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Unrealistic housing targets threaten countryside
We are calling for an overhaul of the way local authorities set housing targets in order to stop countryside being lost unnecessarily.
Extensive research commissioned by CPRE has shown that local authorities are in effect being asked to base their plans on aspiration rather than need, which is resulting in ever higher housing targets and the consequent, unnecessary release of countryside for development – without resulting in an increase in overall housebuilding.
In Kent many of the targets are unrealistic – e.g.18,560 homes planned for Maidstone, 15,600 for Canterbury and 15.600 for Thanet. The total for the county is around 165,000. Kent does not have the infrastructure for these additional homes, the impact on the countryside and environment will be devastating and irreversible.
Among a large number of problems with how the targets are calculated [1], the research found a lack of clear guidance in the process, a lack of objectivity in the calculations, and a lack of concern for land availability and environmental impacts.
The research demonstrates that the unrealistic targets are putting undue pressure on the countryside. Setting targets far higher than what can be realistically built just means that developers have more sites to choose from: as static building rates show, higher targets do not mean faster delivery [2]. The disastrous consequence is that when these unrealistic targets are not met, councils have to identify even more sites for housing, and ever more countryside is released for more lucrative development while brownfield sites go unused [3].
Matt Thomson, head of planning at CPRE, said:
“It is vital that we build more homes, but this will not be achieved through ever higher housing targets based on ambition rather than actual need. The current process is not only highly damaging to our countryside and the environment in general; it is also damaging to community well-being and extraordinarily frustrating for local people.
“Through its planning inspectors and the threat of expensive appeals, the Government is taking a top-down approach to impose and enforce housing targets – despite ministers calling for more localism. Instead, we need to see a more accurate definition of community need at the heart of all local plans, and more consideration for environmental concerns and land availability. Councils should not be penalised for failing to meet implausible ambitions for growth over and above actual housing need.”
To illustrate the unrealistic nature of the housing targets, CPRE has analysed the local plans passed in the past two years that have contained a new housing target. In those 54 local plans, the average housing requirement is 30% above the Government’s household projections, and 50% above the average build rate. Only seven of the 54 targets take environmental factors into account.
To ensure that we build the homes we actually need in the right places, CPRE is calling for community surveys to play a far greater role in determining true need; for available brownfield land to play a leading role in developing targets; and for planning guidance to include a clear definition of housing need that is designed to support those who lack housing, and to ensure local plans specify what kind of homes will meet this need.
To read the full CPRE report click here.
[1] At the heart of these issues is the requirement for local authorities to identify the need for housing and then meet that need in full in their local plans. The National Planning Policy Framework (NPPF) sets out how to determine “objectively assessed housing need”. Online Government guidance in the National Planning Practice Guidance (NPPG) provides a recommended approach to deciding” objectively assessed need” through a Strategic Housing Market Assessment (SHMA).
[2] Government data show that 242,000 houses were given planning permission in the year up to June 2015. Yet housing starts and completions show little sign of matching this number. Quarterly statistics on housing starts show that building rates have been static since the beginning of 2014 – at around 136,000 per year. The latest data show completions are currently at 131,000.
[3] The situation is then made worse because if housebuilding in an area falls below these five-year targets, the local plan that contains these targets – and the protection for land not classed as suitable for housing – no longer applies. Once that happens, local authorities can be forced to allow house building on greenfield land, whether it meets a community’s needs or not.
Meanwhile, CPRE’s 2014 report From wasted space to living spaces found that at least a million new homes could be built on suitable brownfield land across England, and that brownfield land is a self-regenerating resource. CPRE, From wasted space to living spaces, November 2014.
November 17th 2015.
- 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
