The new National Planning Policy Framework, which sets out the rules governing the English planning system, was published on Monday. It is not the NPPF that we need. The Prime Minister was right to describe the housing crisis in lurid terms – but the announcements made on Monday were insufficient to solve the problem of housing quantity or quality.
First, the briefed announcement around getting tough on developers who build slowly was simply missing from anything published on Monday. No wonder cynicism is corroding the fabric of our democracy when an announcement briefed to the press has no relationship to the policies unveiled. But even setting this aside, and hoping Theresa May was hinting to a firmer response to the Letwin Review into the gap between permissions and housing starts and completions, what was announced on Monday was simply inadequate.
As well as setting out the fundamental undersupply of homes over many decades, the Government needs to acknowledge the impact of immigration and low interest rates on high house prices, and pledge to reverse these as far as possible. We are asking our people and voters to take many more homes locally – we must not just set out why greater supply is necessary, we must also reassure them we are also acting on demand.
On Monday, the Government cut its housing goal from 300,000 to 200,000 a year
Talk of ‘tough’ action is nonsense. The original thinking behind the delivery test was that each council had to meet 95-100 per cent of its housing need. The delivery test announced in the new NPPF requires each council to meet 75 per cent of the new numbers required by November 2019/20, (numbers which collectively add up to 265,000 a year). 75 per cent of this is 200,000, meaning the Government’s housing goal fell on Monday from the 300,000 that Philip Hammond announced last Budget to just 200,000 or so.
However, it gets worse, because it looks like councils can use the fact they have large amounts of green belt or other constraints to reduce their numbers down. So it could easily be the case that housing numbers run at 175,000 or so (40,000 lower than at present) and no action is taken. Yet another flaw is that in most places where the delivery test is failed, the proposed sanction – allowing planning appeals to go through more easily – will already be in place because the council will not have a five-year land supply, which already triggers this sanction.
Lastly, the timing is all wrong. The first difficult application of the delivery test is in November 2020, just 18 months from the next election. Even if we wanted to, we cannot declare a free-for-all across anything more than a couple of additional councils months ahead of the election.
Over-briefing and lazy journalism should not hide the paucity of what was announced
It is no wonder that the media are struggling and trust in the mainstream media is falling when outlets ran articles on ‘tough targets’ for councils when the total numbers were in fact a cut on previous targets, and reported an announcement that did not, in reality, exist in any of the policies or documents published. This is ‘Thick of It’ style government and media.
You need a plan to intervene, not a plan-led system without plans
The Government also praised the plan-led system, where local people control development. Yet the document set out that the delivery test not being met would lead to councils facing speculative development – which effectively means large developers (who May was criticising for not building) being able to ram through large sites via the expensive appeals process, the very process which is exacerbating the gap between permissions and delivery.
The whole point of the delivery test was that in areas failing to meet need, Government would find (politically-sensitive) ways to try to intervene to meet the shortfall. Without a plan to intervene, the only gainers are the large land speculators, developers and their hordes of lawyers and planning consultants. Local people will feel let down.
Still too complex and not enough on design, ownership and infrastructure
Without going far enough on housing delivery, there was also nowhere near enough on infrastructure and design. May argued that ‘our new planning rules put a stronger emphasis on good design’. There were some well-intentioned tweaks here in section 12 – for example supporting visual tools such as design guides and codes. But this section was so broad that you could not read it as stopping poor design. You could build a plastic clad block with solar panels in a conservation area, and as long as you did it to the height of the other buildings and referenced the colour scheme. Indeed, the document argued ‘great weight’ should be given to innovative designs.
This is all the more crucial given the fact that poor design slows down housing delivery – which May criticised the developers for. Only a quarter of people with a preference would rather buy an new home rather than an older one. This makes housing delivery slower, which makes it more controversial, while political support is heavily impacted by design. Research shows that popular designs for new housing can cut by half ‘in principle’ opposition to new housing.
This is backed by pricing data. Traditional design, towns and cities are often associated with higher market values because people want to live and work there: the ‘heritage premium’ is four times greater than the ‘new build premium’ in London. Given two identical homes with the only difference being that one is in a heritage area with listed buildings, that home is worth 10.3 per cent more (which makes sense from even a quick glance at Zoopla). Similar research in Holland found new-builds that ‘look traditional’ sell for 15 per cent more than new modern-looking buildings.
Good design is ignored is because too many planners and architects who understand the system prefer shoddy innovative design, whilst large developers are effectively land speculators whose profits do not relate to the quality of what they build, and who need to simply churn out a standardised product to keep cash-flow operational, which makes standardisation more crucial than quality. Varying design would require investment in quality, investment that the sub-contracted out model of the major house builders find unprofitable.
Similarly, infrastructure was insufficiently dealt with, though the Government is at least increasing the levels of infrastructure spending. But I suspect many communities will still feel they do not have the support they need along with new homes. And while there was a positive nod to ownership, there needs to be even greater focus on new homes bringing what 86% of people want – affordable home ownership – to their area. The planning system will remain deeply complex – in fact under this NPPF it may be more complex and confusing. This cost and complexity will cripple the Government’s stated goal of supporting SME developers.
This NPPF needs fundamental changes
What was needed was boldness that sold people a vision, requiring genuine delivery from councils while giving local people genuine power over infrastructure and design, and ensuring new homes benefitted local people.
The housing crisis is undermining support for our economic system and even corroding the loyalty people feel to our society amongst the young and increasingly middle-aged. This NPPF actually goes backward from a 2017 Housing White Paper that, while a step forward, was insufficient. This NPPF needs serious revision or it risks not just being insufficient, but actually taking us a step back.