While lots of us were looking at the planning white paper  something else has been going on.

You may remember from an earlier article that the government has launched a consultation on replacing the current planning rules with a new system. You can comment until the end of October.  The features of this system include

  • Setting mandatory numbers of dwellings that councils must ensure are built in their area;
  • Categorising nearly all areas as suitable for either large or piecemeal development;
  • Automatically giving planning permission to certain types of housing;
  • The government setting a standard amount that developer would have to contribute to the community. This amount would have to cover infrastructure AND “affordable” housing.

But while we were focussed on that the government snuck out another document.  If you want to comment on this you will have to be very quick.  Comments must be in by 1st October.  Most of us missed this entirely, which may have been the intention.

These proposal are intended to be put in practice by amending regulations by the end of the year by amending regulations by the end of the year (paragraph 122), and probably to be missed (as we did) while we all get distracted by the white paper which will take a lot longer to put in to practice and on which the consultation does not close until 29th October!

It starts with all the similar nice things to the white paper, about how important it is to ‘deliver the housing people need’ so we have ‘happier more rooted communities, and how brownfield sites should be developed but also that for maybe 18 months, the requirement to provide affordable housing should be restricted to developments over ‘40 or 50’ houses rather than the 10 at present. (2) So that makes all the nice stuff about rooted communities completely irrelevant. This is because of covid 19 and will be ‘time limited’ (maybe?) so as not to ‘inflate land values in the longer term’(78). So they do understand something about how markets are manipulated?

The justification for cutting affordable housing when people are suffering economic hardship is to encourage SME’s, small and medium building firms (local employment and encouraging sites with permission to be built out more quickly, according to the white paper).  However these are not defined nor how large builders are to be prevented from snapping up the land in 50 plot bites. They do see there may be a problem there, (81) but offer no solution.

They deal with calculating affordability in relation to local wages but this ‘Changes’ document assumes that ‘the affordability of homes is the best indicator that supply is not keeping up with demand’ (31) but demand is not housing need. A lack of affordable housing may mean that the wrong houses, ie too expensive, as in Lewes, may have been built, and there seems to be no plan to prevent this indeed the over 40 plan positively encourages it. Fill up the best land with big houses to keep under the limit and not worry if they take years to sell, profits are coming in from elsewhere. Meanwhile the empty houses are a bankable asset.

They do have a First Homes idea, not unlike our Lewes Low Cost Housing, which 25% of the affordables should be, but this appears to be for owner occupiers. If you simply take the lack of affordable homes as indicating the need to build more house you will just go on filling up the South East with the wrong houses. You need to put the work where the people are in their ‘rooted communities’. Surely they have reduced the old union power enough to risk that by now?

As the key point in the white paper is that  everything should be allocated a planning zone it is interesting to note a dry run of this seems to have been tried in the form of a new introduction, a ‘Permission in Principle’ which developers can apply for without doing all the detail (how different is this actually from making a pre-application/pre-app?)  However anecdotal evidence tells them that the tiresome grownups in local authorities will go and ask about details like ‘transport’ (maybe even water supply and sewage) and even developers don’t seem to realise how much it would be to their advantage to apply for this. Now as developers are not known for missing out on potential advantages we would suggest that this would rather indicate that even they realise that there is more to identifying housing sites than drawing big outlines on maps or spotting a nice field on google earth.

At some point actual feasibility work has to be done and it takes time children. It iss not fair, they just wanted to build lots of lovely houses!  So this whole thing seems to have been written by some well-meaning 12 year olds (school project at Winchester or Eton maybe?) and tweaked here and there so that the lovely people at Persimmon and such will not be inhibited from making something out of the pandemic, because after all making something out of need is what they are for.

Opposition parties really need to get their teeth into these changes.