Response from Kislingbury Parish Council (West Northamptonshire) To Government NPPF Consultation
Kislingbury Parish Council wishes to highlight the concerns it has about how the NPPF Consultation Document proposes that the housing crisis should be dealt with. It identifies as the sole factor that housing starts have been delayed purely and simply by hold ups caused by the planning framework. Having made this highly questionable assumption, it then proceeds to set a target of building 1.5 million homes over the next 5 years.
The proposed changes aim to provide a solution to a problem identified as insufficient housing build starts. It is difficult to argue that there has been insufficient housing built for many years and that many people find it increasingly difficult to afford to buy or rent.
The consultation document locates the reason squarely in the way that the planning process and aspects of the rules changed in 2023 and have resulted in delays to developments being approved. Kislingbury Parish Council suggests that this is a very partial account of why so few affordable homes and homes for Social Rent have been built in the places where they are most needed. Kislingbury Parish Council suggests that if a closer look is taken at the type and location of the 200,000 houses that have been built, this would show that there has been a disproportional level of profit driven development of larger and more expensive homes in rural villages which attract a rural premium.
Parallel to this development has been the on-going effects of Right to Buy and Right to Acquire. Between 1980 and 1997, it has been estimated that 1.7 million homes have been sold under Right to Buy. Since 2015, a further 100,000 social homes have been lost. It has also been noted that the stock of social housing fell from 6.5 million units in 1970 to 2 million in 2017. Furthermore, Right to Buy is no longer achieving its stated aim of increasing the level of home ownership which peaked at 71% in 2003 and has declined since.
There needs to be a clearer understanding of how a profit-driven housing sector interacts with local authority planning processes, which are in turn part of what should be an ongoing democratic process which informs local decisions. Kislingbury Parish Council accepts that a key part of this democratic process was the election of a Labour Government in July 2024 committed to increasing the number of building starts.
However, this commitment can only remain part of a democratic process by ensuring that the requirement of developers to make a profit is balanced with the needs and wishes of citizens.
The consultation document has the laudable aim of ensuring certainty between what it describes as the stakeholders involved. However, such a statement implies that there is an equality of resources between developers (many of which are large multinational businesses), local authorities and local communities.
This is simply not the case; large and even relatively smaller developers employ teams of legal and technical experts who can identify loopholes in planning regulations that can be exploited for profit. In contrast, over the years marked by austerity local authority planning departments have been hollowed out in terms of numbers of planning case officers. Also it is not uncommon for trained planning officers to move on from the public to the private sector. Local communities and individuals clearly have even less recourse to technical and legal expertise.
Staffing levels and employment conditions in local authority planning departments become even more of an issue with the new proposed requirements to identify land to meet housing targets and to maintain a rolling 5 year stock of such land.
Kislingbury Parish Council, therefore, would ask that local authority planning departments be given the resources they need to properly and fully assess development applications and to make sure that, once agreed, developments remain compliant with the original approval.
However, Kislingbury Parish Council sees this regulatory role as only one aspect of what local authorities need to be doing.
Kislingbury Parish Council would also agree with the statement made by the New Economic Foundation (May 2024). NEF and the Local Government Association (13 February 2024) both note that there are currently 1 million households waiting for a council house and it has been estimated that councils are currently spending £1.7 billion per year to keep people in temporary accommodation.
Kislingbury Parish Council agrees with NEF that the current housing crisis can only be met by stopping the prioritising of home ownership and to, instead, see the provision of safe, secure and well-built social housing as the key priority.
To do this there needs to be a wider perspective. To resolve the housing crisis there needs to be a multifaceted approach which does not just depend on private enterprise building a set number of homes (largely for ownership).
This is particularly the case when the workings of the market (e.g. relating to Grenfell and cladding) have been shown to be seriously wanting. The housing crisis will not be solved by private enterprise. The state (at local and national level) has to be involved in order to deal with issues that derive from policy dating back to 1980.
To do this local government needs to be given a supercharged role to act as both provider and regulator.
Kislingbury Parish Council agrees with NEF that it’s time to give local councils the powers they need to reverse the damage Right to Buy has done to communities and give them the tools to tackle the housing crisis.
There is a desperate need to get councils building again. The Right to Buy should also be suspended locally if it can be shown to have detrimental effects on the supply of social housing and any housing bought under Right to Buy should be prevented from entering the Private Rented Sector.
Kislingbury Parish Council also has concerns about the way that (financial) viability has been used by developers to modify proposals once outline permission has been given. We argue that giving a greater role to the provision of social homes to local authorities would reduce the need to ‘window dress’ applications made for development where the real goal is a corporate profit as a result of houses sold for ownership.
The same applies to the concept of affordable housing. Kislingbury Parish Council has a more fundamental objection to this concept of affordable homes. To the layperson, the term ‘affordable home’ implies something that a family on a median income should be able to afford. The truth is that this term is a strange combination of a technical and a marketing term. It is a technical term because it is defined technically. It is a marketing term because its use helps developers sell proposals to local authorities and communities.
Kislingbury Parish Council therefore ask that the use of the term ‘affordable home’ be abandoned and replaced by something that accurately reflects what is on offer. The terms of such offers also need monitoring, as we are aware that locally developers offer affordable homes at below market price but make the process of taking these up difficult and protracted to justify subsequent sale on the open market. A greater role for local authorities would reduce the need to try and window dress planning applications.
Kislingbury Parish Council would also ask that consideration is given to ensure that housing built to meet local needs is not bought up by private companies for rent and that a high percentage (50%) of Social Rent housing are the norm and are provided by registered providers rather than private landlords.
Currently, only developers can appeal if a planning decision is rejected. This seems to fall short of natural justice and we would propose that a mechanism be set up whereby local authorities and local communities could appeal without (as at present) having recourse to judicial review.
Kislingbury Parish Council would urge that decisions on all planning applications be obliged to consider the cumulative effect of planning applications on existing infrastructure in the context of particular locations. Furthermore, that infrastructure includes all infrastructure such as drainage, pumping stations (especially in flood risk areas) as well as education, health and transport infrastructure.
Kislingbury Parish Council welcomes the Labour Party Manifesto Commitment to preserving the Green Belt and preventing urban sprawl. But such sprawl will only be prevented if the Local communities are engaged in the process and if local authorities have the resources necessary.
Our response urges the new Government to look for solutions beyond possible problems with the planning process. In doing so, Kislingbury Parish Council believes that there are even wider issues involved. From a grass roots level it often seems as though decisions are made that favour powerful vested interests. This means that there is little point engaging with democratic political processes. We believe that resolving the housing crisis along the lines suggested by NEF and the LGA would go a long way to correcting the mistakes of the last 44 years of housing policy and show that the philosophy that underpinned this policy – that deregulated markets work better than public initiative – is no longer tenable.
Dr Jonathan Hughes – Chair, Kislingbury Parish Council
On behalf of Kislingbury Parish Council 23rd September 2024
