life of PPG3, net housing additions hovered around half the 300,000 figure. The subsequent coupling of a brownfield focus with a parallel requirement to have a realistic supply of land (in PPS3 and now in the NPPF) coincided with an increase in supply.   It impacts on mix too. An overzealous drive for brownfield leads to high density flatted development in town and city centres. This may not be undesirable itself, but the rationing of land release means this can come at the expense of family homes with gardens, which may be what is most needed to make some cities attractive to families.   The growth in brownfield development that occurred in the second half of the 2000s coincided with a boom in buy-to-let mortgages[29] and a major public sector funding of housing-led regeneration programmes. Looking at the situation today, one would need to understand whether equivalent market drivers exist to accompany any change in policy, and bridge the gap between rhetoric and real-world delivery.   [1] Conference speech text here[2] In this blog ‘brownfield’ is used as shorthand for previously developed land (or PDL).[3] Daily Telegraph article here (£)[4] Welywn Hatfield Council has interpreted it very literally and put its delayed (very delayed) local plan on hold – see here.[5] Blair & Brown: The New Labour Revolution available on BBC iPlayer[6] For example the 1995 White Paper: Our Future Homes – Opportunity, Choice, Responsibility included proposals for “the planning system and public investment to encourage more development in existing urban areas and less on greenfield sites”  and the aim to “build half of all new homes on re-used sites”,[7] In its 1996 Green Paper – Household Growth: Where Shall We Live – which looked at how to address the 4.4m additional households expected between 1991 and 2016.[8] Available here[9] Available on Hansard Volume 307, debated Monday 23rd February 1998[10] The Urban Task Force was chaired by Lord Rogers. Its Mission Statement was “The Urban Task Force will identify causes of urban decline in England and recommend practical solutions to bring people back into our cities, towns and urban neighbourhoods. It will establish a new vision for urban regeneration founded on the principles of design excellence, social well-being and environmental responsibility within a viable economic and legislative framework.”[11] The 2000 PPG3 is available here[12] Planning To Deliver - The Managed Release Of Housing Sites: Towards Better Practice available here[13] Written Answer in Hansard[14] PPG3 Implementation Study (2003) available here. This blog author was part of the research team.[15] In Chapter 3 of the English Regional Planning 2000-10, edited by Corinne Swain, Tim Marshall, and Tony Baden[16] Broadly equivalent to the 3.8m extra households set out in the 1996-based household projections.[17] The Interim Report of the Barker Review is available here[18] Available here[19] Thames Gateway; Milton Keynes/South Midlands; Ashford; London - Stansted – Cambridge. These flowed from recommendations of Professor Crow’s report on the South East Plan.[20] The Final Report of the Barker Review is available here[21] PPS3 (2006) is available here[22] For example, see paragraph 120 of the current NPPF which sits alongside paragraph 68[23] As evidenced by Welywyn Hatfield’s pre-emptive pause of its Local Plan following the PM’s Conference speech[24] See para 9.9 of the Interim Report: 32% was subject to flood risk or in the Green Belt; and 58% was in weak housing markets (which would impact on values capable of overcoming inevitable abnormal costs). Just 31% was in neither category, but most of it was already in use, leaving just 11% available for development. Add on to this, some of the 11% would have site-specific constraints. [25] This was clear from the NLUD data, as this 2014 Lichfields publication showed[26] CPRE – Recycling our Land: The State of Brownfield Report 2000. Available here[27] Based on the Standard Method as calculated at December 2020 to correlate with the CPRE Brownfield Register base date.[28] Examples are in this Inside Housing article[29] Reported as representing 30% of all house purchase mortgages by 2008 (Sprigings N, 2008, “Buy-to-let and the wider housing market” People, Place & Policy Online 2(2) 76–87).  

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