20 October 2017 by Mark Wilding
Commentators say that proposals for a standard formula to calculate housing need figures for neighbourhood plan areas where a district's local plan is out-of-date may reduce disagreements, but warn of unintended consequences.
Neighbourhood plan: consultation suggests that formula-based approach could be used to apportion need
More than six years on from the introduction of the Localism Act, and after the adoption of more than 400 neighbourhood plans, the government continues to tweak the neighbourhood planning system. Among the latest proposed changes, set out in last month's consultation on housing need, are proposals intended to help neighbourhood planning groups arrive at housing need figures in areas without an up-to-date local plan. The consultation document says that, if a local planning authority provides a housing need figure for a neighbourhood plan area based on an out-of-date plan, "any such figure risks being tested at the neighbourhood plan examination and so replicating the current debates on housing figures that can occur at local plan inquiries".
In such instances, a formula-based approach should be used to apportion housing need figures to neighbourhood plan bodies, the consultation proposes. Its suggested formula would take the population of the neighbourhood planning area and then calculate what percentage it is of the overall population in the local planning authority area. The housing need figure in the neighbourhood plan area would then be that percentage of the local planning authority's housing need, based on the proposed standard methodology formula, the document adds.
Chris Bowden, founder of consultancy Navigus Planning, said that scenarios such as the lack of an up-to-date local plan and changing housing need figures have been an issue, particularly in cases where neighbourhood plans are used to allocate housing sites. "(Neighbourhood planning groups) do all their work on sites then get ready for presenting them to the community and the community quite rightly say, 'how many are we planning for?' If you don't have that answer then you can't really consult with people. They pull the drawbridge up."
There have been attempts to offer a solution before. Two years ago, AECOM produced a guide to housing needs assessments for umbrella body Locality. Bowden said this has been useful, but that a government-sanctioned approach may be less susceptible to disagreements. However, he added that the extent to which the proposed formula represents good planning practice is up for debate.
"It's a relatively blunt tool," he said. "What it doesn't take into account of is the quality of supply of housing and sites. The danger is this doesn't take into account changing patterns of movement of people. A lot of neighbourhood plans are in more rural areas. Okay, there might be sites, you might say it's got a school, or shop, but then building 500 houses around a small market town or village, does it represent sustainable development? Is that the right approach?"
The government's consultation makes clear that the proposed formula "would still allow neighbourhood planning bodies to determine whether or not there are any constraints which prevent them from meeting this need". Gary Kirk, managing director at consultancy Your Locale, said this makes good planning sense. But he added that it may throw up some complications. "If one small parish argues successfully to have a reduced number, then presumably somewhere else has to have a greater number. In principle this is fine but there will still be elements of uncertainty. How does the local planning authority redistribute the additional houses that then need to be found?"
Kirk suggests that the government may need to define a fixed and limited number of constraints that neighbourhood groups would be allowed to take into account. If that can be achieved, Kirk sees clear benefits in adopting a standard approach, chiefly by avoiding disagreements when local authorities attempt to come up with their own methods. "In principle the notion of a national formula for distributing housing is a good starting point," he said. "It's a consistent formula across the whole country, therefore it's beyond the potential for local dispute. It's certainly transparent, it's consistent and it's clear as to how it's been arrived at, which would remove the opportunity for local groups to say, 'we don't fit this category, we don't have that requirement'."
However, there may be another problem to be overcome. The government's approach proposes using population figures. But the nature of neighbourhood planning areas might make those numbers hard to come by. "Many neighbourhood plans, particularly in urban areas, are quite deliberately not following the normal political boundaries," said Tony Burton, planning consultant and founder of Civic Voice. "That makes it all the more difficult to get the evidence and information from the census. It demonstrates that there is no pure science."
Ultimately, Burton believes a standard formula may be at odds with the aims of neighbourhood planning. "The whole idea is to put more power in the hands of local people. This is taking power away." That, he said, could have serious ramifications. "It will stop neighbourhood planning in its tracks in some areas of the country," he said. "In others it will provoke very significant disputes. There will be bust-ups that will inevitably fall for examiners and local authorities to resolve. And it will put people in quite a difficult position."