Assessing housing needs and housing targets
The housing target, showing how much housing land will be provided in the next 15 to 20 years, is the most important part of the Local Plan. It has also proved the most challenging.
Under the National Planning Policy Framework, housing targets must be based on objectively assessed housing need (OAN). More than two years after the Framework was published, there is still a steady stream of emerging plans being rejected by Inspectors for getting the OAN wrong and for setting unsound targets. Only last month, Derbyshire Dales failed the test, as did Bury in late June.
The Planning Advisory Service (PAS) has now stepped in, with an advice note on 'Objectively Assessed Needs and Housing Targets'. The note, written by PBA, provides a straightforward step-by-step method to assess needs and set targets, based on practical experience and Inspectors’ advice.
The note starts with the basic principles of the new system. It shows that the Framework and supporting Practice Guidance have fundamentally redefined essential terms. So ‘housing need’ is now almost synonymous with ‘demand’; and the Strategic Housing Market Assessment (SHMA), a central element of the new system, has little in common with pre-NPPF SHMA.
Another central point is that even the most constrained authorities must measure their housing need and take responsibility for it. If an authority demonstrates that it cannot meet its need in full, it must do its utmost to export the unmet part to other places - beyond the housing market area if need be.
Beyond these basic principles, the note offers detailed technical advice including:
- Why the target is not the need
- Easy ways to draw housing market areas
- How demographic projections work
- Why in-migrants and local people weigh equally in the balance
- What is wrong with the new ONS population projection and how to fix it
- What may happen to household formation as the market recovers
- The most useful market signal and how to read it
- Why most job-led housing numbers make no sense and how to put them right
- How not to double-count affordable need
- Why the ‘shortfall’ against the old Regional Spatial Strategy target does not count
- How the OAN should reflect policy priorities, not just numbers.
"We have published this note in response to regular conversations with local authorities where this topic came up, “says Adam Dodgshon from PAS. “The note provides some thoughts on how to tackle key issues. Whilst it has no official status, and is not a prescriptive methodology, we believe it provides further clarity on the subject and we hope that people will find it useful."
The note is relevant to both to plan-making and appeals. It shows what planning authorities have to do to comply with national policy and what they can do to deliver local priorities.