The temptation of targets

I last wrote something about housing ‘targets’ back in November, essentially having a moan about terminology that I felt, and still feel, to be unhelpful.

In a nutshell, my views are as follows:

A) There are no mandatory targets. Rather, there is Local Housing Need (LHN), which is the starting point for plan-making, as per NPPF para 11 and the PPG:

“Assessing housing need is the first step in the process of deciding how many homes need to be planned for. It should be undertaken separately from...”

B) However, I totally accept that the effect of the draft NPPF would be to make it much easier for authorities to set a requirement below LHN.

Since November I know that we've all had ample opportunity to form clear views on the above, but there's been such a recent flurry of targets-talk that I thought I would take the opportunity to collate a few things and briefly revisit the debate.

Local politics

I suspect I'm not the only one who has noticed something of a recent uptick in local targets-talk pre-elections. In my patch it was the leader of Windsor and Maidenhead proclaiming on Facebook on Monday that:

"Currently we are mandated... to hit certain housing targets. [Once this changes] we will be moving to immediately review our BLP and amend our housing numbers accordingly for the remainder of the plan period until 2033."

If the Council was mandated to set the housing requirement at LHN then why did they consult on a wide range of alternative housing figures? The requirement was set at LHN (stepped) on balance, after having given weight to meeting LHN.

One other example close to my heart (professionally) is Epsom and Ewell, where a recent statement from the Council stated:

“The decision to pause... the Draft Local Plan means that we will wait for more detail... with regard to the current mandatory target for housing numbers.”

LHN for Epsom and Ewell is 576 dwellings per annum (dpa), whilst the draft local plan proposed a housing requirement of 300 dpa.?The SA report tested growth scenarios that would enable a requirement of between ~180 dpa and ~400 dpa.

National politics

Planning this week quoted Rishi Sunak as stating:

“I don’t think there was any support for a system that imposed top-down targets without any understanding of local circumstances.”

Is that a call for a national plan? I don't think so, as the PM also discussed the need to "strike a better balance" as part of plan-making. It's all very confusing.

With regards to the opposition, a couple of examples:

• The Telegraph this week reported Clive Betts MP calling the abandonment of mandatory targets a “disaster”.
• Sky News recently reported Lisa Nandy MP as stating: "It is utterly shameful that the prime minister admits he ditched housing targets."

And let's not forget the Guardian reporting in December 2022:

“Keir Starmer has labelled Rishi Sunak “the blancmange prime minister” after mandatory housebuilding targets were dropped…”

The Media

This week we've had the punchy article in the Telegraph: "Why a Tory government can never fix the housing crisis". It states that the draft NPPF:

"...?proposes?weakening the need for councils to follow the figures produced by the [standard method for calculating LHN]?in their local plan homes targets."??

This is near-accurate (the final word should be 'requirement'). However, and of course, the article goes on to discuss proposals to ditch "mandatory targets".

And then there is Planning. I am a huge fan, and I have seen an improvement in its reporting around 'targets' over the months. However, the following headline from an article this week takes loose targets-talk to a new level:

"The councils that inspectors allowed to freeze their housing land supply targets"

It brings the list of targets to four:

1. The national target
2. Standard method LHN
3. Housing requirements set through local plans
4. Five year housing land supply (please ignore this one)

Discussion

On the basis of this evidence, are we sure targets-talk is helpful to the cause of sensible planning reform, including moving to a more plan-led system?

Whilst I see the temptation of a binary argument for and against housing targets (it cuts through), it is simply not how plan-making works.?

Plan-making fundamentally works in a different way, whereby

• LHN is the starting-point and is not planning, but rather an objective technical input (albeit the cities uplift blurs this distinction).
• From this starting point, the local plan is prepared, leading to a housing requirement and a spatial strategy / key diagram / land supply.

Whatever your view on the extent to which providing for LHN should be prioritised as part of local plan-making (and my view is that it should be), or your views on a national and sub-regional plans leading to binding targets for local plans (yes please), spare a thought for clarity on how the system works now.?

Complete clarity on how the system works must be central to planning reform. I know this from personal experience as an SA consultant, with SA having failed quite simply, due to a lack of clarity on how the process works.

Rather than blunt talk of targets, we need to discuss: 1) standard method LHN; 2) alternative top-down inputs to local plan-making; and 3) local plan-making.