Housing Need in Planning Appeals
In any planning appeal involving new dwellings, the Planning Inspector must weigh up the benefits of the development against any harm. In judging how much weight to give to the provision of housing, an Inspector should consider the degree to which housing is needed in the local planning authority (LPA) in question.
Measuring housing need in an appeal
The two key questions are, (1) what is the LPA’s local housing need figure and (2) is this being met, and if not, how big is the shortfall? Both can sway an appeal.
In the first instance, if there is a high level of housing need, the Inspector may be justified in giving greater weight to the provision of new housing, irrespective of whether or not a LPA is achieving its targets. We will turn to how to evidence this shortly.
In the second instance, a LPA that is failing to meet its targets could be penalised in an appeal. This is the subject of other blogs on the Housing Delivery Test (12/3/20) and on Five Year Housing Land Supply (2/10/19) and is therefore not covered here.
The standard method for calculating housing needs
The Government is expected to review the standard method this year, but whatever the outcome, the data produced by the Office of National Statistics (ONS) that underpin the method will remain relevant to any appeal.
The two ONS datasets used in the standard method are (i) the growth in households and (ii) the ratio of houseprices to earnings as set out in paragraph 2a-004-20190220 of the National Planning Practice Guidance.
Tipping the planning balance with housing facts
It has never been easier to obtain statistics, with the ONS publishing its data in easy-to-use excel worksheets. The ratio of houseprices to earnings and population projections were published in March 2020 while household projections will be published later in the year. The relevant tables containing data for each LPA are:
• Houseprices to earnings (the affordability ratio) – table 5c
• Population projections – table 2
• Household projections – 2016-based and 2014-based
The latest Affordability Ratios
The ONS’s latest update on 19th March 2020 for the ratio of houseprices to earnings shows a slight reduction between 2018-2019 in most parts of England. Nevertheless, 136 LPAs experienced a rising ratio, with 35 of these having a significant rise of over 0.5 compared to the 2019 release. They included big increases in the affordability ratio from 8.93 to 9.44 in Forest of Dean, from 8.52 to 9.06 in Reading, from 9.93 to 10.47 in East Devon, from 8.83 to 9.48 in Hastings, from 12.59 to 13.41 in East Hampshire, from 9.73 to 10.61 in West Devon and from 12.22 to 13.28 in Winchester.
Even where the ratio is lower than the national average of 7.83, the rate of increase can be important in demonstrating rising housing need. For example, Bury’s ratio, although relatively low, has increased by nearly 10% over 12 months from 6.22 to 6.82. Pendle’s ratio has increased by 20% from 3.66 to 4.40 and Knowsley’s has increased by 25% from 4.12 to 5.14.
Use of statistics in planning appeals
Facts and figures from the Office of National Statistics can be highly useful, albeit a rather dry subject. Graphs can bring the figures to life when presenting your appeal case. For example, the graph below illustrates the rising affordability ratio for one LPA.
Planning Inspector’s reference to housing need
An example of the use of the affordability ratio is a recent appeal for 84 dwellings in Cherwell where the Inspector noted, “The affordability ratio has increased more rapidly in the district than in Oxfordshire over the CLPP1 plan period and it is apparent that market housing is increasingly unaffordable for many. As such, even though the proposal would simply be policy-compliant in regard to the quantum of affordable housing, I give significant weight to this provision in helping to address what is clearly a district-wide need.”(APP/C3105/W/19/3228169)
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