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Housing delivery test: what it means for Kent
Last week’s announcement
of results from the 2019 Housing Delivery Test looks at first like very dry
reading, but for some Kent districts the consequences could be far-reaching.
The Test was
introduced when the National Planning Policy Framework was revised in 2018. The
NPPF sets high targets for the number of homes for which each area must plan, and
the Test measures how well each district is doing at delivering those homes.
There is no
doubt we need to build more homes, but the method for calculating the number
required in each district is a blunt tool and one that takes little account of
local housing needs or constraints.
The targets
are based on statistical growth projections that are then adjusted to take into
account the local affordability of houses.
Put simply,
in Kent, where property prices are high and local full-time salaries tend to be
relatively low, it means housing targets calculated in this way exceed the projected
household growth and far outstrip the rates at which the building industry
delivers housing.
Housebuilders
only complete houses at the rate they know the local market will absorb them;
there is simply no incentive for them to build any faster just to address local
need.
What do the
housing test results mean in practice? Across Kent, only four districts
(Dartford, Maidstone, Shepway and Tonbridge & Malling) can demonstrate they
are meeting these targets.
All the rest are to have sanctions applied that mean they must either demonstrate an action plan demonstrating the steps they will take to meet those targets (Ashford, Canterbury, Dover and Tunbridge Wells), or they must take steps to allocate yet more sites to build 20 per cent more homes over and above the existing targets (Gravesham, Medway, Sevenoaks and Swale).
Thanet, meanwhile, is one of eight local authorities across the country that fails the delivery test to such a spectacular degree that it is now officially required to adopt a presumption in favour of all housing development. This means that speculative planning applications which would normally never be accepted as sustainable or desirable must be, in large part, given a green light.
The irony, of course, is that local authorities are being penalised by having to allocate sites not in their Local Plan, and which are sequentially less and less sustainable, when the rate of delivery and release of homes is entirely within the hands of the development industry and beyond the control of local authorities.
It is iniquitous that local authorities – and more importantly local communities –must suffer from ever-more green spaces being allocated against targets which remain unreasonable.
This is the very opposite of good town planning.
Monday, February 17, 2020
- A number of important documents have yet to emerge. For example, a rigorous transport plan and a finalised air-quality assessment. The latter is critical given that allocations at Teynham will feed extra traffic into AQMAs.
- There seems to be no coherent plan for infrastructure delivery – a key component of the plan given the allocations being proposed near the already crowded Junction 7.
- There seems to have been little or no cooperation with neighbouring boroughs or even parish councils within Swale itself.
The removal of a second consultation might have been understandable if this final version of the plan were similar to that being talked about at the beginning of the consultation process. It is, however, radically different in the following ways:
- There has been a major shift in the balance of housing allocations, away from the west of the borough over to the east, especially around the historic town of Faversham. This is a move that raises many concerns.
- A new large allocation, with accompanying A2 bypass, has appeared around Teynham and Lynsted, to which we are objecting.
- Housing allocations in the AONB around Neames Forstal that were judged “unsuitable” by the council’s own officers have now appeared as part of the housing numbers.
- Most of the housing allocations being proposed are on greenfield sites, many of them on Grade 1 agricultural land – a point to which we are strongly objecting.
Concerns about the rush to submit the plan
The haste with which the plan is being prepared is especially worrying given the concentration of housing in Faversham. If the town is to take a large amount of new housing, it is imperative that the policies concerning the area are carefully worked out to preserve, as far as possible, the unique nature of the town. The rush to submit the plan is likely to prove detrimental.
As Swale does not have a five-year land housing supply, it is open to speculative development proposals, many of which would run counter to the ideas contained in the current plan. Some are already appearing. This is a common situation, and one that, doubtless, is a reason behind Swale’s haste.
Our overriding fear, however, is that this emphasis on haste is ultimately going to prove counterproductive. This is because it is our view that the plan, in its current form, is unlikely to pass independent examination. We are urging Swale to listen to and act upon the comments being made about the plan and to return the plan to the council with appropriate modifications before submitting it to the Secretary of State.
Essentially, this means treating the current consultation not as the final one but as the ‘lost’ second consultation.
The consultation ends on Friday 30 April and we strongly urge residents to make their opinions known if they have not already done so.
Further information
