2019: What’s that coming over the hill?
- Written by Andrew Strachan & Aqib Saghir
Happy New Year from all at NJL! As we return from our festive break, we take a sneak peek into the new year ahead and pick out some of the key things to look out for in 2019.
Lift off for GMSF
2018 was a turbulent year for the GMSF, with confusion resulting from lower than expected population projection figures published in the summer; sparking a re-think of housing targets, and subsequent advice from government to plan to previously established targets.
With a modicum of clarity on this and other issues, a draft of the Framework has, this month, been submitted to the GMCA Executive Board, and is set to be released for an 8-week consultation running from 21st January 2019 to 18th March 2019.
The 2019 GMSF draft identifies capacity for 218,549 homes in the City-Region, and proposes that a minimum of 201,000 new homes be built between 2018-2037. Each of the 10 Individual authorities are, however, likely to be encouraged to provide housing beyond the minimum targets, with further central Government subsidy on offer to the GMCA for encouraging this to happen.
Already, parts of the plan are being questioned. For example, a target of constructing a minimum of 50,000 affordable homes by 2037 has been set, however the proportion of which each individual local authority must seek to provide has not been made clear.
Some Local Authorities have also been given stepped targets for housing for the first five years. This is true of Stockport, Trafford and Bolton, which will all have lower initial targets
We will be looking again at the GMSF as the year progresses, starting with a review of the publication draft due out later this month.
Liverpool City Region – Is 2019 the year of progress?
As we enter 2019, its now been almost 4 years since the Liverpool City Region Combined Authorities reached its Devolution Agreement. Shortly after the Devolution Deal was announced, it was revealed that the Liverpool City Region Combined Authority Housing and Spatial Planning Board are preparing the City Region Spatial Framework.
Since then, the spatial framework has still not managed to get off the ground. Previous years have seen numerous evidence gathering exercises take place, but no draft version of the framework has been released thus far. Will 2019 see the combined authorities continue to build on their evidence base? Or, will the year see the Liverpool City Region Spatial Framework published in draft format? As it stands, the Liverpool City Region Spatial Framework is lagging behind its Greater Manchester counterparts.
We will be following the city’s progress, so watch this space.
Raynsford Review & Letwin Review – Will the findings be implemented?
Industry conversations in the coming year will undoubtably be shaped by two significant planning reviews in 2018. The Raynsford and Letwin Reviews call on those working in the built environment professions to reflect on the desired outcomes of the planning system. Each of these reviews make recommendations which, if followed, will have far reaching implications.
Former planning minister Nick Raynsford’s review into the state of the planning system looked to take stock of how it is functioning, address uncertainty about what it aims to achieve and reiterate the relevance of planning to modern society.
Going back to first principles, the review looked at the changes made to the planning system from 1947 to present day, and considers the reasons behind the perceived failure of the planning system to deliver the outcomes needed by society. 24 recommendations for change have been suggested, covering a broad range of topics.
2018’s Letwin Review similarly looked to guide debate on how best to reform planning in England. As we covered in our blog toward the end of last year, Sir Oliver Letwin’s review of build out rates in England identified some of the main obstacles to addressing the countries housing crisis.
Principally, Letwin noted a lack of diversity in housing type and tenure and the relatively slow rate of delivery achieved on larger development sites. The report attributed much of this to the dominance of market absorption rates in dictating the actions of the large home builders.
Addressing these issues, Letwin has put forward some fairly radical recommendations that, if implemented in full, will see a new set of rules for house diversity, a National Expert Committee established and a cap on the value of land at 10 times the agricultural value.
Each of these changes will of course take time to negotiate and bring into effect, in some cases requiring new primary legislation.
Both reviews are certain to inform industry and planning debate in the coming year, with the implementation of their recommendations worthy of watching.
Spotlight on ‘Deliverability’ of housing
With the revised NPPF released last summer, the implications of the many changes and focus shifts it brings about are still being unpacked and tested by the industry, Inspectors and Local Authorities.
However, a key area which we feel will be of importance in the year ahead will be demonstrating the deliverability of development schemes.
The new definition of ‘deliverable’, which is contained within Annex 2 of the new NPPF, indicates that sites with outline planning permission, permission in principle, allocated sites or sites identified on a brownfield register should only be considered deliverable where there is clear evidence that housing completions will begin on site within five years.
This itself does represent a change from previous practice, and potentially opens up the possibility of challenges being made to any given Local Authorities assessment of which sites are deliverable and which are not.
At the same time, there is likely to be greater pressure placed upon developers to demonstrate their track record of delivery, show a robust approach to development, indicate an ability to fully fund proposals, and a commitment to ensuring genuine public benefits from schemes within reasonable timescales.
We will of course follow the deliverability debate as it evolves.
Planning Inspectorate Reform Anticipated
In May 2018 the former Secretary of State for Housing, Communities and Local Government announced an independent review into planning appeal inquiries – with a look into the end-to-end process of planning inquiries. The aim of the review is to improve the planning appeal inquiries procedure to make it quicker and better. Following a Call for Evidence in July, the outcome of the review is expected in early 2019.
We look forward to seeing what major changes are made to the appeal process particularly in light of the recent struggle the Planning Inspectorate have had with delays in caseloads due to a lack of Inspectors. Expect a radical reform to the current process – the scope of the review will look into alternative appeal procedures, how effective current practice is and how the end to end procedure can be halved in time.
What’s clear is that 2019 promises to see sweeping changes across the appeal process.
Housing Infrastructure Funding – Still Missing in Action
The £5.5bn Housing Infrastructure Fund follows on from the Governments 2017 Housing White paper and 2018 Autumn Budget update, and was designed to help unlock up to 650,000 new homes.
Two types of funding were envisioned, with 1) Marginal Viability Funding - looking to assist schemes that are held back by the high cost of putting in the necessary infrastructure needed to build new homes and; 2) Forward Funding – looking to back strategic high impact infrastructure schemes with an initial investment, designed to encourage further investment.
In February of last year, projects to be funded through Marginal Viability Funding were announced, with a further 45 projects to be funded through Forward Funding also announced in March of that year.
From the outset, the application of funding has proven to be contentious. Alongside an imbalance in allocation (the majority (80%) of spending is to be concentrated in the South of the country), none of the funds appear to be have actually been utilised thus far. This works against the ambitions of the fund, which are ultimately to boost confidence to invest in building new homes and to open up site which were previously not considered deliverable.
Looking to the year ahead, the industry will be keenly watching for examples of the fund being successfully applied.
Local Industrial Strategies - First of Many?
The Local Industrial Strategies (LIS) are described by Greg Clark as a ‘new and unique partnership between government, academia and industry’ to shape the economy. The LIS are intended to use a solid evidence base to outline a long-term plan to ensure places seize opportunities for growth.
Business Secretary Greg Clark and Greater Manchester’s Deputy Mayor for the Economy Richard Leese in 2018 announced that Greater Manchester would be developing one of UKs first LIS. The LIS is expected to be published in March 2019. With the aforementioned GMSF finally taking shape simultaneously, it will be interesting to see how the two combine to ensure Greater Manchester maximises its growth. The LIS is referenced in the 2019 GMSF draft which is a good sign of conformity between the two.
Ministers announced last month that the entire country will also be able to benefit from developing a LIS. The government announced it will work in partnership with places to develop LIS, which are led by either Mayoral Combined Authorities or Local Enterprise Partnerships. Time will tell if other Local Authorities or Combined Authorities will develop a LIS.
Infrastructure in the North – What’s Next?
The disparity in infrastructure investment between the North and South has been well publicised over the years. Recent years has seen the imbalance between the two increase further. The think tank dedicated to the North of England, IPPR North, recently revealed the scale of this disparity. Since 2014, transport spending per person by the Government in London has increased twice as much than in the North. This, no doubt, is abundantly clear to travellers in and around the North of England, with BBC revealing Manchester’s own Oxford Rd, Piccadilly and Victoria ranking among the train services impacted most by delays and cancellations in the Country.
There is a clear need to re-think how the government can bridge the gap between the North and South. Decades of underinvestment has limited the potential of the North. Now more than ever, major investment is needed in order to foster growth in this key area of the country.
We hope 2019 sees a change in approach from the Government. The aforementioned Local industrial Strategies may be key to this, ensuring the right powers and funding are in place to unlock growth in the North.
These are just some of the interesting areas we think will be shaping the year ahead. As with many other industries in the UK, ours will be eagerly waiting for clarity over the intended departure from the EU. As noted by the Chancellor in the 2018 Autumn budget, many of the initiatives and funding proposals linked, to varying degrees, with the topics discussed above will be subject to change should a deal not be reached in time for March 29th.