The SDRA have responded to the Government’s consultation on changes to housebuilding targets as below.

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Stoke D’Abernon Residents’ Association
Stoke D’Abernon, Cobham, Surrey
22nd September 2024

Response to proposed changes to National Planning Policy Framework. Our response is shown below.

A. Housing Targets and Planning Our main concern with the proposals is that they do not reflect proper planning for the housing we actually need. The proposed housing target of 375,000 dwellings per year over 15 years (totalling 5,625,000 dwellings) would house over 12.5 million people. However, given the current demographic trend of deaths exceeding births in Great Britain, this target appears unrealistic. It is unsurprising that these targets are disconnected from household projections, making them impractical.

B. Arbitrary Housing Targets The figure of 375,000 dwellings per year is arbitrary and lacks a logical basis. It is unrealistic to expect the UK to build this many homes annually. While there is a shortage of social housing, there is no public funding to invest, and the private sector is not stepping in, evidenced by the “land-banking” of over 1 million approved plans. Expecting housing to be a quick fix for the economy without the necessary backing is doomed to fail. The declining rate of housebuilding has little to do with planning; it is, in essence, a reflection of the economy.

C. Regional Disparities in Housing The homeless populations in areas such as Southport, Liverpool, Middlesbrough, Leeds, Sunderland, and Manchester are being failed by the current “levelling down” strategy, which reduces housebuilding north of the Watford Gap while increasing it disproportionately in the South, where homelessness is less of an issue.

D. Urban Decline and Misplaced Priorities Our urban centres are becoming hollowed out, with shops and offices in lower demand. This raises the risk of these areas becoming neglected. Instead of focusing on urban regeneration, the government’s plans are focused on building on green spaces, which contradicts efforts to combat climate change and protect public health. Additionally, these plans compromise food security by reducing available farmland.

Chapter 3 – Planning for the Homes We Need

E. Contradictory Proposals The title of this chapter and the actual proposals are at odds. These plans will result in the wrong types of homes being built in the wrong locations.

F. Housing Targets and Local Exceptions We disagree with removing exceptions to housing targets derived through algorithms. There are valid reasons to make exceptions in areas with constraints, such as flood risks or demographic issues. Setting unachievable targets for areas over a 15-year period is not only unrealistic but also constitutionally unfair.

G. Greenbelt Development We oppose the presumption in favour of approving planning applications, particularly on Greenbelt land, when an area cannot demonstrate a 5-year land supply. This effectively imposes Greenbelt releases undemocratically, overriding local plans.

H. Flawed Calculation of 5-Year Land Supply We disagree with basing the 5-year land supply on algorithmic housing targets rather than local plans, and we oppose adding a buffer under any circumstance. Ignoring local plans undermines the entire planning process.

I. Cross-Boundary Cooperation We agree that the government should amend the National Planning Policy Framework (NPPF) to improve cooperation on cross-boundary planning. However, this cooperation should not be tied to the timing of local plan adoption, and land availability in neighbouring areas must be considered.

Chapter 4 – A New Standard Method for Assessing Housing Need

J. Flawed Baseline for Housing Needs We do not agree that housing stock should be the baseline for assessing housing need, as this approach ignores actual housing demand and household projections. The result is that homes will be built where they aren’t needed, leading to inefficiency.

K. Misleading Affordability Calculation Using the workplace-based median house price to earnings ratio to assess affordability is misguided. Affordability should be based on where people live, not where their employers are located. This approach distorts the housing need in areas with high commuting populations.

L. Incorrect Weighting of Affordability The proposals incorrectly assume that mortgages are based solely on a single individual’s income and fail to account for household income. Additionally, the measure overlooks other forms of income, such as those from self- employment or investments. This flawed approach will result in incorrect affordability assessments.

M. Definition of Greybelt Land We do not agree with the proposed definition of Greybelt land, which is overly broad. Development on Greenbelt land should be strictly limited to prevent the degradation of high-performing Greenbelt areas.

N. Safeguarding Greenbelt Land We agree that additional measures should be introduced to prevent the deliberate degradation of Greenbelt land. All Greenbelt areas should be equally protected, and subjectivity in their evaluation must be avoided.

O. Inappropriate Land Releases We disagree with the release of land in areas that are not aligned with the 15-year local planning cycle. Greenbelt land should not be used for housing development outside of this framework.

P. Affordable Housing Mix The term “affordable” has lost its meaning. The focus should be on genuinely affordable housing, such as social rented housing. Greenbelt land should not be released for market housing, and the 50% target for affordable housing should be raised to 100%.

Q. Benchmark Land Values We support setting indicative benchmark land values for Greenbelt land, but they should reflect local agricultural land values to ensure fairness and cost efficiency.

R. Development Contributions We oppose accepting contributions below the levels set in policy, and all payments should be made upfront to avoid financial strain on local authorities.

S. Greenbelt Protections All Greenbelt land, regardless of whether it is newly released or part of a previous local plan, should be subject to the same protection rules.

Chapter 9 – Supporting Green Energy and the Environment

T. Missed Opportunities for Green Initiatives The government’s proposals lack essential measures to address the climate crisis, such as better insulation for new homes and the integration of solar or wind energy. These omissions are inexcusable given the urgency ofthe climate emergency.