National Organisation of Residents Associations


NORA Response to Updating the National Planning Policy and Guidance




Our view of the problem of determining Housing Need Assessment follows from a study of the latest ONS Table 209, which supplies the following data regarding the history of the annual completed dwelling houses in England since 1969. This determines our answers to the six questions in this Consultation Paper. The current housing need is divisible into two sections.

First, there is the tremendous backlog of public sector dwellings for rent due to the virtual cessation of local authority production of new dwellings in 1979. With annual average production of 100,000 new dwellings by English local authorities from 1969 to 1978 and its rapid decline ever since must mean there is now a deficit of 4M public sector dwellings, which would have served the needs of those, who could not afford to buy or rent in the private sector.

The second need is for those in England, who can afford to buy in the private sector. The private sector builds new dwellings at a rate they can sell them, since to build houses without purchasers would lead to bankruptcy. If there was the market, surely entrepreneurs would take advantage of it. So it is reasonable to conclude that the demand for new dwellings for sale is usually met by the prevailing rate of house building. The demand depends on numerous factors other than ONS household predictions, a view that is supported by the ONS and well-described in documents from the now-deceased NHPAU.

The production of new dwellings in the private sector has varied from a maximum of 176,000 new dwellings in 1988 to a low of 83,000 in 2010 with an annual average of 125,000 presumably reflecting the fluctuating demand consequent on changes in the several parameters that affect demand. It presumably explains why the English private sector has never managed to complete 200,000 new dwellings in any year since 1969, the earliest date in the ONS Table 209, since the demand never reached that level.

Even were local authorities able to build at the rate prevalent prior to 1978, the average total annual production of new dwellings in England would be no more than 225,000. Only a tremendous campaign to fund and organise local authority production would even this figure be reached, so the figure of 300,000 must be a dream most unlikely to be fulfilled. Only in one year, 1969, did the total number of all new dwellings in England including the private sector, local authorities and Housing Associations reach 300,000. The average total production in England prior to the collapse of the public sector was 250,000 a year.

This analysis leads to the conclusion that the housing needs for the private sector would be met by providing planning support for no more than 175,000 new dwellings a year. Providing more planning applications for the private sector is misleading and places unsupportable pressure on the planning system and the community.

The key to the problem is the production by the public sector. How fast the backlog of 4M dwellings can be filled depends entirely on its funding. Using a formula based on ONS predictions is unrealistic and the use of the Affordability Ratios to increase local targets is of little value other than to oblige planning departments to grant more planning consents that are most unlikely to be fulfilled and cause much distress to all those involved in the planning process.

Planners may plan the number of new dwellings to be built, but it is the developers, who decide how many to build and when to build them.


Q1: Do you agree that planning practice guidance should be amended to specify that 2014-based projections will provide the demographic baseline for the standard method for a time limited period?


The use of 2014-based projections is unrealistic and causes avoidable distress to all involved in the planned process including planners, the developers and the relevant communities.

Q2: Do you agree with the proposed approach to not allowing 2016-based household projections to be used as a reason to justify lower housing need?


The 2016-based household projections give more realistic calculations and are more likely to produce targets that can be fulfilled.

Q3: Do you agree with the proposed approach to applying the cap to spatial development strategies?


Simplifying the calculations reduces stress.

Q4: Do you agree with the proposed clarifications to footnote 37 and the glossary definition of local housing need?


Because we question the whole process of defining needs when the real question is how to match demand with feasibility, the clarifications are only helpful if they reduce stress on those involved in the planning process.

Q5: Do you agree with the proposed clarification to the glossary definition of deliverable?


Since deliverability is entirely in the hands of the developers, who are at the mercy of the potential buyers, it may be helpful to assess the success of the planning process, but the hope, that it will hurry the building process, is highly unlikely if, for reasons beyond control, buyers disappear from the market.

Q6: Do you agree with the proposed amendment to paragraph 177 of the National Planning Policy Framework?


Until Brexit occurs, decisions taken by the relevant EU bodies need to be obeyed by all EU members. In this case the EU decision makes sense anyway, so we should abide by it even after we leave the EU.

November 2018                                                Alan Shrank - NORA chairman