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Surprise, surprise! Kent’s environment suffers the failings of flawed government planning policy
Richard Thompson, CPRE Kent planner, shows how developers benefit from their own failure to build houses while our communities lose ever more green space
While the Housing Delivery Test might seem a dull and dry topic, often buried in the darkest, deepest recesses of a council’s website, its consequences should not be ignored.
When CPRE Kent reported on the 2019 Housing Delivery Test results, it was a bleak picture. Well, last month the 2020 Housing Delivery Test results were published. And the situation for Kent has worsened yet further.
The test works by comparing how many homes have been built in each council district against how many homes the district is deemed to have needed over a three-year period (though reduced this year for a month to allow for the impact of the Covid-19 pandemic).
These homes-needed figures will either come from a council’s Local Plan if it was adopted within the last five years or, more commonly for Kent, be based on the government’s ‘top-down’ standard method formula for calculating housing numbers.
If at least 95 per cent of the homes deemed needed have been built within a council’s district over that period, the council is regarded as having passed the test.
More than 85 per cent though less than 95 per cent, the council is put on the naughty step and has to write an ‘action plan’ in which it promises to try harder.
If less than 85 per cent though more than 75 per cent, the consequences become serious as an extra 20 per cent is added to the number of homes that will need to be built in that district. This makes it increasingly hard for councils to demonstrate they have a five-year supply of houses – and where a council cannot demonstrate a five-year supply it becomes subject to the “presumption in favour of sustainable development”.
If fewer than 75 per cent of homes deemed needed have been built, that council area automatically becomes subject to the “presumption in favour of sustainable development”. This means that if a site can be considered to deliver ‘sustainable development’, then planning permission should be granted, even if there is no support from the council for housing in that location or the site sits outside the Local Plan.
As set out in the table below, the combination of the 2020 Housing Delivery Test results and accepted lack of five-year supply by councils now means the majority of Kent is subject to the presumption.
Further, Canterbury, Dover and Folkestone and Hythe are all in precarious positions should developers seek to challenge the five-year supply position (note that both Canterbury and Tunbridge Wells only just avoided falling into the 20 per cent buffer requirement because of the Covid adjustment).
What does this mean in practice? Only that the majority of Kent is now at increased risk of speculative planning applications for developer-led interpretations of ‘sustainable development’.
CPRE Kent has long campaigned that the standard method for calculating the number of homes is a blunt instrument that fails to recognise local constraints and actual housing needs. Yet the revision made to the standard method in December 2020 is likely to further increase pressure on Kent to take some of London’s deemed increase in housing need.
It is also our view that the Housing Delivery Test and five-year supply requirements are fundamentally flawed.
The reality is that the supply of homes is all but controlled by the housebuilders, who clearly will only build what the local market will absorb. Yet if this building rate falls below these unreasonable targets, often the only response a local authority can have is to grant yet more planning permissions or allocate yet more land for increasingly unsustainable development.
And so the cycle continues.
Or, put another way, while the development industry is rewarded for failure to build houses with an increasing suite of sites where ever-greater profits may be made, communities suffer the real-world consequences of yet more precious green spaces being allocated for development.
Friday, February 12, 2021
- 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
