How flawed housing targets threaten our countryside
New research shows that local housing targets are driven by over-ambition rather than need
The Campaign to Protect Rural England (CPRE) is today calling for an overhaul of the way local authorities set housing targets in order to stop countryside being lost unnecessarily .
Extensive research commissioned by CPRE has shown that local authorities are in effect being asked to base their plans on aspiration rather than need, which is resulting in ever higher housing targets and the consequent, unnecessary release of countryside for development  – without resulting in an increase in overall housebuilding.
Among a large number of problems with how the targets are calculated , the research found a lack of clear guidance in the process, a lack of objectivity in the calculations, and a lack of concern for land availability and environmental impacts.
The research demonstrates that the unrealistic targets are putting undue pressure on the countryside. Setting targets far higher than what can be realistically built just means that developers have more sites to choose from: as static building rates show, higher targets do not mean faster delivery . The disastrous consequence is that when these unrealistic targets are not met, councils have to identify even more sites for housing, and ever more countryside is released for more lucrative development while brownfield sites go unused .
Matt Thomson, head of planning at the Campaign to Protect Rural England (CPRE), said:
“It is vital that we build more homes, but this will not be achieved through ever higher housing targets based on ambition rather than actual need. The current process is not only highly damaging to our countryside and the environment in general; it is also damaging to community well-being and extraordinarily frustrating for local people.
“Through its planning inspectors and the threat of expensive appeals, the Government is taking a top-down approach to impose and enforce housing targets – despite ministers calling for more localism. Instead, we need to see a more accurate definition of community need at the heart of all local plans, and more consideration for environmental concerns and land availability. Councils should not be penalised for failing to meet implausible ambitions for growth over and above actual housing need.”
To illustrate the unrealistic nature of the housing targets, CPRE has analysed the local plans passed in the past two years that have contained a new housing target. In those 54 local plans, the average housing requirement is 30% above the Government’s household projections, and 50% above the average build rate. Only seven of the 54 targets take environmental factors into account .
To ensure that we build the homes we actually need in the right places, CPRE is calling for community surveys to play a far greater role in determining true need; for available brownfield land to play a leading role in developing targets; and for planning guidance to include a clear definition of housing need that is designed to support those who lack housing, and to ensure local plans specify what kind of homes will meet this need.
The Oxfordshire SHMA, published in March 2014, suggests the need for an extra 100,000 houses in the county by 2031. This is the equivalent to two new cities the size of Oxford in just 17 years. This could lead to roughly 200,000 more people – a 30% increase in the population – much higher than the 10% anticipated UK population growth for the same period. The SHMA figures would mean building at virtually double any previous rate. The housing targets in the SHMA are having a direct effect on the countryside, for example the draft Vale of White Horse District Local Plan proposes 1,400 houses in the North Wessex Downs AONB and 1,500 houses across four sites in the Green Belt, contrary to NPPF policy.
Communities and Local Government Secretary of State Greg Clark recently approved a planning inspector’s recommendation to increase housing targets for North Somerset Council. The council has been waiting for their local plan to be approved for three and a half years. The plan was given the go-ahead by a planning inspector in 2012 but the housing target was subsequently successfully challenged in the courts. Since that time the council has done more work on their housing target and arrived at a figure of 17,000, but a planning inspector said that this should be raised to at least 21,000 to meet figures set out in a housing assessment. Development potential in North Somerset is highly constrained by Green Belt, Areas of Outstanding Natural Beauty and areas at high risk of flooding. This means that the council cannot show that enough houses are likely to get built over the next five years to meet the higher figure. If this situation remains unchanged, it will trigger a national policy which voids the local plan and allows developers to pounce on greenfield sites that are not currently allocated for housing. It would also be likely to lead to the loss of Green Belt land.
Notes for editors
 CPRE, Set up to fail: why housing targets based on flawed numbers threaten our countryside, November 2015
 CPRE commissioned Housing Vision, housing market consultants, and Tibbalds Planning and Urban Design, to research and review the methodologies used to determine “objectively assessed need” for housing since the introduction of the National Planning Policy Framework (NPPF) in 2012. Their report is available from the CPRE website here.
Housing Vision and Tibbalds, Smarter SHMAs: a review of Objectively Assessed Need in England, commissioned by CPRE, November 2015.
 At the heart of these issues is the requirement for local authorities to identify the need for housing and then meet that need in full in their local plans. The National Planning Policy Framework (NPPF) sets out how to determine “objectively assessed housing need”. Online Government guidance in the National Planning Practice Guidance (NPPG) provides a recommended approach to deciding” objectively assessed need” through a Strategic Housing Market Assessment (SHMA).
 Government data show that 242,000 houses were given planning permission in the year up to June 2015. Yet housing starts and completions show little sign of matching this number. Quarterly statistics on housing starts show that building rates have been static since the beginning of 2014 – at around 136,000 per year. The latest data show completions are currently at 131,000.
 The situation is then made worse because if housebuilding in an area falls below these five-year targets, the local plan that contains these targets – and the protection for land not classed as suitable for housing – no longer applies. Once that happens, local authorities can be forced to allow house building on greenfield land, whether it meets a community’s needs or not.
Meanwhile, CPRE’s 2014 report From wasted space to living spaces found that at least a million new homes could be built on suitable brownfield land across England, and that brownfield land is a self-regenerating resource. CPRE, From wasted space to living spaces, November 2014.
 CPRE’s new research, distinct from that of Tibbalds and Housing Vision, assessed all local plans outside of London containing housing targets adopted between April 2013 and July 2015. See CPRE, Set up to fail, November 2015.