National Organisation of Residents Associations


NORA Response to Fixing Broken Housing Market White Paper




NORA members welcome the government's recognition that the UK Housing Market is broken. Unfortunately they do not regard the several proposals in this White Paper adequate even to start the process of repairing and restoring sanity to it. Tinkering with the policies and definitions in the National Planning Policy Framework will not build more houses. Encouraging first time buyers, who are unable to afford to buy their homes, runs the serious risk - when interest rates rise - of replicating the crisis in the mortgage and financial markets of 2007-2008. Without clearer definitions of housing need and housing demand, NORA members do not see a sensible and acceptable way forward.

NORA members see four problems needing resolution, house price inflation, pressure on developers, assessment of need and demand and affordable rented accommodation.

House price inflation

The UK housing market was stable in the 1960s, when mortgages were charged at 3% for the life of the mortgage, based solely on one income and on no more than three years income, which was sufficient then for 65% of the population to own their own homes. This means that in stable times nearly 40% of the population lived in rented dwellings. House price inflation began when Mutual Building Societies turned into banks, and then proceeded to Increase the availability of cheaper and larger mortgages without adequate equity. House purchasers were not buying bigger houses but just paying more for the same. House price inflation is continuing because mortgage interest rates are low and the lid on the kettle - luxurious dwellings in the metropolis - is continually rising as foreign investors seek a safe haven for their capital. Increasing the supply of housing is most unlikely to stop the inflation unless the lid on the kettle is also firmly closed.

The current level of house prices puts ownership out of the reach of the majority of the population. Only those with high incomes or support from relatives can contemplate ownership. The urban environment can only be viable if housing is available for those in lower income groups such as teachers, the police, nurses, transport workers, local authority staff, etc. It is not supportable if the cost of housing consumes half their salary. The demand for rented accommodation exceeds its supply leading to considerable inflation of rents, so even rented accommodation needs to be subsidised for a substantial proportion of the community. Because jobs are less secure than they used to be, rented accommodation is now more appropriate for a greater proportion of the population than before, as periods between jobs can make payment of the higher running costs of buying a property unaffordable.

Pressure on developers

Developers need to make a 20% profit on their proposals otherwise they will not have the capital to continue to operate. Consequently they need to sell their properties, so they cannot be responsible for rented property. Even building Buy-to-Let property is currently a risky proposition, since government policy is designed to reduce their attractiveness to landlords hoping to make purchase easier for first-time buyers.

It is well-recognised that developers have available access to adequate planning consents for at least five years building of houses in over 70% of local authorities, but there are several reasons why the rate of completions does not reflect the availability of planning consents. A key reason is the limited demand for the type of housing that developers can be certain of their 20% profit margin. The current rate of completions obviously goes some way to meet the demand of those customers able to afford the new dwellings. That only 60% of the predicted number of dwellings is being built is highly suggestive that it is the 40% of rented dwellings needed that are not being built.

Another factor is that there is little or no downside to obtaining planning consent and then not completing building. Even digging a trench is enough to constitute 'starting building', which then avoids the need to re-apply for planning permission every three years. We need effective deterrents to leaving sites undeveloped. NORA members believe that to blame Local Planning Authorities (LPA) for the failure of developers to build dwellings is inappropriate. Applying pressure on planning departments and planners to approve more planning consents for dwellings may produce more planning consents, but it does not increase the rate at which dwellings are being built. After all it is the developers - not the planners - who decide whether to build the dwellings that planners approve.

Assessment of need and demand

There is a clear difference between demand, which is presumably measurable from data provided by estate agents and council housing departments, and need, which appears to be derived from household projections made by the Office for National Statistics (ONS) It is not clear how these predictions are made, nor how they are related to the targets set for individual LPAs nor how they relate to relevant demand. There needs to be a clear explanation how the targets for new dwellings are derived. That many LPAs find it difficult if not impossible to plan to meet the imposed targets, because there is no available land or to approve the targets would result in serious damage to their environment, does not seem to have been included in this assessment of targets. Furthermore, there needs to be a clear distinction between local demand - the amount of housing needed by the current residents in an LPA - and 'incomer' demand - the amount desired by residents from elsewhere. Treating the two alike results in the ludicrous situation where, at the extreme, attractive areas would be swamped with high-density housing to meet the 'demand' from incomers, thus destroying the reason why incomers wish to move there. The demand is clearly for 40% of new dwellings to be rented accommodation, and a substantial proportion need to be at subsidised rents.

The predictions made by the ONS and by Eurostat, that our population will rise by a third during this coming century with the indigenous population increasing by 8 million and net immigration by 12 million, demand a far more expansive approach than is envisaged in this White Paper. Garden villages and garden towns are not enough when we need new garden cities.

Affordable dwellings

The definition of 'affordable dwellings' includes a range of different types of subsidy varying from capital gifts from the Treasury to exacting subsidy from those buying dwellings at the full price on the relevant development. The system is complex, and NORA members consider it inequitable and an important reason for house price inflation continuing.

It is the general opinion of NORA members, most of whose members are owner-occupiers, that both the need and the demand are for subsidised rented accommodation. Since 'affordable dwellings' are unlikely to provide developers with a 20% profit margin on their housing proposals, they are not an attractive proposition for developers. Nearly 40% of dwellings need to be for rent, and, if only 10% of developers' dwellings are expected to be 'affordable dwellings', who is expected to build the missing 30% and also deal with the back-log?

NORA members therefore consider the initiative needs to come from local authorities, housing associations and charitable organisations like the Peabody Trust. NORA members regret the past sale of council housing without their replacement, and view with concern the current intention to allow affordable homes to be sold at full market price without restricting their sale to those eligible for affordable homes, so that the size of the market for affordable homes is unlikely to increase.


The several suggestions for changing the NPPF, weakening the definitions of several parameters and imposing penalties are all seen as comparable with moving the deck-chairs on the Titanic. The White Paper's emphasis is on building houses for sale when the real demand and need are for rented dwellings.

The government needs to explain clearly and simply how the housing targets are assessed, and most importantly to recognise it is vital to stimulate a campaign to ensure that at least 40% of new dwellings are built for rent in order to meet the demand and need of the substantial minority of the population unable to fund purchase of their homes.

38 questions in the White Paper provide an opportunity to expand on our arguments posited in this Introduction.


Question 1
Do you agree with the proposals to:
a) Make clear in the National Planning Policy Framework that the key strategic policies that each local planning authority should maintain are those set out currently at paragraph 156 of the Framework, with an additional requirement to plan for the allocations needed to deliver the area's housing requirement? YES
b) Use regulations to allow Spatial Development Strategies to allocate strategic sites, where these strategies require unanimous agreement of the members of the combined authority? YES
c) Revise the National Planning Policy Framework to tighten the definition of what evidence is required to support a plan? YES

Question 2
What changes do you think would support more proportionate consultation and examination procedures for different types of plan and to ensure that different levels of plans together?
The key issues are transparency and cooperation between the several parties involved in designing plans. Intentions may be good, but often the personalities add a dimension that legislation is unlikely to resolve.

Question 3
Do you agree with the proposals to:
a) amend national policy so that local planning authorities are expected to have clear policies for addressing the housing requirements of groups with particular needs, such as older and disabled people?
NO. LPAs have no power to require developers to put in applications for housing to suit groups with particular needs, so it is not clear how 'policies' could achieve this objective. The main housing concern remains the lack of adequate rented dwellings, and this is a matter for government policy rather than for LPAs.
b) from early 2018, use a standardised approach to assessing housing requirements as the baseline for five year housing supply calculations and monitoring housing delivery, in the absence of an up-to-date plan?
NO. NORA members are alarmed at this proposal. They fear that a 'one size scheme' will not fit all. There is a clear need for the assessment of housing need and demand to relate to its feasibility and to recognise that the imposition of unrealistic proposals is unacceptable. A national standardised approach may spread the burden evenly over the country, which would satisfy those LAs with readily available land, while prejudicing others with little or no available land, who fear that their individual identity will be destroyed, so that their area will lose its attractiveness and its viability.
The elements that appear to be the basis for determining the housing requirements are in urgent need of clarification. How the Office of National Statistics derives its forecast of future households and how this is assessed for each LPA needs to be explained and justified. The demand from the local community is understood, but the assessment of the demand from other sources also needs to be explained, clarified and justified. Only then can the community and the LPA be able to support the targets set by Planning Inspectors and judges. Also the relevance of the feasibility of expansion in all areas needs to appreciated in order to avoid the objections and conflict by the community and by LPAs.

Question 4
Do you agree with the proposals to amend the presumption in favour of sustainable development so that:
a) Authorities are expected to have a clear strategy for maximising the use of suitable land in their areas?
NO. Apart from defining suitable sites in Local Plans, it is difficult to understand what extra 'clear strategy' is intended, nor in terms of housing what is actually meant by 'sustainable', a word freely used but not explained or defined.
b) it makes clear that identified development needs should be accommodated unless there are strong reasons for not doing so set out in the NPPF?
NO. Identifying 'development needs' is the 'Elephant in the room' and requires transparency currently lacking in the system. Unreasonable targets are set for LPAs when sites for substantial development do not exist or invasion of protected land is the only solution and unacceptable.
c) the list of policies which the Government regards as providing reasons to restrict development is limited to those set out currently in footnote 9 of the National Planning Policy Framework (so these are no longer presented as examples), with the addition of Ancient Woodland and aged or veteran trees? YES
d) its considerations are re-ordered and numbered, the opening text is simplified and specific references to local plans are removed? YES

Question 5
Do you agree that regulations should be amended so that all local planning authorities are able to dispose of land with the benefit of planning consent which they have granted to themselves?
YES, but sold at the market price.
Question 6 How could land pooling make a more effective contribution to assembling land, and what authorities to play a more active role in land additional powers or capacity would allow local assembly (such as where 'ransom strips' delay or prevent development)? No comment

Question 7
Do you agree that national policy should be amended to encourage local planning authorities to consider the social and economic benefits of estate regeneration when preparing their plans and in decisions on applications, and use their planning powers to help deliver estate regeneration to a high standard?
YES but the destruction of communities and the loss of historic properties must be avoided.

Question 8
Do you agree with the proposals to amend the National Planning Policy Framework to: a) highlight the opportunities that neighbourhood plans present for identifying and allocating small sites that are suitable for housing? YES
b) encourage local planning authorities to identify opportunities for villages to thrive, especially where this would support services and help meet the authority's housing needs?
YES, but village envelopes need to be respected and priority given to rural employees.
c) give stronger support for 'rural exception' sites - to make clear that these should be considered positively where they can contribute to meeting identified local housing needs, even if this relies on an element of general market housing to ensure that homes are genuinely affordable for local people?
NO. The addendum to this proposal - allowing an element of general market housing - would lead to abuse and the loss of the village identity. It could turn it into a commuter setting if owners had no relationship with the village.
d) make clear that on top of the allowance made for windfall sites, at least 10% of sites allocated for residential development in local plans should be sites of half a hectare or less?
NO, because not all LPAs have such sites, and to create them would be unfeasible
e) expect local planning authorities to work with developers to encourage the sub-division of large sites? YES
f) encourage greater use of Local Development Orders and area-wide design codes so that small sites may be brought forward for development more quickly?. YES

Question 9
How could streamlined planning procedures support innovation and high-quality development in new garden towns and villages?
The planning procedures do not need streamlining, but developers and architects need to submit appropriate proposals, that meet the declared local policies, that would result in streamlining the planning process. Appropriate pre-application discussion is essential.

Question 10
Do you agree with the proposals to amend the National Planning Policy Framework to make clear that: a) authorities should amend Green Belt boundaries only when they can demonstrate that they have examined fully all other reasonable options for meeting their identified development requirements?
NO. The whole concept of 'identified development requirements' is the underlying problem that LPAs face. The assessment of the housing needs and demands remains opaque, and, until transparency is ensured, arguments over numbers of dwellings in the differing local authorities will persist. This particular mention of the Green Belt undermines the whole concept of the Green Belt, which was designed to prevent coalescence of urban areas, and this excuse to violate it is unacceptable.
b) where land is removed from the Green Belt, local policies should require compensatory improvements to the environmental quality or accessibility of remaining Green Belt land?
NO. This is not an acceptable deal. It may be compensatory but it is not equivalent. The need to maintain separation of adjacent urban areas remains and any diminution of its function is undesirable. If current pressures on LAs to find land for dwellings when it is not available apart from Green Belt, then the pressure is inappropriate. Once this pressure is accepted as a reason for using Green Belt, surely it is setting a precedent, so that the expected surge in population in the rest of this century will inexorably diminish the Green Belt and even lead to its abolition in extremis.
c) appropriate facilities for existing cemeteries should not to be regarded as ‘inappropriate development’ in the Green Belt?
NO. NORA members ask what constitute 'appropriate facilities' for existing cemeteries that were not included in the original planning consent? d) development brought forward under a Neighbourhood Development Order should not be regarded as inappropriate in the Green Belt, provided it preserves openness and does not conflict with the purposes of the Green Belt?
NO. This is yet another unreasonable excuse to diminish the Green Belt, and setting an undesirable precedent. Neighbourhood Plans should not need to use Green Belt land for dwellings.
e) where a local or strategic plan has demonstrated the need for Green Belt boundaries to be amended, the detailed boundary may be determined through a neighbourhood plan (or plans) for the area in question?
Provided the use of Green Belt land for dwellings is matched by replacing the loss with equivalent land designated as Green Belt in the vicinity.
f) when carrying out a Green Belt review, local planning authorities should look first at using any Green Belt land which has been previously developed and/or which surrounds transport hubs?
This should only apply if the loss is matched by a replacement of equivalent land as Green Belt.

Question 11
Are there particular options for accommodating development that national policy should expect authorities to have explored fully before Green Belt boundaries are amended, in addition to the ones set out above?
YES. Brownfield sites, windfall sites and small sites all need to be found wanting and examinerd in a sequential analysis. The crucial criterion in the first place is whether the demand and the need for the number of new dwellings imposed are appropriate, fair and reasonable.

Question 12
Do you agree with the proposals to amend the National Planning Policy Framework to:
a) indicate that local planning authorities should provide neighbourhood planning groups with a housing requirement figure, where this is sought?
YES, provided the assessment is explained, transparent and feasible without damaging the existing environment.
b) make clear that local and neighbourhood plans (at the most appropriate level) and more detailed development plan documents (such as action area plans) are expected to set out clear design expectations and that visual tools such as design codes can help provide a clear basis for making decisions on development proposals? YES
c) emphasise the importance of early pre-application discussions between applicants, authorities and the local community about design and the types of homes to be provided? YES
d)makes clear that design should not be used as a valid reason to object to development where it accords with clear design expectations set out in statutory plans?
YES. provided the criterion for design expectations is clear and enforced by planning authorities.
e) recognise the value of using a widely accepted design standard, such as Building for Life, in shaping and assessing basic design principles - and make clear that this should be reflected in plans and given weight in the planning process?
YES, but the LPA must include the appropriate Space Standards for dwellings on the grounds that otherwise properties not fit for purpose could be developed. The 2015 Nationally Described Space Standards would ensure that this would occur, and NORA members consider this should be mandatory.

Question 13
Do you agree with the proposals to amend national policy to make clear that plans and individual development proposals should:
a) make efficient use of land and avoid building homes at low densities where there is a shortage of land for meeting identified housing needs?
NO. It should be taken for granted that planners and the community will ensure that land is used efficiently at all sites, but to oblige planners to accept high-density housing to meet 'identified housing needs' where it would drastically change the character of the area is unacceptable. Each case needs to be looked at on its merits otherwise this would give developers carte blanche to ruin attractive areas.
b) address the particular scope for higher-density housing in urban locations that are well served by public transport, that provide opportunities to replace low-density uses in areas of high housing demand, or which offer scope to extend buildings upwards in urban areas?
NO. To 'address the particular scope' could in legal terms oblige planners to accept high-density housing in areas well-served by public transport, to replace low-density housing in areas of 'high demand', and to approve high-rise dwellings when this would drastically change the character of the area, and this is unacceptable. It is essential that planners and the community should be able to consider each case on its merits.
If such policies were introduced with a presumption of granting planning consent, it would be tantamount to giving developers carte blanche to ruin attractive areas, and in particular the case of 'replacing low-density housing' could destroy long-established communities. Planners and the community must retain the facility to prevent the replacement of attractive terraces by alien development.
Where such proposals are considered acceptable adequate off-street parking must always be an important component in any housing development, especially those distant from transport hubs. At transport hubs off-street parking must also be adequate to serve commuters arriving by their own transport.

c) ensure that in doing so the density and form of development reflect the character, accessibility and infrastructure capacity of an area, and the nature of local housing needs?
YES, but the needs and the demands of housing must be proportionate to the environment and justified by transparent explanation for the imposed targets. Again it is vital that the calculation of 'local housing needs' is transparent and accepted by both planners and the local community.
d) take a flexible approach in adopting and applying policy and guidance that could inhibit these objectives in particular circumstances, such as open space provision in areas with good access to facilities nearby?
NO, it is not acceptable to expand the pressure on local facilities of neighbouring communities by approving their absence in new adjacent development. It is open to abuse.

Question 14
In what types of location would indicative minimum density standards be helpful, and what should those standards be?
This is a big question, which really merits an essay.
To increase density of dwellings Georgian and Victorian architects preferred terraces, the former even up to 100 per hectare in four storeys whereas Victorians built back-to-backs usually of two storeys.
Today's architects prefer high blocks of apartments to achieve high densities, preferable especially when there is adequate open space in the vicinity. At the other extreme architects design detached houses with front and rear gardens at a density of less than 20 per hectare, which is clearly extravagant in today's climate and just not appropriate, and will not repair our broken housing market. Terraces even of four storeys could prove attractive in any situation in suburbs of cities or in rural areas provided there is adequate open space in the vicinity, and if a transport hub is not nearby adequate off-street car parking facilities are essential. Near transport hubs adjacent dwellings may not merit off-street parking facilities. but densities of 40 to 50 dwellings per hectare should be feasible.
System-built housing must be encouraged and may have relevance in many locations, but each proposal must be judged on its merits.
Their success depends entirely on high quality design and respect for the neighbourhood. It should be left to each LPA to make these decisions, in the light of local needs, and the need to preserve the character of existing neighbourhoods.

Question 15
What are your views on the potential for delivering additional homes through more intensive use of existing public sector sites, or in urban locations more generally, and how this can best be supported through planning (using tools such as policy, local development orders, and permitted development rights)?
The potential of the described sites for development can only be realised if developers wish to pick up the gauntlet. If they are unwilling to do so, planning cannot persuade them. Even granting PDR is unlikely to be a sufficient carrot unless 20% profit is likely. The sites described are best developed for dwellings for rent and subsidised rent to provide homes for the section of the urban community unable to afford to purchase their homes but provide the vital services essential for the maintenance of society - nurses, teachers, doctors, police, local authority staff, transport staff, etc. This is only likely to be implemented by local authorities, housing associations and charitable organisations.

Question 16
Do you agree that:
a) where local planning authorities wish to agree their housing land supply for a one-year period, national policy should require those authorities to maintain a 10% buffer on their 5 year housing land supply? YES
b) the Planning Inspectorate should consider and agree an authority's assessment of its housing supply for the purpose of this policy?
YES but this proposal is subject to a transparent explanation for the assessment of any targets agreed by the local authority and its community.
c) if so, should the Inspectorate's consideration focus on whether the approach pursued by the authority in establishing the land supply position is robust, or should the Inspectorate make an assessment of the supply figure?
To place the onus on an Inspector to make proposals on assessments undermines the democratic right of the electorate to decide the nature of their environment. This problem exists now and is considered oppressive and dictatorial by many of the electorate.

Question 17
In taking forward the protection for neighbourhood plans as set out in the Written Ministerial Statement of 12 December 2016 into the revised NPPF, do you agree that it should include the following amendments:
a)a requirement for the neighbourhood plan to meet its share of local housing need?
YES, but on two conditions. First that the assessment of housing numbers is agreed and the 'share'is not only agreed but also feasible without damaging the environment.
b) that it is subject to the local planning authority being able to demonstrate through the housing delivery test that, from 2020, delivery has been over 65% (25% in 2018; 45% in 2019) for the wider authority area?
The use of the household delivery test to measure the efficiency of the LPA is illogical since the LPA does not build the dwellings, and they have no power to oblige developers to build them at the rates listed.
c) should it remain a requirement to have site allocations in the plan or should the protection apply as long as housing supply policies will meet their share of local housing need?
The latter is preferable.

Question 18
What are your views on the merits of introducing a fee for making a planning appeal? We would welcome views on:
a) how the fee could be designed in such a way that it did not discourage developers, particularly smaller and medium sized firms, from bringing forward legitimate appeals?
If a fee is to be charged for appeals, it should be properly related to the cost of holding the appeal, and therefore related to the cost of the staff involved, the time taken in preparation, the hearing and the report, but this might prove too expensive for appellants of small companies or firms or householders. Fees assessed on a graduated scale related to the potential value of the proposal would be fairer to small firms.
b) the level of the fee and whether it could be refunded in certain circumstances, such as when an appeal is successful.
NO. The fee should not be returnable. The fee is related to the costs of running the service and is not related to the appeal result. Such a proposal would have wider implications right across the legal system.
c) whether there could be lower fees for less complex cases.
NO. A dividing line for 'less complex cases' would be discriminatory and unfair to some, so this proposal is unwise.

Question 19
Do you agree with the proposal to amend national policy so that local planning authorities are expected to have planning policies setting out how high quality digital infrastructure will be delivered in their area, and accessible from a range of providers?
NO. LPAs have no power to require the provision of high quality digital infrastructure, so this would be just another bureaucratic and useless burden.

Question 20
Do you agree with the proposals to amend national policy so that:
- the status of endorsed recommendations of the National Infrastructure Commission is made clear? and
- authorities are expected to identify the additional development opportunities which strategic infrastructure improvements offer for making additional land available for housing?
YES. However, LPAs have no powers to require owners to put forward land for development or to require developers to make proposals, so the requirement should be clearly limited to identifying the potential of such development opportunities.

Question 21
Do you agree that:
a) the planning application form should be amended to include a request for the estimated start date and build out rate for proposals for housing?
YES. With large projects it would be appropriate where possible to divide the proposal into smaller units, so that the time scales are easier to assess.
b) that developers should be required to provide local authorities with basic information (in terms of actual and projected build out) on progress in delivering the permitted number of homes, after planning permission has been granted?
NO. LPAs have no power to require the provision of high quality digital infrastructure, so this would be just another bureaucratic and useless burden.
c) the basic information (above) should be published as part of Authority Monitoring Reports?
NO. This would create a colossal bureaucracy, and no justification is given for it. It would be of little use, since planners cannot force developers to build any quicker than they intend.
Much more useful would be stiff financial penalties, which LPAs can levy on developers if approved developments are not completed within the times specified in their application as described in 21 (a). It would also avoid partial completion being used as an escape route.

d) that large housebuilders should be required to provide aggregate information on build out rates?
NO. This would create a colossal bureaucracy, and no justification is given for it. It would be of little use, since planners cannot force developers to build any quicker than they intend.

Question 22
Do you agree that the realistic prospect that housing will be built on a site should be taken into account in the determination of planning applications for housing on sites where there is evidence of non-implementation of earlier permissions for housing development?
NO. This would place an unnecessary extra burden on LPAs. On what basis could they judge such issues? The process for granting planning permission should not be made more complex and onerous in this way.
If what is intended is that there should be either ways of encouraging sites to be developed, or penalties for developers who obtain planning permission but fail to complete a development in a reasonable time, then these should be introduced and enforced separately.

Question 23
We would welcome views on whether an applicant's track record of delivering previous, similar housing schemes should be taken into account by local authorities when determining planning applications for housing development.
NO. This would place an unnecessary extra burden on LPAs. On what basis could they judge such issues? The process for granting planning permission should not be made more complex and onerous in this way.
If what is intended is that there should be either ways of encouraging sites to be developed, or penalties for developers who obtain planning permission but fail to complete a development in a reasonable time, then these should be introduced and enforced separately.

Question 24
If this proposal were taken forward, do you agree that the track record of an applicant should only be taken into account when considering proposals for large scale sites, so as not to deter new entrants to the market?
NO. All developers should be expected to produce results promptly and not just seek consents for a land bank.

Question 25
What are your views on whether local authorities should be encouraged to shorten the timescales for developers to implement permission for housing development from three years to two years, except where a shorter timescale could hinder the viability or deliverability of a scheme? We would particularly welcome views on what such a change would mean for SME developers. No comment.

Question 26
Do you agree with the proposals to amend legislation to simplify and speed up the process of serving a completion notice by removing the requirement for the Secretary of State to confirm a completion notice before it can take effect? No comment

Question 27
What are your views on whether we should allow local authorities to serve a completion notice on a site before the commencement deadline has elapsed, but only where works have begun? What impact do you think this will have on lenders'willingness to lend to developers?
YES. We have had instances of developers making a token start on a development and then failing to complete it within a reasonable timescale. Even where the LPA has finally been persuaded to take action, the process has taken far too long to complete.

Question 28 Do you agree that for the purposes of introducing a housing delivery test, national guidance should make clear that:
a) The baseline for assessing housing delivery should be a local planning authority's annual housing requirement where this is set out in an up-to-date plan? YES
b) The baseline where no local plan is in place should be the published household projections until 2018/19, with the new standard methodology for assessing housing requirements providing the baseline thereafter? YES
c) Net annual housing additions should be used to measure housing delivery? YES
d) Delivery will be assessed over a rolling three year period, starting with 2014/15 - 2016/17? YES

Question 29
Do you agree that the consequences for under-delivery should be:
a) From November 2017, an expectation that local planning authorities prepare an action plan where delivery falls below 95% of the authority's annual housing requirement?
NO. How would this affect the rate of delivery?
b) From November 2017, a 20% buffer on top of the requirement to maintain a five year housing land supply where delivery falls below 85%?
NO. If the developers fail to fulfil their quota when they have the planning consents, what is the point of giving them more consents?
c) From November 2018, application of the presumption in favour of sustainable development where delivery falls below 25%?
NO. Giving developers even more planning offers when they have failed cannot be conducive to good practice by developers.
d) From November 2019, application of the presumption in favour of sustainable development where delivery falls below 45%?
NO. This is illogical because it would not produce more houses.
e) From November 2020, application of the presumption in favour of sustainable development where delivery falls below 65%?
NO. This is illogical because it would not produce more houses.

Question 30
What support would be most helpful to local planning authorities in increasing housing delivery in their areas?
Ensure that planning consents for new dwellings include a clause limiting the time of validity of the consent leading to withdrawal of planning consent from those developers failing to build when they have adequate planning consents. In addition give planning authorities the power to refuse to accept repeated planning applications for renewal of consents by relevant developers who have failed to start development in the relevant time span. In addition give power to LPAs to impose substantial fines if approved developments are not completed within the time schedules listed in their applications.

Question 31
Do you agree with our proposals to:
a) amend national policy to revise the definition of affordable housing as set out in Box 4? YES
b) introduce an income cap for starter homes?
YES, provided that this properly reflects income differences across different areas of the country (which the proposed levels of £90,000 in London and £80,000 elsewhere fail to do).
c) incorporate a definition of affordable private rent housing? YES
d) allow for a transitional period that aligns with other proposals in the White Paper (April 2018)? YES

Question 32
Do you agree that: a) national planning policy should expect local planning authorities to seek a minimum of 10% of all homes on individual sites for affordable home ownership products?
YES to the proposal but a wider view needs to be taken. If urban areas are to remain viable, it is vital that 40% of all new housing developments are for rent and not just for purchase. If developers can only be persuaded to accept 10% as affordable housing, this represents only a quarter of the rented dwellings that are essential to try to solve the broken housing market. If developers are expected to meet the demand for rented dwellings, the figure of 10% is far too low and a bold decision would suggest at least 40%. Otherwise local authorities, housing associations and charitable organisations must be expected to provide them.
b) that this policy should only apply to developments of over 10 units or 0.5ha?
YES, but should only apply to 10 units. The likelihood of developers splitting a large site into several sites of 10 units each should need to be covered by an appropriate condition that excludes this manoeuvre designed to circumvent the policy.
LPAs should be free to seek affordable housing on smaller sites, where they consider it appropriate.

Question 33
Should any particular types of residential development be excluded from this policy?
YES. Care needs to be taken to avoid inappropriately including residential developments designed for people with some special needs. For example, should the policy apply to care homes, which are residential but are normally operated by commercial firms or other organisations?

Question 34
Do you agree with the proposals to amend national policy to make clear that the reference to the three dimensions of sustainable development, together with the core planning principles and policies at paragraphs 18-219 of the National Planning Policy Framework, together constitute the Government's view of what sustainable development means for the planning system in England?
NO. The word 'sustainable' is scattered throughout the text of the NPPF and the White Paper without explaining what it actually means. What does 'perform an economic, social and environmental role' actually mean? Until what is meant by these words, the answer to this question is meaningless and pointless.

Question 35
Do you agree with the proposals to amend national policy to:
a)Amend the list of climate change factors to be considered during plan-making, to include reference to rising temperatures? YES
b)Make clear that local planning policies should support measures for the future resilience of communities and infrastructure to climate change? YES

Question 36
Do you agree with these proposals to clarify flood risk policy in the National Planning Policy Framework? YES

Question 37
Do you agree with the proposal to amend national policy to emphasise that planning policies and decisions should take account of existing businesses when locating new development nearby and, where necessary, to mitigate the impact of noise and other potential nuisances arising from existing development?
YES, but the burden of mitigation should fall on the developer and not the existing developments such as business or dwellings. The 'agent of change' should be responsible for protecting the environment, so that any new housing development likely to be affected adversely by existing business needs to have its own protection provided by the developer. In the reverse situation a developer of a new business likely to adversely affect existing residents needs to provide adequate protection for the residents.

Question 38
Do you agree that in incorporating the Written Ministerial Statement on wind energy development into paragraph 98 of the National Planning Policy Framework, no transition period should be included? No comment

April 2017                                                Alan B Shrank - NORA chairman