DLP Planning Ltd (DLP) have submitted their response to the DCLG Consultation on “Planning for the Right Homes in the Right Places. DLP’s key recommendations include:
- Support the principle of a Standardised Objectively Assessed Housing Needs (SOAN) methodology but as presently drafted, it gamed to lower OANs in areas of high demand. In areas seeking employment growth, Local Authorities will not always seek to match job creation objectives with the appropriate level of housing growth.
- The introduction of the 2 year “evidence free zone” prior to Examination of a Plan will result in greater rigidity in the Plan system and is likely to result in the Government’s target of 250,000 dwellings per annum being substantially undershot.
- The alternative to safeguard plans against rising housing requirements from Objectively Assessed Needs for housing (OAN) would be to require plans to include a requirement to identify reserve sites for an extra 20% or a further 5 years of housing land (whichever is lower) and policies to be released in light of higher indicators of demand.
- The proposed SOAN should be taken further and, for those authorities wishing to take an economic development led approach, guidance on the relevant economic activity rates should also be published. This information could be taken from the Office for Budget Responsibility (OBR) or an adopted or agreed Strategic Economic Plan or City Region Deal. This again would reduce one of the major areas of complexity in economic / job led projections by relying on published data available in the public domain.
- The provision of a clear methodology / appraisal format would assist in standardising the approach taken to viability appraisal. The basis for some of the inputs included within this approach could then be specified i.e. BCIS as a basis for build cost, 10% for external works (excluding abnormals). The requirement for comparable evidence of sales costs and reference to RICS guidance on non-standard build costs (i.e. abnormals) will also assist.