Policy pitfalls preventing cities from delivering against a boosted housing need.
The most recent iteration of the National Planning Policy Framework (NPPF) retains an uplift in housing need across the 20 largest cities in England, with an expectation that need is accommodated within the urban centres themselves, or through strategic cooperation with neighbouring authorities.
Cities across the country are consistently failing to meet these thresholds, between them accounting for almost all of the national shortfall in delivery against housing need. Neighbouring authorities can help to share the burden by contributing to housing targets. However, the wider strategic planning processes that are needed to achieve this have largely failed due to a range of reasons including lack of political support and uncertainty over national policy.
Recent revisions to the NPPF could have addressed this issue in sharper focus, ensuring that future Local Plans were delivered not only with robust targets, but with a renewed commitment to strategic planning across city regions. The lack of commitment to strategic planning in the NPPF is a barrier to greater cooperation and coordination across local authority boundaries, delaying progress towards a meaningful reduction in the current national housing shortfall.
Missing the mark
Delivery of new homes on brownfield land has been a big focus for the Conservatives since the Coalition Government. The most recent iteration of the standard method for calculating housing need, published in 2021, was updated to encourage this, applying a 35% up lift to the 20 largest cities in England. Between them, these cities currently have an annual housing need of 128,700 homes, 43% of the total figure for England.
Unfortunately, delivery rates have not accelerated to meet these ambitious targets. Over the past three years, the cities built an average of 63,200 homes per annum, just 49% of their annual housing need under the standard method. The lack of delivery in these cities accounts for 90% of the country’s total shortfall against housing need, with London alone making up 66% of the deficit.
At present, the 20 cities are planning for a combined total of 65,200 homes per annum. Since March 2021, an average of 83,200 homes were consented each year, creating a 28% cushion against this target. This has resulted in average delivery of 63,200 homes per annum, just 3% below adopted requirements.
So targets adopted in local plans are broadly being met, but the targets don’t incorporate a 35% uplift from the standard method, and therefore don’t meet housing need. This creates a gap between new home delivery and Government ambitions for 300,000 homes per annum.
Everybody needs good neighbours
Authorities neighbouring the top 20 cities are not accommodating unmet housing need. Between them, these local authorities are currently planning for 56,400 homes. This is 8% below their combined housing need of 61,000. This means that the 65,600 homes not being delivered within the top 20 cities are not being planned for delivery anywhere else.
There are two key challenges that prevent neighbouring areas from accommodating unmet need. These include the reduced availability of land, and a lack of joined up planning between authorities.
Flood Risk, Natural Landscapes, Sites of Specific Scientific Interest, Heritage Land and National Parks are just a handful of designations that restrict deliverable land to a selection of channels and corridors.
Sufficient infrastructure capacity is a further constraint, whether that means road capacity, access to the power grid, sufficient water resource or rail access to the urban centre.
Outside of these issues, a key consideration is Green Belt, which borders 14 of the 20 cities targeted through the standard method uplift.
Green Belt is solely a policy constraint, but it covers 36% of land in authorities neighbouring the top 20 cities, so strategies aimed at meeting unmet housing need will typically require a Green Belt review. Differences in political control across city regions can make this challenging.
Of the 20 urban areas across the country, 19 are Labour-led, either having the most councillors or through Mayoral powers. The surrounding authorities typically differ in control, and conflicting views between neighbours can create barriers to strategic decision making. Efforts to overcome this have had little success in recent years, with four joint strategic planning initiatives collapsing in 2022 alone.
Case Study: The West of England conundrum
As with many cities across the country, Bristol is now facing higher housing need hurdles, and difficulties in distributing need across the wider market area. Over the past three years, Bristol has delivered an average of 1,861 homes per annum, just 55% of local housing need under the standard method.
With limited options for delivery within the local authority boundary, the city may be looking for support from Bath & North East Somerset, North Somerset, and South Gloucestershire. Without a greater level of collaboration between these authorities, new home provision that meets the city’s housing need remains unlikely.
Constraints in Bristol and surrounding areas