Delivering First Homes - Exception and Rural Exception Sites

We have recently read a LPA S.78 planning appeal statement of case that claims that the housing needs assessments produced by the LPA “ are a robust examination of housing need ”. The LPA considers that its HNA’s are exemplary and should be replicated. Only their methodology would be accepted as robust evidence of need.

Following our assessment of the example of its robust housing need assessment supplied by the LPA that accompanied the statement of case (therefore in the public domain), we can confidently say that the HNA is neither robust nor does it meet the LPA’s own policy for evidencing need for a rural exception site! How inconvenient for the LPA.

There are 4 fundamental issues with the LPA’s preferred methodology;

1) The first fundamental issue is that the HNA makes no reference to supply.   An assessment of supply is necessary. Logically, the snapshot of households in affordable need is not the same as the number of additional homes that are needed.   The LPA fails to take into account that supply from vacancies is likely to occur to mitigate the measure of need. Have any planning consents been granted that amount to committed development that will help to address the outstanding need?

2) The second fundamental issue is that the LPA relies on a headcount of households i.e. at the point the survey was undertaken X households were in housing need. Somehow the number X is interpreted as the level of need ignoring the fact that only a small proportion of households actually completed the survey, and that housing need is in fact a flow of households measured over time. The flow over time provides a further dimension to the assessment (turning the circle into a sphere).

3) The third fundamental issue is that the LPA survey questionnaire even fails to ask if the household in need is seeking to remain living in the parish or is planning to leave it!   Therefore evidence is questionable to support the council’s policy requirement to demonstrate that need for local housing exists.

4) The fourth fundamental issue is that house prices and rents are not fully analysed or described in the report. The report is ambiguous about prices and there is no clarity about how the test of affordability is applied. This is crucial to the credibility of the report.

The problem is that 80% to 90% of HNAs in circulation on England are produced by LPAs or rural enablers and none of them are robust as they are all rely on a similar methodology.

So why the disc to sphere analogy? Because measuring the flow of need over time adds an extra dimension which most thinking people recognise as true!

Our full critique of the LPA one dimensional HNA can be found at the following link. It makes fascinating reading. https://www.cnbhousing.co.uk/independent-expert-witness-services

For follow up reading we recommend  the various publications of philosopher and astrophysicist Neil DeGrasse Tyson who applies deep thought to belief systems and subjectivity.

Last year, a parish council client commissioned us to undertake a housing need survey (HNS). A HNS was required because the client felt that recent development proposals were not in line with the perception of local need.    

We had an excellent public response to the survey and produced relevant data. Once our report was written, we supported the client to ensure that there was a full understanding of the data and our findings. The findings showed that the needs of a number of household groups resident in the parish were not being met and that this was likely to adversely impact on the community.  

We have recently been informed that a development proposal has come forward that exactly meets local need as evidenced by the HNS. This can now go through the planning process with the support of objective local evidence.

Of course, if the development proposal didn’t meet local need, the parish council now have the evidence to resist the development.

Please get in touch to have an informal discussion about how we can support neighbourhood planning processes and outcomes.

A report that has piqued our interest is the Richard Bacon’s review of scaling up self and custom build housing (the ‘Bacon Review’).

The Bacon review, authored by MP Richard Bacon, is an independent review into scaling up self-build and custom housebuilding, as a contribution to resolving our housing crisis. This report was commissioned by the Prime Minister, and written and covers every aspect of self-build and custom housebuilding, from the advantages and disadvantages, to the process; issues one might find along the way; and how we could approach it better as a country.

We have taken a great interest in self-build and custom housebuilding over the years and in the course of our work we have reviewed many local authority registers, as well as had discussions with land agents, local authorities, house builders and registered providers on the subject. 

We have formed the view that the role self-build and custom housebuilding is undervalued by the general public and some local authorities. This is because it is self-evident that historic self-build and custom housebuilding has been the key factor in shaping some of our most distinctive and characterful towns and villages especially in rural areas which is of particular interest to our consultancy.

So here are a few observations stimulated by selected findings of the review.

Thanks to the BBC for broadcasting the 8th November edition of Start the Week, presented by Andrew Marr. The show talked about how the generations differ in several ways including employment, economics and housing. One of the excellent contributors was Bobby Duffy, Professor of Public Policy and Director of the Policy Institute at King’s College London, a generational analyst who’s most recent book explores many aspects of how the generations differ and the implications of this.

I am a Baby Boomer and have worked in housing for over 40-years. I got a mortgage and became a homeowner in my early 20s, had a secure job with an occupational pension.  So the show grabbed my interest. From the show I learned about the other generations and quickly realised that with children and grandchildren and maybe more grandchildren in future I could relate to other generations. It’s worth defining the generations:

Local planning authorities will soon be faced with assessing NPPF compliant planning applications that involve the Government's new 'First Homes' scheme as well as other Affordable Home Ownership (AHO) products.

There is generally little evidence of such need within existing housing registers or waiting lists. Also, some councils are making assumptions about the level of need using older, out of date evidence bases that precede the current NPPF.  

Our view, based upon our recent local household surveys, is that demand for First Homes and the 2021 Help to Buy scheme will be strong thanks largely due to the popularity of the outgoing Help to Buy scheme. But how can the demand be quantified? Will the housing provided be truly affordable to those that aspire to it? What value is a 30% discount if the discounted price is not generally affordable to local households?

CNB Housing Insights can help answer these questions. 

Nearing the end of a tumultuous year, CNB Housing Insights are taking stock of the chaos of 2020 and the challenges it has presented for the housing world.

This is the year that everything changed. A pandemic swept across the whole globe, reshaping our daily lives and causing a heart-breaking amount of loss in it’s wake.

CNB Housing Insights is particularly interested in the impact the pandemic has had on the housing market.

The following line chart reveals the numbers of residential sales over the value of £40,000 in the last four years [1]. The purple line tells a fascinating story, pinpointing the exact moment England came to a standstill. In April, 32,400 sales took place. As the country started coming out of hibernation (AKA Lockdown 1.0), October saw an increase of sales by 213%.  The figures for house sales in August-October are provisional so far, but October saw sales of c.101,000. This figure hasn’t been topped since the mad rush to beat the SDLT rule change back in April 2016   that effected individuals wanting to purchase second homes [2].

Current National Planning Policy Framework defines affordable housing as ‘ housing for sale or rent, for those whose needs are not met by the market (including housing that provides a subsidised route to home ownership and/or is for essential local workers) ’ .

One of the recent announcements made by the government was a pledge to provide much needed increased funding to neighbourhood planning groups in urban and deprived areas. With the pot increasing from £10,000 to £18,000, starting this week to help improve deprived areas, neighbourhood planning groups will be keen to put this money to good use on behalf of their local communities.

As part of this announcement, the government also stated that these groups will be provided with access to technical expertise free of charge, which includes advice on housing needs assessments presumably via Locality and its partners.  

What about CNB Housing Insights? 

“The Locality Toolkit is a starting point for neighbourhood planners to get a broad brush understanding of local  housing issues, but you very rapidly realise that the toolkit doesn’t give you the real insights into what the local housing problems are, who it affects and the scale and type of housing that is required. This finer information is the only real foundation for neighbourhood plan policies to address the issues and ensure that appropriate housing is provided on a scale that is actually needed.”

Locality offers basic facts and a one size fits all methodology for assessing local housing needs. If you really want to understand where the gaps and surpluses in your housing stock are in order to meet the needs of local residents, you need a robust survey and expert analysis. The additional government funding enables CNB Housing Insights to provide this detail to assist the communities that need it the most, within the reach of neighbourhood planning budgets. 

What additional value does this expertise bring? In all of our neighbourhood planning related evidence bases we have described what is driving the need for additional housing locally and quantified any gaps in local housing supply that might exist. This is crucial if younger and older people are to be retained in their communities for both their benefit and the wider sustainability of local communities. Neighbourhood planning inspectors have never doubted the robustness and relevance of our work.

 CNB Housing Insights can provide a detailed, bespoke Housing Needs Survey. Additionally, we would welcome the opportunity to widen the scope of the evidence base to support local policies on affordable home ownership, design standards, space standards and innovations such as co-housing.

 Pick up the phone to Chris on 07809 625636 for an informal chat about how CNB Housing Insights can support your community.