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The Consequences of an Absence of Housing Targets in Relation to Levelling up and Regeneration

Matt Hare, Partner at Carter Jonas (Cambridge), comments

Under its many guises – three Prime Ministers and three Secretaries of State for Levelling Up, Housing and Communities – the current Government has been resolutely committed to growth. But to varying degrees, those responsible for housing delivery have edged away from the 2019 manifesto pledge to deliver 300,000 homes per annum.

Liz Truss set out to remove so-called ‘Stalinist’ housing targets; whilst until recently, Michael Gove, as the re-appointed Secretary of State, has been more acquiescent, suggesting that that the target remained but the calculation and implementation would be ‘rebased.’

We now know that Gove’s proposition is in fact not to tinker with the Standard Method for calculating housing need just yet. Instead his proposals (as set out in the draft revisions to the National Planning Policy Framework) are potentially more extreme. To recap, the key proposed changes regarding housing targets are:

  • Proposed additional caveats would allow for lower levels of housing to be planned in situations in which meeting full needs would result in adverse impacts, such as building at densities significantly out of character with the existing area, or where there is clear evidence of past over-delivery in terms of the number of homes permitted compared to the housing requirement in the existing Local Plan. In such cases this over-delivery may be deducted from the provision required in the new Plan.
  • Green Belt boundaries would not be required to be reviewed and altered if this would be the only means of meeting the objectively assessed need for housing over the Plan period. It will be a matter for the individual local planning authority (LPA) as to whether such a review takes place.
  • The duty to co-operate would be replaced by a future ‘alignment policy’, and plans will no longer be required to be ‘justified’.
  • Where the housing requirement is less than five years old, LPAs would no longer have to demonstrate a five-year housing land supply.
  • Some LPAs with well advanced Local Plans will only need to demonstrate four years’ housing land supply instead of five years, for a period of two years from the point that the proposed changes to the Framework take effect. 

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