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Russell Crowe provides an initial response to the Government’s Housing White Paper

Now that the dust has settled and we have had an opportunity to fully review and consider the Government’s Housing White Paper, we broadly welcome the acknowledgement that the housing market in this country is broken, and the clear statement that the starting point to resolving this is to build more homes. 

We do however have some concerns over the approach being taken to tackle the issue and will be responding fully to the Government’s consultation in the coming weeks.  In the meantime, below we consider seven key points in the report, with recommendations for areas that should promptly be addressed.

Making sure every community has an up-to-date, sufficiently ambitious plan

Richborough Estates broadly support the intended simplification of the Plan-led system and the proposals to boost the capability and capacity of planning authorities in order to regularly review Plans.  We do however have concerns over the implementation of the duty to co-operate and whether the introduction of a Statement of Common Ground between authorities will tackle the issue of delivering unmet needs.

If the Examination process is to be simplified and the tests of soundness amended to remove the need for a ‘sound’ Plan to contain ‘the most’ appropriate strategy, then we consider that it would be appropriate to increase the level of flexibility incorporated into new Plans through the provision of additional sites for delivery, or reserved for development should Plans fail.

Assessing housing requirements

The proposed standardised approach to assessing housing need would be a positive step in speeding up the Local Plan Examination process and the principle of this is supported.  If such an approach can also be robustly utilised to set appropriate housing targets at the Parish level to inform neighbourhood plans, then this would also be welcomed.  We look forward to seeing further details of such measures in due course.

Amendment to the presumption in favour of sustainable development

The proposed amendments to the presumption in favour of sustainable development are supported and the intention to make ‘footnote 9’ policies a closed-list is seen as a sensible progression of this area of policy, which will help to increase clarity in the decision-making process.

Green Belt

We welcome the clarification from Gavin Barwell MP at the Birmingham leg of his ‘Housing White Paper tour’ that the document is not a strengthening of Green Belt policy, but instead an articulation of the exceptional circumstances test that the Planning Inspectors already use in assessing Local Plans which include Green Belt releases.  Sensible and proportionate levels of Green Belt release are in our view fundamental to achieving sustainable growth patterns across the country.

Types of sites

The Housing White Paper sets out the Government’s broad support of a range of sites, including smaller sites of less than 0.5ha, previously developed land and new garden towns and villages.  Whilst we appreciate that sites across the full spectrum of typologies and scales need to come forwards if the housing crisis is to be remedied, it is important that the Government does not prioritise such sites ahead of sustainable greenfield sites being delivered, as in the vast majority of local authority areas these are the sites that are delivered promptly and form the bulk of the immediate housing land supply.

Fixing five-year supply

The proposal to fix annually the five-year housing land supply is not seen as a positive step in tackling the housing crisis.  Should an authority have a marginal supply position then it is important that this can be tested throughout the year in order to understand if the assessment made at 1st April is fulfilling housing deliver during the year.  Removing the ability to critique housing land supply during the year has the potential to artificially delay any shortfall being remedied.

The housing delivery test

We welcome the intention to test a local authority’s past housing delivery, and introduce a presumption in favour of sustainable development.  However, we consider that the levels proposed to test delivery and trigger the presumption (25% at November 2018, 45% at November 2019 and 65% from November 2020 onwards) are extremely modest.  Given the scale of the issue at hand, we consider that this should be significantly higher – if not 100% - and will set out our position in our full Housing White Paper response.

Furthermore, given that the housing crisis is not a new issue, we do not consider it appropriate to tier the requirement in such a drastic way.  The need to significantly boost the supply of housing is a long held Government priority, and in locations where this has not happened we do not consider that a further 3 years and 9 months grace period should be granted until the full housing delivery test is applied.

28 February 2017