Letter: Do We Really Need to Worry About Local Plan Housing Numbers?

Published on: 5 Jul, 2021
Updated on: 5 Jul, 2021

From: Bibhas Neogi

In response to: MPs Have Made It Clear to the Housing Secretary – Surrey Housing Figures Too High

Regardless of the house targets in the Local Plan the reality is that nothing like the numbers will be built. Developers will not build unless there is adequate infrastructure both in physical terms and the facilities that the communities need.

Judging by the numbers that have been built out of those that have approved planning permissions in Guildford and Waverley, there isn’t much hope of achieving anything like the numbers in the Local Plan.

To get to understand the underlying problems, Hansard account of a debate initiated by the previous Guildford MP, Mrs Anne Milton, is helpful. I quote from Oct 30 2019 Hansard – “Despite my having had numerous meetings with ministers from the Department for Transport and the Ministry of Housing, Communities and Local Government, Guildford’s infrastructure, both road and rail, is under extreme pressure, as is the two-lane stretch of the A3.

“That affects many more constituencies than just mine; it affects everybody south of Guildford. Developers will build only where there is a commitment to the delivery of infrastructure. Builders simply will not build without it; they go elsewhere, where it is easier to build.

In Cranleigh, in Waverley borough, a total of 7,640 permissions have been given since 2013, but only 1,906 homes have been built. Cranleigh is required to build 1,700 new homes over the Local Plan period, which is from 2013 to 2032. Of those, 1,600 have been granted permission. The largest sites in Cranleigh account for 1,348 of those dwellings, of which only 168, or 12%, had been built as of September 4.”

So, do we really need to worry about excessive numbers of housing in the Local Plans?

Responses to Letter: Do We Really Need to Worry About Local Plan Housing Numbers?

Valerie Thompson Reply

July 6, 2021 at 9:15 am

Already there are two applications in West and East Horsley, one for 132 houses and another for 110. Neither depends on road infrastructure. The fact that the local schools are full, the station car-park is full and the surgery is full will not stop them. Infrastructure requirements do not constrain developments. Proposals are in place to increase the number of houses in West Horsley alone, by 33 per cent. I say to Mr Neogi, don’t tell the residents of the Horsleys that such numbers are either needed or appropriate.
- Harry Eve Reply
  
  July 6, 2021 at 12:34 pm
  
  Inadequacy of our roads infrastructure is being effectively ignored and the applications will add to existing congestion with all its adverse consequences.
  
  The local road network was not regarded as a constraint on the Local Plan – just the A3. There are no realistic solutions on offer because SCC feels obliged to ignore constraints and enable development whatever the impact on residents – including those in Guildford town and right across the borough because traffic generated in the villages will not stay within them.
- Bibhas Neogi Reply
  
  July 6, 2021 at 3:05 pm
  
  I think Valerie Thompson misses the point I am making. From the track record in building houses, it seems very unlikely that targets in Local Plans will be achieved.
  
  I am not able to comment on the number of housing proposed for any particular area as I do not have any connection with the authorities.
  
  If, as Mrs Thompson says, “the local schools are full, the station car-park is full and the surgery is full”, and I was looking to buy a house, would I consider buying in the Horsley area? Definitely not. I expect developers should know that and should be very careful in investing money in their projects.
  
  I gather both East & West Horsley Neighbourhood Plans have been prepared in consultation with the current residents and so the targets have been arrived at following the process set out in the Local Plan development procedure.
  
  Local Plan is a misnomer – it should have been called Local Aspirational Plan since the council do not own the sites nor have they the funds to invest in the developments.
Valerie Thompson Reply

July 7, 2021 at 9:54 am

GBC does have the ability to approve or refuse gross developments, which would bring in money from the developers. It seems they are rubbing their hands with glee at the huge sums they will gain.

Mr Neogi talks about builders not constructing without the necessary infrastructure in place, but this what is happening in the Horsleys. No new infrastructure has even been proposed.

The Neighbourhood Plans were achieved with a great deal of input from residents but they never agreed to the vast numbers of houses being dumped on them by the Guildford Local Plan, with its removal of green belt protection and the designation of open fields as numbered and approved sites.
Ben Paton Reply

July 7, 2021 at 12:21 pm

Why does Mr Neogi write: “…the reality is that nothing like the numbers will be built.”

What is the evidence for this?

Does Mr Neogi believe, or can he show, that the Housing Target set in the previous Local Plan was not built?

Can he show that the total number of houses in the current Plan – including permissions already given do not reach the housing target?

In fact, the figures show that the housing target for this Local Plan is already exceeded.

Does this matter?

Yes, for many reasons. One reason is transparency and honesty and accountability. GBC has a duty to present accurate information. Another is that the housing target was unconstrained, ie it was the absolute maximum number of houses that might be “needed” regardless of constraints, if the population projections used were correct. The ONS has now acknowledged that the projections were in fact wrong and/or materially overstated.

Another reason is that the housing numbers are supposed to address need. But we know that the real need is in social houses ie council housing and the Local Plan largely ignores this.

Still another reason is that it is wholly irresponsible to build more and more houses whilst ignoring the requirements for infrastructure ie transport (roads and trains and buses), health (GP surgeries, hospital beds) and education (teachers, classrooms and school places.)

Why does Mr Neogi believe that lack of infrastructure is a binding constraint? Private developers are motivated by profits. If they can build and sell houses whilst the infrastructure is inadequate – what stops them if they have planning permission?

Nothing it seems.
Bibhas Neogi Reply

July 7, 2021 at 4:33 pm

Over one million homes in England with planning permission since 2011 have not been built as reported in a recent Guardian article below, –

https://www.theguardian.com/society/2021/may/08/over-1m-homes-in-england-with-planning-permission-not-built

It also mentions “The LGA says only by building more council homes can the housing crisis be tackled and the government’s housebuilding target be met. It is calling for councils to be given powers to kickstart a social housebuilding programme of 100,000 homes a year. Polling by the association has found that 80% of MPs and 88% of peers think councils should have more financial freedoms and powers to build new homes.” So, I agree with Mr Ben Paton.

Developers would not build unless they can sell the houses and make a profit. Hence there are so many approved planning permissions that have not been built. Home buyers, perhaps other than those looking for retirement homes, would look at the availability of schools, leisure facilities, shops and the commuting situation, if they work away from the area, before they buy. It is the reality that drives the numbers that will be built regardless of numbers in the Local Plan.

Local authorities will be penalised by the central government for not achieving the targets, I agree, but this is totally unjustified as councils do not control the process and there is precious little joined-up thinking between the Housing and Transport Departments. The Housing Infrastructure Fund is available in certain cases but this does not address all infrastructure deficits.

Local authorities are already straining under the cuts as analysed in the National Audit report
https://www.nao.org.uk/wp-content/uploads/2018/03/Financial-sustainability-of-local-authorities-methodology.pdf
and this report said there was “limited room for manoeuvre in delivering further savings”.

Other important factors are the availability of trades people – masons, carpenters, plasterers, painters, makers of windows and doors, roofers, tilers, gas fitters and electricians. The country does not have the capacity and there are not enough apprenticeship programmes that would match the needs.

Councils can only get Section 106 contributions or from the imposition of Community Infrastructure Levy (CIL) from the developers as well as contribution in kind for building affordable homes (whatever that means) within the development.

As far as I am aware, councils do not and cannot get funds in any other form from the developers and GBC has not implemented CIL yet.
David Roberts Reply

July 10, 2021 at 4:17 pm

I think Mr Neogi is arguing that the Local Plan housing targets are so unlikely to be met that there’s no point in worrying that they are too high. To the extent that 14,000 homes are never going to be built by 2035, I agree.

The flaw in the argument is that the targets are already being used to justify excessive building on sites allocated in the Plan that are not necessary. This is taking place now, and cannot be undone by reducing the figures in several years’ time.