Local authorities are now expected to calculate their district’s minimum housing need using the Standard Method, the basis of which is the official household projections. Whilst the publication yesterday (20 September) of the latest, 2016-based, household projections may result in changes to the Standard Method, to ensure that it aligns with the aim of increasing housing delivery, it will nevertheless continue to provide a fix on minimum housing need at local authority level.
A fix on housing need at district level is one thing, but how does this inform housing need at settlement level?
The answer is, it doesn’t, not without first having an understanding of settlement population and its characteristics.
In some cases, this understanding will be used to ‘divvy up’ the local authority’s need based on the Standard Method, but there are many reasons, for the sake of good plan making and sustainable development, that a bottom up, rather than top down assessment of settlement need will be required.
Neighbourhood Housing Requirements
The revised National Planning Policy Framework (NPPF) published on 24 July 2018 clarifies that Local Plan strategic policies should set out a housing requirement for designated neighbourhood areas – which it states should reflect the overall strategy for the pattern and scale of development, including relevant housing allocations.
The revised NPPF confirms that unless there has been a significant change in circumstances, such figures should not need re-testing at the neighbourhood plan examination, which simply emphasises the need to rigorously test such numbers at Local Plan examinations.
In the event that it is not possible to provide a requirement figure for a neighbourhood area, within the Local Plan, the revised NPPF requires that local planning authorities provide an indicative estimate. That indicative estimate should account for:
- The latest evidence of local housing need
- The population of the neighbourhood area
- The most recently available planning strategy of the local planning authority
The importance of determining adequate housing need (see a recent project example here) at the local level is highlighted by the social objective underpinning the sustainable development principles of the revised NPPF; “to support strong, vibrant and healthy communities, by ensuring a sufficient number and range of homes can be provided to meet the needs of present and future generations.”
Paragraphs 65 and 66 are the only sections of the revised NPPF to discuss this topic, and whilst the revised NPPF refers only to ‘neighbourhood areas’, sub-District assessments can cover a number of geographical areas and can assist in testing the robustness with which a Local Plan proposes to distribute housing need across a District, as well as assessing the localised need for a particular residential development.
Despite the standardisation of the housing need at local authority level, there remains significant opportunity for interested parties to firstly test a local authority housing requirement, against wider Local Plan policies and Vision, as well as testing whether the housing requirement identified at a sub-district level is appropriate, and where not an alternative can be properly evidenced.
So, just as with the existing Objectively Assessed Need (OAN), sub-District housing assessments will be needed to support Local Plan representations, planning applications, and appeals.
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Housing need, Standard Method