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Your Official Top 20: The new Standard Method and the cities/urban centres uplift
Our blog - 'Mangling the Mutant' - provided thoughts on the implications of the revisions to the Standard Method for assessing local housing need when it was released just before Christmas, and charted the Government’s retreat from its original proposals of August last year. For most local planning authority (LPA) areas, the Government simply reverted to its 2018 version of the Standard Method, with the only change being a 35% uplift to the 20 largest Cities and Urban Centres in England. Applying this uplift magically elevates the combined national local housing need figure to just shy of 300,000 per annum; fancy that! The general merits of this approach are debated elsewhere. In this blog we look specifically at the top 20 cities/urban areas selected for the uplift, which are currently: Birmingham, Bradford, Brighton and Hove, Bristol, Coventry, Derby, Kingston upon Hull, Leeds, Leicester, Liverpool, London, Manchester, Newcastle upon Tyne, Nottingham, Plymouth, Reading, Sheffield, Southampton, Stoke-on-Trent, and Wolverhampton[1]. There are two things to note when considering the top 20 cities/urban areas. First, the top 20 cities/urban areas can change over time based on population growth. Second, with the exception of London[2] the uplift is applied only to the LPA in each city/urban area with the largest population; for example, in Manchester the uplift is only applied to Manchester City Council (being the Manchester LPA with the greatest population) not the whole urban area of Manchester (including Salford, Trafford etc.). The selection of the top 20 gives rise to many questions. In this blog we look at four: How were the top 20 determined and is there a logic to the threshold? The top 20 can change, but is this likely? and Urban vs administrative boundaries? What is the rationale for the uplift? How were the top 20 determined and is there a logic to the threshold? There is no background data set that shows the full workings out of how the Government arrived at the top 20 list. The PPG simply states: “The cities and urban centres list is devised by ranking the Office for National Statistics list of Major Towns and Citiesby population size using the latest mid-year population estimates (nomis, official labour market statistics).” (2a-004) When the updated PPG was first published it linked through to a Freedom of Information (FOI) request. That link seems to have been updated over the Christmas break, now directing to a list of towns and cities defined by the ONS. From the original FOI link, buried away in the data requested, was a dataset matching Middle Layer Super Output Areas (MSOAs) to the list of towns and cities which can be found here. Using this data and the matching the MSOAs against the latest 2018 mid-year population estimates we get the 20 cities/urban areas which matches with the Governments own list (the list of the top 40 and current population is presented later in this blog). We can’t be sure if the Government used best-fit MSOAs as the FOI data also included cities matched at the smaller output level. But since there are no workings from MHCLG and we reach the same 20 cities with our approach (see below for the list), we think we are on the right track. Of note, Portsmouth is number 21 and is the closest LPA to being subject to the uplift; dodging the 35% bullet by virtue of just 12,000 people. Also of note - as was highlighted in our previous blog - all of the OxCam corridor’s urban areas fell outside the top 20; however, four of them feature in the top 30 (with a further two – Oxford and Cambridge - in the 31-40 band)[3]. Whatever the merits in principle of applying the cities/urban centres uplift, questions arise as to the logic of a fixed percentage uplift to just 20 areas, creating a 'cliff edge' with comparable places falling either side of a threshold that might be perceived as arbitrary; the fact that - outside the top 20 - there are four other cities/urban areas with a population over 200,000 (including Portsmouth and Norwich) or places - like Milton Keynes - with obvious potential to grow, does make it seem a blunt approach. An alternative would have been to mirror the formula approach of the affordability adjustment, with a sliding scale or bands based on size, so the uplift is in some way proportionate to the size of centre. This would have captured an uplift to other locations that are undeniably major urban centres. The top 20 can change, but is this likely? The PPG (ID: 2a-004) says: “Whether a cities and urban centres uplift applies depends on whether the local authority contains the largest proportion of population for one of the 20 cities or urban centres in England within the list.” So, the 20 LPAs currently might change if the population of these areas changes relative to other centres down the list. But is this likely? Probably not. We have looked at the ONS 2018-based population projections up to 2043. Applied to the current defined urban areas (which may change given possibility for urban growth etc.) and calculated at MSOA[4] level. Presented in the table below, these show that, even with differing rates of growth, areas are not projected to grow (or shrink) to the extent the places falling within the top 20 will change. In simple terms, barring some dramatic population shifts (such as a baby boom in Portsmouth and a mass exodus from Wolverhampton), no urban area outside the top 20 is projected to grow at such a rate, relative to those above it, that it breaks into the top tier. The LPAs that have the 35% uplift now are most likely stuck with it until a new system for binding housing requirements (as heralded by the White Paper) comes along[5]. If there are any changes to the top 20, it is more likely to come about as a result of ONS amending the defined urban areas by best fit MSOAs, although this would mean the ONS methodology for such a technical exercise carrying a policy-making burden it was not designed to bear. Urban vs administrative boundaries With the exception of London, the uplift is applied to the LPA with the highest population in each defined top 20 cities/urban area. The Government’s aim is to apply the uplift to the most populous areas to encourage more sustainable and brownfield development. However, this principle does not take account of how the urban areas of cities align with the LPA boundaries. It also does not take account of the practical constraints on development potential each of those LPAs might have (flagging how the assessment of need for these cities is now contaminated by policy factors). For some cities, the approach does make some sort of sense. For example, the urban area of Hull is more or less wholly within the LPA of Hull City Council as shown below. The same goes for Wolverhampton. In these cases, the uplift is applied to (in the main) the whole of the city/urban area and is neither applied to large areas outside of the urban area nor to areas that form part of the functional city but are outside of the LPA's control. However, for others it is less logical. Take Manchester: only Manchester City Council gets the 35% uplift. While this LPA does cover the central area of Manchester, applying the uplift just to the City means that other areas close to the centre (such as parts of Salford and Trafford) are not subject to the same uplift. That is despite them potentially having more brownfield land or central locations for development than areas in the very south of Manchester City’s boundary. Equally, what is it that makes the Greater Manchester urban area (comprising Manchester City, Bolton, Bury, Rochdale, Salford and Stockport) different from the way in which all 33 of London's Boroughs and the City were treated by the method? Bradford is at the other end of the scale to Manchester; the LPA is far larger than the defined urban area itself. With a blanket 35% uplift to the whole LPA, the city has options – subject to its Green Belt – to address the uplift by releasing land on its periphery or rural hinterland. Another issue arises where large parts of a functional city are not within an LPAs boundary (akin to Manchester in many respects). In Bristol a large chunk of the eastern part of the city (an area of Green Belt release where a considerable portion of the city’s previous housing needs have been met) is not subject to the uplift as it is outside the Bristol City area. Nor is a large part of Bristol’s northern extent within in its own boundaries (albeit not captured by the ONS best fit). Nottingham is similar where large parts of its wider urban area (also not captured by the ONS best fit) are not in control of the City Council. This obviously highlights both the limitations (and idiosyncrasies) of the ONS ‘best fit’ exercise (in terms of defining what is or is not part of a main city or urban area) but also the variable approaches available to some LPAs for delivering 35% extra housing. This takes us to land constraints: the 35% uplift bears no relation to the availability of land in the area. Two obvious examples are Brighton & Hove and Reading. As highlighted in our previous blog, Brighton is bounded by the sea to the south and a National Park to the north while Reading has already built up to its boundaries with much of its development needs already being met on adjacent land in neighbouring LPAs. The same can be said of Coventry, Leicester and Southampton to differing extents. So, where can the extra 35% be met? The duty to cooperate will have to do some heavy lifting here to redistribute uplifted needs in plan preparation. Whilst it can work - Coventry is an example of relatively successful (if not exactly speedy) redistribution under this regime[6] - we know from experience elsewhere it creaks (as do other strategic planning mechanisms) when faced with big numbers and multiple local authorities across complex urban areas. What is the rationale for the uplift? In our previous blog we set out the Government's rationale for the uplift was based on three factors: maximising existing infrastructure; responding to the availability of land arising from structural change in retail and commerce, thereby maximising brownfield rather than greenfield development; and responding to climate change by reducing high-carbon travel. The approach set out by Government raises two points of discussion: First, is one of principle. Housing need is a concept that has long been untarnished by policy factors that should promote or constrain the delivery of housing in different areas[7]. This was made very clear by the Courts in Gallagher Estates Ltd v Solihull MBC[8] where, at paragraph 37 of the judgment, the housing requirement was clearly delineated from the objective assessment of housing need as follows: “ii) Full Objective Assessment of Need for Housing: This is the objectively assessed need for housing in an area, leaving aside policy considerations…. iii) Housing Requirement: This is the figure which reflects, not only the assessed need for housing, but also any policy considerations that might require that figure to be manipulated to determine the actual housing target for an area. For example, built development in an area might be constrained by the extent of land which is the subject of policy protection, such as Green Belt or Areas of Outstanding Natural Beauty. Or it might be decided, as a matter of policy, to encourage or discourage particular migration reflected in demographic trends. Once these policy considerations have been applied to the figure for full objectively assessed need for housing in an area, the result is a "policy on" figure for housing requirement.” This distinction between 'need' and 'requirement' means plan makers (and in due course the Local Plan Inspector) would take the local housing need (‘policy off’) and determine the appropriate requirement (‘policy on’) based on spatial policy factors that would include judgements about the desirability to focus development on brownfield sites, in proximity to transport infrastructure, and the desirability of reducing high-carbon travel (all three being longstanding components of national planning policy). The updated standard method now incorporates these three spatial policy judgements into the assessment of need. Of course, the NPPF para 11 b) still applies, so the housing need figure remains a minimum starting point, and capacity factors may justify setting a requirement figure below the level of 'need'. The practical problem arises because the 35% uplift does not take account of constraints, with locations like Brighton (and London, Birmingham, Coventry etc.) all having very recently demonstrated to Inspectors that are they do not have realistic urban capacity to meet previous (even lower) estimates of need. The urban priority is being 'double handled' in both the assessment of need and in the 'policy on' exercise of setting the requirement, with the evidential foundation for the former bearing no relationship to the proper exercise that will need to be undertaken in the latter. This creates a problem of perception (the numbers are unlikely to be achieved in the areas identified) and practicality (in that unmet need is then difficult to redistribute to neighbouring areas), which makes it less likely the Government will hit its 300K per annum national ambition or address growth needs in areas of greatest economic and affordability pressures.   This takes us to the second point. If we are crossing the Rubicon to include spatial ‘policy-on’ elements into the assessment of need, why stop here? Could a lesser uplift have been applied to the next tier of cities (21-30)? Why did the Government not also apply an uplift to urban areas where development would help meet its own aspirations such as the OxCam Arc (e.g. by applying an uplift to Milton Keynes, Oxford, Cambridge and other Arc urban areas) to reflect the National Infrastructure Commission? The PPG (ID: 2a-010) already provided a conceptual framework for this in explaining the basis on which 'actual need' might be higher than the standard method: “Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates. This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan). Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of: growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals); strategic infrastructure improvements that are likely to drive an increase in the homes needed locally” Taken as a whole, the 35% uplift to the top 20 urban areas and cities invites more questions than it answers. It will be perceived as a blunt tool with a potentially messy application in many of the cities/urban areas to which it applies. And having blurred the concept of need for policy reasons, it appears not to have fulfilled its potential – for reasons on which we can all speculate – to deliver the uplift in areas where it will deliver the most benefit.   [1] ID: 2a-004[2] ID: 2a-034[3] Northampton (22), Luton (23), Peterborough (27), Milton Keynes (29), Oxford (34), Cambridge (40).[4] MSOA = Middle layer Super Output Area[5] Some initial thoughts on the challenge of this new White Paper system for setting binding requirements can be found here[6] Based on the Memorandum of Understanding between Coventry and the Warwickshire authorities, which has been taken through Local Plans in both Coventry and its surrounding areas.[7] This 2010 research provides a good summary of the concepts of housing need. PPS3 (2006 and subsequently) defined housing demand and need respectively as: “The quantity of housing that households are willing and able to buy or rent” and “The quantity of housing required for households who are unable to access suitable housing without financial assistance.” [8] The judgement is available here   Image credit: Pollard Thomas Edwards  


Mangling the mutant: change to the standard method for local housing need
The launch of the proposed new standard method for local housing need on 6th August 2020 unleashed a media and political storm. An unfortunate cross-over with the problems of A-levels and GCSEs led to it being dubbed the ‘mutant algorithm’[1] On 16th December, the Government sought to resolve matters, making a series of announcements across four publications: A written Ministerial Statement[2] Response to the Consultation on Proposed Changes to the Current Planning System[3] Updates to the Planning Practice Guidance on Local Housing Need[4] to set the new standard method approach A spreadsheet with the indicative figures from the updated method[5] What are the headlines and what does it mean? For most local authorities, it’s ‘as you were’ Outside the 20 largest urban areas, the method will remain that which was first introduced in 2017, which is based on applying the 2014-based household projections, with a percentage uplift to reflect the price-income affordability of housing, subject to the 40% cap. Whilst the number will change in response to fluctuations in affordability, the ten year period over which it is calculated, and the plan-related 'cap', this represents stability. Interestingly, this now means that the majority of those local authorities preparing plans over the next 2-3 years, looking ahead to 2040 or beyond, will be doing so based on a demographic trend period of 2009-2014 that was infected by the financial crisis. The 20 largest cities and urban centres top up their need figure by 35% The new method applies what it calls a 'cities and urban centre uplift' of 35% to the capped need figure generated by the existing standard method in the top 20 largest cities and urban centres. What is classified as the top 20 is based on ranking the ONS list of major towns and cities[6] by population, and thus it may change over time. The current top 20 are Birmingham, Bradford, Brighton and Hove, Bristol, Coventry, Derby, Kingston upon Hull, Leeds, Leicester, Liverpool, London, Manchester, Newcastle upon Tyne, Nottingham, Plymouth, Reading, Sheffield, Southampton, Stoke-on-Trent, and Wolverhampton. The effect of this uplift is summarised in the table below, which compares the new SM approach against past delivery, the most recent Local Plan, and the previous version of the SM without the urban uplift. As can be seen, London represents the biggest absolute increase because the 35% is applied to all Boroughs, whereas for other metropolitan areas it only applies to one or two urban authorities. We turn to the London figure later in our analysis. The City and Urban Centre Uplift: Quart into a pint pot? Beyond London, the figures generate a number of interesting dynamics. The new SM figures are markedly higher than most current Local Plan requirement figures for those cities, which were themselves lower than the previous Standard Method (ie without the new cities and urban centres uplift). With some exceptions (perhaps), this may simply mean the new method will pile up need into cities that do not realistically have the urban capacity to meet it. The Government rationale in its consultation response presents three reasons for this approach: "First, building in existing cities and urban centres ensures that new homes can maximise existing infrastructure such as public transport, schools, medical facilities and shops. Second, there is potentially a profound structural change working through the retail and commercial sector, and we should expect more opportunities for creative use of land in urban areas to emerge. Utilising this land allows us to give priority to the development of brownfield land, and thereby protect our green spaces. And third, our climate aspirations demand that we aim for a spatial pattern of development that reduces the need for unnecessary high-carbon travel." All three reasons are what the planning system would traditionally have regarded as being ‘supply side’ or ‘policy-on’ and not part of the so-called ‘objective assessment of need’[7]. 26% of the total housing need figure for these twenty cities is now based on explicit 'policy-on' considerations, and it will be interesting to see whether and how these are played back into the debate over setting 'policy-on' requirement figures, particularly in circumstances where those cities might say they are unable to meet needs due to lack of suitable or deliverable/developable sites. Questions may be raised as to whether these policy factors are consistent with the concept of need as defined in the NPPF, or whether the application of them only to the 20 largest urban centres - within what can be multi-polar urban conurbations - has been justified. The Government goes on to say that: "The increase in the number of homes to be delivered is expected to be met by the cities and urban centres themselves, rather than the surrounding areas. In considering how need is met in the first instance, brownfield and other under-utilised urban sites should be prioritised to promote the most efficient use of land. Development should align with the character of local neighbourhoods in urban areas and support the building of green homes. This is to ensure that homes are built in the right places, to make the most of existing infrastructure, and to allow people to live nearby the services they rely on, making travel patterns more sustainable. Local planning authorities should co-operate on that basis, notwithstanding any longer-term proposals set out in the Planning for the Future White Paper which explain that we intend to abolish the Duty to Cooperate." Of course, the drive to meet needs in urban areas on brownfield land is not new. Many of the 20 cities are ones where their current Local Plans sought but failed to identify sufficient land to meet previous - lower - estimates of need, thereby generating unmet need. For example, in Brighton & Hove, the current Plan was adopted after an examination process where the Inspector concluded[8] that, to be adopted, “I would need to be satisfied that the Council had left no stone unturned in seeking to meet as much of this need as possible.” Brighton's Plan was subsequently adopted with an annual target of 660, against a need figure (at the time) of 900‐1,200 dpa, with unmet need that has not subsequently been addressed. The new standard method now proposes a figure for Brighton that is almost three times recent rates of delivery, in a tightly bound city wedged between the South Downs and the English Channel. Extra need in Brighton thus inevitably increases pressure on areas like Horsham and Mid Sussex via the duty to cooperate.  Other high profile examples include Birmingham, Bristol, Coventry and Reading, in some cases leading to plan making failure (e.g. the West of England) or protracted (largely unsuccessful) attempts to resolve - with multiple neighbouring local authorities - how those unmet needs will be addressed. In many of these same cities (but also, for example, Newcastle, Leeds) needs that cannot be met in the urban area have resulted in plans proposing Green Belt release on the urban edge. The Government might argue (as does Neil O’Brien MP – a critic of the 'mutant algorithm' – in this tweet thread) that the changing world and new permitted development rights will open up new capacity for residential development, that the development model for development in cities will need to change, and that the new Urban Task Force will help to shape a new approach. That may be right to some extent (of note, some of the 20 cities have exceeded their local plan targets suggesting the plan makers' attempts to quantify urban capacity is not infallible), but it does seem that the structural change sketchily envisaged would at best take time to achieve, whereas the new Standard Method figures will need to inform plan making now. And there is no change proposed to the NPPF’s requirement (para 67) for local plans to have: a.  specific, deliverable sites for years one to five of the plan period b.  specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the pla Plan makers in these cities - faced with the elevated need figures - will be required to identify specific deliverable and developable capacity capable of meeting that need, and will struggle to rely on more abstract concepts around how future urban development will be realised. The two most recent iterations of the London Plan - faced with this challenge - have seen Inspectors (who reviewed the evidence) recommending a reduction in the housing requirement figures advanced by the Mayor due to insufficient confidence in deliverability of the urban capacity. The conclusions of the Inspectors examining the New London Plan in 2019 are apposite when they settled on the capacity constrained requirement figure that looks shortly to be adopted: "Furthermore, the question of supply is based on capacity and given that this would be maximised as far as realistically possible, it is difficult to see how the number of deliverable housing units could be increased [above 52K per annum] without consideration being given to a review of the Green Belt or further exploration of potential with local authorities within the wider South East." On its face, it therefore seems unlikely there is sufficient evidence to conclude that these 20 cities will almost double the rate of housebuilding from 67.3K to the new ‘need’ of 131.5K. This takes us inexorably to: Green Belt release on the edge of those cities that have them, with the scale of need being a proven part of an ‘exceptional circumstances’ justification under the NPPF; and/or  the duty to cooperate and the requirement for cities who cannot meet their need to seek arrangements with neighbouring LPAs as per the NPPF requirement (para 25 a) “that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.” Unfortunately, we know that big cities' attempts to successfully negotiate solutions for this unmet need are both tortuous and rarely completely successful (Birmingham being a notable example).   The national housing need figure is 297,605 (let’s call it 300,000) Based on the indicative figures supplied by Government, the new national total is just short of 300K, but this figure will change when individual affordability ratios, projection period, and outputs of the plan-based 'cap' all change over time. This compares to an average annual net additions rate since 2017 of 236K. However, the change in the Standard Method is not evenly spread by region. The figure below charts current local plan requirements, average delivery, the current method (with and without the urban uplift) and the (now deceased) mutant algorithm. Key points emerge: London is responsible for the greatest uplift. The increase to 93.5K is almost identical to the figure produced by the ‘mutant algorithm', and is well north of recent completions and current or emerging London Plan. The Government says: "It is clear that in London, in the medium term, there will need to be a much more ambitious approach to delivering the homes the capital needs. The Secretary of State for Housing, Communities and Local Government expects to agree the London Plan with the Mayor shortly. This new plan, when adopted, will set London’s housing requirement for the next 5 years." This would suggest the London figure is of more academic interest right now, and its uplift will not contribute towards meeting 300K over the next five years. The new standard method is below recent rates of housing delivery in the midlands and northern regions; criticisms made about consistency with the ‘levelling-up’ agenda might be made again. The figures in the three southern regions (to 113.7K dpa) are an increase, but not by very much when one considers that the three southern regions have been delivering 93.3K dpa over the past three years. Those regions have been achieving this despite only partial local plan coverage, particularly in areas of Green Belt where rates of development are very low. The new figures appear to be readily achievable if those regions can secure local plan coverage. The reduction from the mutant algorithm’s 137K dpa figure is a stark measure of the political change that has occurred. Whither the OxCam Corridor? The authorities in the OxCam corridor have delivered an average of just over 22K dwellings per year in the last three years (to 2020); slightly more than the standard method indicated was needed (before any urban uplift) – 21K[9]. But none of the cities in the corridor fall within the 20 largest urban areas to which a 35% uplift is applied – meaning that the number across the arc will remain at just under 21K dpa for the foreseeable future. This falls below the identified need for between 23,000 and 30,000 homes to support transformation economic growth across the arc, as identified by the National Infrastructure Commission. This ultimately means that Government is reliant upon authorities in the OxCam corridor voluntarily ‘doing more’ than the minimum housing need figure if it wants to fulfil the arc’s economic potential. There is nothing in the PPG to prevent this – indeed, it is encouraged. But it is interesting how the corridor - a longstanding national policy priority - did not similarly feed its way into the revised method as part of the new ('policy-on') uplift. The Government has reiterated the 2023 deadline for Local Plans In the WMS, the Secretary of State commented on the timescale for implementation of the wider reforms in the White Paper, saying that the Government: “will publish a response in the Spring which will setting out our decisions on the proposed way forward, including to prepare for legislation, should we so decide, in the Autumn.” Whatever the parliamentary passage of that primary legislation, this will be only the first step in a journey that will also involve secondary legislation, policy and guidance to be concluded before any local authority begins its 30 month plan preparation period. There is, quite simply, no realistic prospect of the White Paper providing the framework for practical plan making over the next few years. Despite this, some LPAs have taken the view that they should halt plan making to wait for the new system. The Government has therefore made plain in its response to the consultation that: “The government wants to ensure that work continues to progress Local Plans through to adoption as soon as possible and, at a minimum, by the end of 2023 to help ensure that the economy can rebound from COVID-19.” The December 2023 deadline was the basis of the Secretary of State’s announcement in March 2020[10] which included the following threat: "The government will prepare to intervene where local authorities fail to meet the deadline in accordance with the existing statutory powers, considering appropriate action on a case by case basis." The Government will need to monitor closely how quickly the local plan making system – which has stalled due to White Paper, SM and COVID uncertainty – gets back in the saddle and progresses with plan-making. There are a significant number of local authorities where plans will fall beyond the five years-from adoption threshold over the next 2-3 years and need new plans. Putting all of the above together, one overwhelming conclusion becomes apparent… It is unlikely the SM alone will lead to 300K by the mid 2020s. Outside London, the new SM adds up to 204,000 dpa. It is only London’s heroic figure of 93.5K that means the new method gets close to 300K, and we know this is a task for the new London Plan that may take five years to put in place, even before it delivers new homes on the ground. There have to be very significant doubts over the prospect of London hitting that figure given past rates of delivery. There is little evidence that many local authorities are actively seeking to exceed the standard method, despite it being a minimum starting point; in fact, there are examples of areas ratcheting down their ambitions in response to it. We may see some areas continue with higher build rates, but that may diminish as plans are reviewed based on the new method. The Government would need to introduce significant complementary incentives for areas to go above their numbers. The duty to cooperate has not proved an effective mechanism for the timely resolution of unmet needs in areas of constraints, and we are unlikely to have a sequencing of new local plan production before the December 2023 deadline that ensures all areas are preparing plans at the same time such that needs are met across wider areas. There is so far little evidence that the strategic plan making ambitions being pursued in many areas are proving an effective or responsive way of addressing these matters. With a fair wind, the proposals in the new SM are a recipe for maintaining (just) current national rates of housing delivery, but seem unlikely to get England over the 300K hurdle. [1] The consensus is that it’s really only a formula, but ‘algorithm’ is more à la mode.[2] The Ministerial Statement is available here[3] The response to the consultation can be downloaded here[4] The PPG can be accessed here[5] The figures can be downloaded here[6] Office for National Statistics list of Major Towns and Cities[7] Definitions clearly set out in Gallagher Estates and Lioncourt Homes vs Solihull MBC [2014] EWHC 1283 (Admin)[8] As set out in her letter[9] MHCLG indicative figures suggest the new SM yields 200 dpa more in the corridor, but this is due to a gremlin for Oxford which did not take account of the recently adopted Plan (impacting on the cap). No cities in the OxCam corridor feature in ‘the list’ of top 20 cities and urban centres.[10]