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29.07.2024

Expectation Management: Labour, planning reform and the state of things as they are

According to recent press reports in The Times and The Guardian, Labour will unveil the next piece in it's planning reform agenda on Tuesday: An eight week consultation on a revised NPPF.

I am going to save my comments until the consultation opens. Thankfully, Zack Simons has already summarised the weekend briefings for us in a handy LinkedIn post. To quote Zack, on Tuesday we are expecting an:

  • "8 week consultation, new NPPF adopted late September.
  • “Mandatory housing targets” going up by 50%.
  • That’s a circa 100,000 home national increase to what we now call “local housing need”. Changes include: (i) “toughened” affordability ratios “to take account of how many people might move into an area if housing was cheaper”, and (ii) no use of “previous oversupply of housing to reduce future targets”.
  • Councils “must review protections for the green belt if they cannot meet their housing need on brownfield land”.”

The article also mentions changing nutrient neutrality rules to move compliance with the Habitat Regulations from pre-commencement to pre-occupation, however that would require legislative change*, so even if it features in Tuesday's consultation it is unlikely to happen that quickly.

The point of this post, however, is a little different. Given all of the excitement surrounding the new Government and it's agenda, it can be easy to forget where things stand at the moment.**  This post is intended to serve as a small dose of reality.

To call the current state of our planning system ‘challenging’ would be a polite understatement.

Planning is a function of local government and local government is struggling. Badly. According to the National Audit Office, total spending power for local authorities fell by 26 per cent between 2010/11 and 2020/21. In February, the Local Government Information Unit reported that half of local authorities in England anticipated having to issue a Section 114 notice in the next five years.

This financial pressure has lead to significant cuts in resources for planning departments. The Institute of Fiscal Studies has calculated that between 2010 and 2020, real terms spending by local authorities on planning and development fell by 58%. This translates not just to fewer planning officers, but also fewer ecologists, architects, lawyers, heritage and design officers available to support them. At a time when planning has become more complex and involved than ever before.

This is not something that can be turned around quickly.

Even if Labour could just turn on the spending taps*!, planners, architects, ecologists, lawyers etc. all take time to recruit and train. Rebuilding capacity and resources in the public sector requires a long-term view. It is not something that can be achieved overnight. Three hundred additional planning officers is a good start, but that is all it is. A start.

When it comes to house building, we are in a similar situation. Labour's promised house building (r) evolution is starting from an extremely low base. 

Housing starts and completions are down. The latest MoHoLoCoGo figures show that "between 1 January and 31 March 2024, the number of dwellings where building work has started on site was 22,310 (seasonally adjusted). This is a 11% increase when compared to the previous quarter and is a 41% decrease when compared to the same quarter of the previous year.

The number of dwellings completed was 34,630 (seasonally adjusted). This is a 12% decrease when compared to the previous quarter and is a 12% decrease when compared to the same quarter of the previous year."

Regardless of how effective Labour's policy reforms turn out to be; these numbers have further to fall.

There is a very simple reason for this. The  number of permissions being granted for residential development has also been falling. 

The HBF's latest Housing Pipeline Report showed that in the 12 months to March 2024, the number of planning permissions granted for new homes was at it's lowest level in almost a decade. The number of units achieving planning permission in the year ending Quarter 1 2024 represented the lowest 12-month total since Quarter 3 2014. Year on year, that represented a 13% drop, and a 22% reduction on the year to Quarter 1 2022.

Even if the promised revisions to the NPPF had an immediate positive effect, it will take time for the new influx of planning applications to be granted and yet longer for construction to begin. There is an inevitable time lag between the grant of consent and the delivery of new homes that cannot be avoided.

And that is before we get into the wider constraints posed by:

  • A lack of grid capacity
  • Water scarcity
  • Nutrient and water neutralities
  • Flood risk and climate change adaptions; and 
  • Lack of capacity in the construction sector (largely, but not exclusively, due to a shortage of construction workers).

The impacts of which extend far beyond the housing sector. In fact, they impact all types and forms of development - including logistics and renewable energy schemes.

In short, by all means be optimistic, hopeful, excited even, but do not underestimate the scale of the problems that these reforms are attempting to address. Nor the time it will take for the impact of the changes to be felt on the ground. 

Regardless of how effective Labour's planning reform agenda turns out to be, in the short term at least, things are likely to get worse before they get better.

Right. Now, I have got that off my chest, it is time to stop being a storm cloud… and get ready for the first major planning consultation of the Labour government. Caffeine machines at the ready. It is going to be a busy week!

 

 

 

*And would only really enable the implementation of consent that would otherwise time-out. So it is more a means of buying time, and preventing consents from lapsing entirely, than an actual solution.

** I do not exclude myself from this. This post might be the blogging equivalent of having a quiet word with myself.

*! Which we are reliably informed that they cannot.

On Tuesday Rayner will announce an eight-week consultation on reversing a
string of changes to planning rules made by the Tories, which Labour says has
slowed the pace of housebuilding.
A return to mandatory local housing targets will be centrepiece of the change,
after the Tories made local assessment of need advisory only.
As part of a “growth-focused approach to the planning system” Rayner is also
planning to change the way housing targets are calculated in a way that will lead
to “significant increases” in many areas”