A planning journalist has asked for my views on the proposal in the planning reforms/NPPF consultation that the Standard Method-derived housing number becomes ‘advisory’ only. Do I think it will mean councils will plan for fewer homes?
For me the ‘advisory’ thing is not that significant a change. The important change here is what follows later in the paragraph – the extent to which it will be easier/clearer for councils to calculate a housing need number using an alternative approach.
“The important change here… is the extent to which it will be easier/clearer for councils to calculate a housing need number using an alternative approach”.
Many councils are already considering alternatives to the Standard Method. My colleague Rachael Ferry-Jones and I have been advising councils considering it. We’ve found that one of the issues is understanding the difference between housing ‘need’ and ‘requirement’. The terms are often incorrectly used interchangeably (including by myself). Below I have set out some thoughts based on the discussions we’re having with councils and weaved into this my thoughts on the NPPF consultation.
The basics aren’t changing
I think it’s helpful to start with what isn’t changing – the way that housing numbers in plans are arrived at. The indicative changes to the NPPF wording in Para 61 include additional wording that states that the ‘outcome of the standard method is an advisory starting-point’ mphasis).
Planning Practice Guidance (PPG) currently says: ‘Authorities should use the standard method as the starting point when preparing the housing requirement in their plan’. In my view not a lot has changed; the word ‘should’ in the PPG is there in the sense that it is the recommended (but not the only) approach. The word ‘advisory’ is being used similarly to indicate that (as has ever been thus) that this number is not necessarily the number you have to plan for.
The number you have to plan for is the housing ‘requirement’ – the number that you end up with having taken the ‘need’ figure and considered the effect of constraints etc. before reaching the final figure.
We’ve been using this when we talk to councils:
Exceptional Circumstances to become ‘Local Characteristics’(?)
Hence, to my mind, the most significant change is not so much the Standard Method-derived number becoming ‘advisory’. It is how ‘exceptional circumstances’ (to justify using an alternative approach) will be re-cast that is of most significance. At the moment ‘exceptional circumstances’ aren’t defined, and from the advice to councils that I have seen, they face an almost impossible task to justify/establish that circumstances exist exclusively to/in a single place.
The NPPF proposed wording also says: ‘… also propose to give more explicit indications in planning guidance of the types of local characteristics which may justify the use of an alternative method, such as islands with a high percentage of elderly residents, or university towns with an above-average proportion of students’.
It appears that the term ‘exceptional circumstances’ is going to be dropped in favour of ‘local or (‘particular’) characteristics’. The students thing alone opens this up considerably for many places. The ‘more explicit indications’ could create a clearer route for councils to decide whether they are in a position to use their own approach to calculating housing need.
Yes this number may be lower than that derived from the Standard Method, but it isn’t guaranteed, and still needs to be agreed – how low is low enough?
Yes, an alternative approach may yield a number lower than that derived from the Standard Method, but it still a starting point and isn’t guaranteed to be lower. The number still needs to be agreed – how low is low enough? It still needs to be deliverable. And whatever method is eventually used it needs to be evidence based, reflecting current and future demographic trends and market signals and, for now, don’t forget the ‘unmet needs’ of neighbouring areas.