Concerns Over Under-Delivery as Councils Propose Staged Housing Requirements
A growing number of local planning authorities are producing local plans proposing housing targets on a phased trajectory, where annual completions increase at fixed points over the plan period. Some in the development community fear that the trend could make under-delivery of homes more likely.
David Murray-Cox, an associate director at consultants Turley believes: “for local authorities contemplating a big uplift in housing delivery, a stepped trajectory can make delivery of local plan numbers more achievable, thereby satisfying the National Planning Policy Framework (NPPF) test that plans should be aspirational but realistic.” Councils including Arun, Calderdale, East Cambridgeshire, Guildford, Melton, New Forest, Poole, Welwyn Hatfield and West Oxfordshire have all gone down this route.
The trend reflects many local authorities’ reliance on large strategic sites and new settlements, but the practice is not referenced in either the NPPF and PPG. Whilst draft guidance put forward by the MHCLG in March supported the approach “where justified”, this was not replicated in the final version released in July.
There have been mixed messages among the few inspectors to take on this approach. In June, Inspector Jonathon Bore claimed Guildford Borough Council’s proposal for a stepped trajectory was not acceptable. Bore stated the proposal would be contrary to government policy as the council’s approach would not deliver a sufficient amount of homes early enough to counter worsening affordability trends within the borough.
Inspector Mark Dakeyne’s report on the Arun Local Plan in July considered a stepped trajectory which would increase the annual target from 610 homes between 2011/12 and 2015/16 to 1,310 homes annually between 2020/21 to 2025/26, “justified by particular circumstances.” Amongst the confusion are calls for consistency. Michael Knott, a planning director at Barton Willmore said, “many in the development industry are struggling to reconcile the adoption of stepped trajectories with national policy to significantly boost the supply of new housing.”
The stepped trajectory approach to delivery is an essential shifting of under-supply to later in the plan period which is inviting a requirement to review the plan. The concern is that the application of the presumption in favour of sustainable development will be avoided as requirements are reduced earlier on in the plan period.