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Agenda item

Response to Government Consultation: "Planning for the Right Homes in the Right Places"



1.         This report is produced in response to the government’s consultation on the document ‘Planning for the Right Homes in the Right Places’ (September 2017).


2.         The main proposals: a new method for calculating local housing figures, and mandatory Statement(s) of Common Ground between authorities, have potentially significant implications for the Council and these are set out in the report.


3.         The recommended response to the consultation questions is set out at Appendix A.




1.         That Appendix A to the report be submitted to government as the Council’s official response to the consultation.


2.         That Cabinet note the proposed introduction in 2018 of mandatory Statement(s) of Common Ground, to be negotiated with other Local Planning Authorities (see paragraphs 4.10-4.19 of the report).


This report proposed a response to the Government’s consultation on the document ‘Planning for the Right Homes in the Right Places’ (September 2017). The potentially significant implications for the Council of the proposed new method for calculating local housing figures, and the creation of mandatory Statement(s) of Common Ground between authorities, were set out in the report.


  • The Planning Policy Manager first referred to the standardised approach that had been used to assess housing need for each district and said that there was no immediate concern for Dartford as the figures presented were within the levels specified in Dartford’s current Local Plan. He did however voice concern that the levels currently defined could increase in the future and that any change, up or down, would likely impact targets defined in the Local Plan. He then noted how the Government still wanted Local Plan delivery targets to meet national housing need and said that this may require house building requirements to be redistributed because of relevant constraints in certain areas. He said that the proposed way of addressing this would be to introduce negotiated ‘Statements of Common Ground’ across Housing Market Areas and noted the increased levels of risk and complexity that this would introduce as Dartford begins to prepare the next version of its Local Plan, which is due to start  this winter.


  • The Planning Policy Manager said that the new proposals could have simplified things further but noted that calculation changes, the lack of geographic guidance, and the fact that the Local Plans in each local authority area can be at differing stages of development, added to the complexity. He then said that there were no incentives for those who encourage housing growth and development, and noted that the source of associated funding for the development of the infrastructure required to support the new housing being delivered was unclear. He also noted that there were no proposals in the consultation that would allow Councils to penalise those developers who are granted planning permission but then fail to start development.


  • The Planning Policy Manager said that, overall, the consultation response welcomed the aim of simplification but expressed concern over the housing demand methodology. He said that extra guidance on the ‘Duty to Co-operate’ was welcome but that mandatory requirements that lead to delay and a potential increase in bureaucracy were not.


  • Members referred to the pressures that could be put on those developers who fail to develop areas that have been given planning permission and suggested that the renewal of permission once the period for development has expired should be reconsidered, and that the response should suggest that developers have to resubmit their application from the start in order to regain planning approval. The Planning Policy Manager said that this had not been included and the extent to which this would have a major impact or not would need consideration. He also noted that the ability to charge Council Tax on dwellings that have been given planning permission, but have not been built, is proposed again to encourage their development. It was also noted that while land values continue to rise at a significant rate the incentive for developers to accelerate development will remain reduced if increased supply reduces sale prices.


  • Members expressed concern over the redistribution of housing need across Housing Market Areas as it was suggested that some local authorities may be asked to deliver additional housing in order that a neighbouring local authority’s housing need figures may be met. Members also suggested that a co-ordinated response to the delivery of infrastructure was required as the various agencies involved seemed to be working independently.


  • Members noted the continued proposals for change that were being received from Government and asked whether this was having an adverse impact on those staff involved in the development of Planning Policy. The Planning Policy Manager replied that the impact on staff was not too great as some of the proposals contained within a consultation do not get implemented, while others are refined and put forward for further consideration. He also noted how views expressed in consultation responses do get considered and can lead to changes when proposals are implemented.


  • Reference was then made to site development viability and it was suggested that the consultation response include the requirement to generate a Supplementary Planning Document (SPD) on viability. The Planning Policy Manager agreed that viability can become an issue when a developer cannot bring forward the development of a site as it is no longer economically viable when land/development costs, infrastructural and affordable housing requirements are taken into consideration. He said that an SPD could help provide transparency for the public and clarity when the Development Control Board is considering planning applications. He said that this potential new approach, being tried by some London Boroughs for example, will be monitored as it is understood to be subject to challenges on the legality of key requirements.


  • The Advisory Panel endorsed the report’s recommendations.

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