The Northern Housing Consortium (NHC) is a membership body representing registered housing providers and local government across the North of England (North East, Yorkshire and Humber and North West).
We welcome the opportunity to engage with government to support the development of effective housing strategy that works for all localities across England.
In shaping our response to the White Paper, we held a series of member engagement roundtables and were pleased to host the Housing Minister in Gateshead. Our response has also been driven by the ongoing work of the Commission for Housing in the North.
We recognise that this White Paper is focused on housing supply and it was never intended to be a White Paper that would capture the wider holistic role that housing can play in shaping communities, improving life chances – including health and well-being.
Our responses to the White Paper consultation questions will focus on supply. However, we feel strongly that the White Paper should have given more consideration to the importance of existing stock and the role that regeneration can play in supporting the supply of the right homes in the right places.
The Housing Minister acknowledged during his visit to Gateshead that we cannot have a national housing strategy that doesn’t reflect the needs of differing localities.
Indeed, we would argue we should consider a national housing framework with local strategic vision and delivery. We have explored this further in the final report of the Commission for Housing in the North – “A New Framework”.
We would therefore urge the Government to work with the NHC and its members to swiftly consider the development of an effective regeneration strategy with appropriate investment and delivery tools. This strategy could be utilised to not only ensure we are boosting housing supply but that we are also supporting economic growth and renewal.
The NHC would be pleased to work with the Minister and their officials to this effect and we would be keen to develop a policy paper for Ministerial consideration.
Notwithstanding the omission of regeneration in the White Paper, NHC members broadly welcomed the White Paper as it demonstrated a good analysis of the challenges facing housing supply and has made useful steps towards developing some solutions.
- Policy Integration
Notwithstanding the acknowledgement above that the Housing White Paper was intended to focus on supply of new build. NHC members felt it was increasingly important to consider housing policy in context of wider strategies including the Industrial Strategy and consideration of infrastructure investment. Similarly, concerns were raised that other departmental policy decisions were negatively impacting on housing supply – with the example of Local Housing Allowance (LHA) cap cited as prime example.
All the NHC roundtables considered the challenges faced by lack of capacity both in planning departments and across local government more generally. We welcome the acknowledgment in the White Paper that local government needs capacity support but the White Paper proposals need to go further. NHC members expressed concern of capacity in delivery (use of CPO’s or site assembly skills), in developing pipeline of supply where sites are stalled, in tackling poor conditions in the private rented sector and in developing new effective housing strategies.
NHC members are seeking to maximise capacity through effective partnerships – with Registered Providers working with Local Authorities, consideration of the role the HCA could play in boosting capacity and learning from approach of Combined Authorities.
NHC members welcomed the broader signals from government regarding greater flexibility both in terms of HCA programme funding, changes to Starter Homes etc. In an era of devolution and a welcome return to a focus on place we feel that flexibility – including possibly at policy level – has a significant role to play in ensuring each locality can reach its housing aspirations.
NHC members also raised concerns regarding shortages (or potential shortages) in the supply chain, particularly around bricklaying and the difficulty faced by attracting people into the sector. There was concern that these issues may be further exacerbated in the North as Brexit unfolds.
The NHC response to the specific consultation questions is set out below:
The NHC welcomes the Government ambition of making plans easier to produce. We understand planning can be a long-winded process which can impact on supply.
We would take issue with the comment in the White Paper that Local Authorities are “ducking” the issue and feel that capacity restrictions have hindered the production of plans. We recognise that Northern regions are not immune to this challenge as evidenced by analysis by Lichfields demonstrates with regard to production of Local Plans.
Local Plan Progress as proportion of LA’s in region
We therefore agree with proposals to differentiate between mandatory and optional plans, we further welcome proposals that reduce duplication and the ability to work collaboratively with partner authorities including but not exclusively Combined Authorities.
The NHC welcomes the Government’s recognition that we need to more effectively plan for an ageing society including in terms of housing supply.
We are supportive of the proposal to amend policy so that local authorities should have clear policies that address the housing requirements of groups with particular needs.
We would welcome an opportunity for NHC and its members to engage further with government as you draw upon stakeholder expertise in shaping a response to an ageing society.
However, assessing housing requirements will not necessarily ensure that supply is delivered if wider government investment and policy decisions continue to act in a damaging manner.
For example, recent proposals to amend Local Housing Allowances (LHA) on supported housing have had a damaging impact on pipeline supply. We would therefore urge a greater degree of policy impact assessment if Government is to achieve its ambitions to boost housing supply. We anticipate the Supported Housing Green Paper will respond to sector concerns.
With regard to assessing housing needs, the Housing White Paper advised that consultation on the detail underpinning a standardised approach would be brought forward. We recognise the calling of General Election in June 2017 has delayed this process but we would urge minimal further delays.
We acknowledge the benefits of a standardised approach to assessing housing need but remain concerned that any standardised approach did not reflect nuances across housing market conditions and in particular how “future growth” is captured.
We will work constructively with Government when they bring forward more detailed proposals to ensure we achieve a balance between a standardised approach and one that does not over simplify the process.
We agree that Local Authorities are expected to have clear strategy for maximising the use of suitable land in their areas. We have seen in other sectors that opening up data can enhance public participation in policy development and delivery and we look forward to seeing how greater data transparency can support housing supply.
That said NHC members felt that land viability in the North was of greater concern and that government support in terms of investment and the role of the HCA was required to ensure land with marginal viability could be deployed to boost housing supply. In particular, some participants in roundtables suggested that enhanced HCA support in this arena would be a significantly useful role.
We welcome this proposal to reduce the discrepancy between unitary and two tier authorities. In this section of the White Paper, Government also proposed to consult on a General Disposal Consent (Growth and Infrastructure Act 2013) which would allow disposal at less than best consideration without the requirement to obtain the consent of the Secretary of State.
Whilst we welcome this proposal and will respond to consultation process in due course we would also urge the Government how it can further incentivise similar behaviours across the wider public sector and partner agencies. NHC members reported frustration at land purchasing across public sector bodies where conflicting needs regarding economic return ultimately led to potential land for housing supply not being brought into pipeline.
We understand the rationale that pooling can ensure land is brought forward and that it can encourage SME builders into the market and welcome efforts to diversify delivery.
However, issues regarding sub division of larger sites were raised by NHC members with regard to the pooling limitations on S106 planning obligations. The limitation of five contributions to deliver key infrastructure is leading to challenges around viability of delivery (cost of a new primary school is unlikely to be met by 5 pooled contributions of smaller housing sites) and further development proposals risk being unable to be considered as sustainable development due to lack of mechanism to secure planning obligations to deliver infrastructure.
If government wish to continue to encourage small builders into the market place then it is imperative that these constraints arising from this restriction are adequately addressed.
The NHC remains passionately committed to the principles and benefits of regeneration – although we strongly believe that this a narrow focus on “estate regeneration” is restrictive and we reiterate our call for government to consider how we can respond to the challenges of poor quality private rented and owner occupied stock in a wider holistic regeneration strategy.
We would welcome further engagement with government as to how “social and economic benefits of regeneration” can be effectively considered in a manner that recognise the long term benefits of regeneration alongside the detriment (both social and economic) of lack of investment.
This was of particular concern when considering regeneration in lower value areas where value uplift may not be enough in the short term to demonstrate economic return. We continue to call on government to consider how we can deliver economic and social renaissance in these localities through effective and sustainable investment streams – including patient equity.
We remain willing to work with government to help shape an effective Regeneration Strategy.
The NHC has long championed the benefits of design standards such as Building For Life and wider principles of inclusive design both in construction of buildings and the wider neighbourhood environment.
We have many exemplars across the North of excellence in design but managed in cost effective manner and would be delighted to recommend these to Government in your plans to “draw upon the expertise of a wide range of stakeholders” as you develop thinking on housing for older people. We therefore welcome further support from Government in this area.
We welcome the Government’s proposals to boost capacity within the planning system through additional financial support. We recognise the balance that needs to be struck in making the appeal system fit for purpose.
NHC members felt that particular consideration should be given to ensuring SME firms were not further distanced from the housing supply market including application of fees on appeal. The inclusion of fee refunds if appeal were to be successful would be one consideration.
However, in the roundtable sessions some participants went further suggesting that there should be further streamlining or fast-tracking of planning process for “approved” SME builders and designated small housing sites.
The work of the Commission for Housing in the North also highlighted best practice in working alongside SME builders to assist with site considerations/viability, accessing finance etc. One example of this is listed below.
Wakefield MDC – Unlocking capacity through planning
Wakefield MDC had identified more than 4,000 properties with planning permission that were not yet built out. Further analysis showed that whilst a proportion of these sites were held by the volume builders, others were held by smaller businesses (or individuals). The local authority took the view that they could offer support
to these smaller businesses to help unlock capacity. Working with these landowners as part of the local authority’s commitment to boosting SME builders’ capacity in Wakefield they were able to offer support to access financing options, understand Homes and Communities Agency programmes and promote the support and offer available from the local authority. Whilst this approach is at local authority level, the ability to scale up this model to work across a combined authority market is achievable and the impact on unlocking pipeline capacity would be considerable.
Question 21, 22, 23, 25
The concept of landbanking is frequently visited in debates regarding housing supply and volume builders participating in NHC roundtables disputed the view that they were holding back on supply and felt it was more challenging to get the public sector to bring forward land.
However, in more general terms we welcome proposals to give Local Authorities “sharper tools” including consideration of past performance, completion notices etc. To ensure the tools are effective we must ensure that local authorities have sufficient capacity to use them and whilst we welcome proposals set out in the White Paper to increase financial capacity we would urge the government to work with NHC members to ensure that capacity remains viable.
We agree with the extension of the definition of affordable housing to include low cost home ownership (and products providing a route to home ownership). NHC members have previously reported this had been a barrier regarding planning capacity.
We recognise the government’s desire to increase options around home ownership and welcome the changes signalled in the White Paper regarding Starter Homes. We would ask Government to consider including Rent to Buy within the concept of home ownership product in applying its 10% expectation.
The NHC recognises the Housing White Paper is a useful step forward in shaping a range of policy interventions that can ensure we deliver the right homes in the right places. NHC members welcomed Ministerial comments regarding the differing nature of housing markets and look forward to working with government to ensure that we can bring forward tools and proposals that will not only boost supply of much needed new homes but also work to ensure our existing homes and communities are places people want to live in.
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