Planning consent – simple and successful with well-presented data

16 Aug Planning consent – simple and successful with well-presented data

Planning application numbers for residential developments in England have slumped to their lowest for at least 16 years, figures published in April 2023 show. This is partly because a complex planning system may be deterring would-be developers. But there is an encouraging upside too.

The good news is that well-sourced information can make the application process smoother, swifter and an efficient streamlined route for gaining permissions not only as the economy faces strong financial headwinds and a long post-pandemic recovery, but also during the current housing crisis.

Data working harder

The key, based on experience, is being able to provide the detailed information elected members in many different planning authority areas need to make positive local decisions, while also working very closely with their planning officers to prepare and implement strong proposals successfully.

This is an Enzygo (www.enzygo.com/planning/) area of expertise, and one where we believe we are strongly placed to help boost the economy.

Because it is now vital across many sectors, I have outlined examples of low-carbon infrastructure projects with carefully-controlled environmental impacts that we have helped clients and developers to deliver recently.

Housing in crisis

However, the UK is also facing an acute housing shortage that could potentially be made worse by high property prices, plus rising interest and mortgage repayment rates.

With this in mind, I also focus below on house-building and the Government’s controversial 300,000 annual new homes target. In particular, I look at possible reasons why residential applications are falling, plus the growing priority of providing social and affordable housing.

To illustrate this last point, I show how, through Enzygo’s land use approach, we were able to secured planning permissions for a Buckinghamshire charitable housing association to reuse vacant garage sites in an urban area.

As a result, six new dwellings will now be available for affordable rent – usually up to 80% of market rent – or for social rent, with typical discounts of 50% to 60% below market sector rents.

Prince William’s new initiative as the Prince of Wales which sets a five-year ball rolling to ‘end’ homelessness starting at the Duchy of Cornwall’s Poundbury estate is also important in this context.

Enzygo – a wide modern remit (www.enzygo.com)

Because careful data handling was crucial in each case, I want to start by listing some of the diverse renewable energy and energy storage, residential, holiday resort, green transport, and industrial projects we secured permission for in 2022.

They included 140MW of new solar photo-voltaic site installations, 385MW of battery energy storage capacity, and 20MW of standby gas energy facilities. One of our recent flagship project is ‘Capturing Oxfordshire sunshine … with extra community benefits’ (https://enzygo.com/news/capturing-oxfordshire-sunshine-with-extra-community-benefits/).

At the same time, we worked with four local planning authorities as clients, managed residential planning applications for more than 300 new properties, and secured consents at four different holiday parks across England, EV charging points in three municipal areas, a pharmaceutical building extension, 500kW of wind turbines, several rural dwellings, and an energy-from-waste plant.

Roofs over homeless heads

Unfortunately, the fall in residential applications is increasing pressure on local authority planners, with recent policy changes partly blamed. When the first version of the National Planning Policy Framework (NPPF) was issued in 2012, a ‘bounce’ in applications was attributed to its simplicity.

But continuing reforms, some commentators suggest, could be delaying local plans and putting off developers, with new issues like ‘beauty’ complicating discussions between councils and developers. The Levelling Up and Regeneration Bill going through parliament may make this increasingly difficult.

The Government did commit in October 2022 to provide 300,000 new dwellings annually. But Secretary of State for Levelling Up, Housing and Communities, Michael Gove performed a policy U-turn in December after a threatened rebellion by Conservatory MPs concerned that the target was described as a ‘starting point’, even though it was only ‘advisory’.

Falling figures

DLUHC figures released in April 2023 show that applications in England for new dwellings, or to improve old ones, were their lowest in at least 16 years (‘Planning applications in England: October to December 2022’ – https://www.gov.uk/government/statistics/planning-applications-in-england-october-to-december-2022/planning-applications-in-england-october-to-december-2022); data shows that local authorities received 409,459 planning applications in 2022, down by some 14% on the year before; application numbers have fallen steadily since early 2021.

This followed a Home Builders Federation study warning that England’s housebuilding starts could fall below 120,000 to their lowest in more than 80 years (‘Housing pipeline report – Q4 2022 report‘ – https://www.hbf.co.uk/news/housing-pipeline-report-q4-2022-report-published-april-2023/).

Party policies – what can be done?

The next general election must be held by 28 January 2025. For Conservatives, this could provoke a policy split between home-building for younger people, and the anti-building NIMBY sentiments of older voters. A Labour victory might see wholesale policy changes.

An alternative Conservative approach might be to expand ‘help to buy’ support for first time buyers to qualify for mortgages. However, soaring interest rates would suggest this is not feasible. Increasing credit without actually building more homes could simply serve to inflate market prices.

Labour says it will support prospective buyers, and might also introduce a pro-building agenda that allows local authorities to buy land through compulsory purchase at a fraction of its potential cost. This would remove the ‘hope value’ that is created in anticipation of receiving planning permission for developments over and above what land or property are worth in their current form.

Another option for Labour might be to increase the national housing stock by building a fresh generation of ‘new towns’, while relaxing existing restrictions on green belt sites. Both ideas are controversial.

Types of application

Permission may depend on whether new-build or adapting existing buildings is involved. Permitted development rights can mean, for example, that changes from shops to residential use are relatively easy, subject to a prior approval application, and acceptable transport, contamination risk, noise, flooding, and natural light criteria.

However, new residential property consents are more complicated since technical considerations must be demonstrated to achieve policy compliance, and whether the authority has a five-year housing supply. If not, it may be easier to gain planning permission as it becomes harder to prove whether supply will meet demand.

Other factors may include acceptable drainage, environmental and ecological considerations, highway issues, local community views, and individual design details.

Social and community, plus affordable housing

Given the current housing shortfall when many community members are already under intense financial stress, the focus is growing on low-cost and subsidised housing that both put a roof over vulnerable heads and help people up onto the first rung of the property ladder.

Social housing is provided by government-funded organisations. However, affordable housing -defined as ‘social rented, affordable rented and intermediate housing provided to specified eligible households whose needs are not met by the market’ – is available via private developers or landlords.

In general, affordable housing is for those with a household income at or below the median, as rated by a recognised housing affordability index. The UK Government standard definition is any property provided at least 20% below market value, and is relevant for both rentals and properties for sale.

But people are eligible for affordable housing if they cannot afford to rent or buy housing from the private sector. The qualifying details are too long to show here. However, I give an official web reference later.

Enzygo – a further success for Red Kite

The successful planning statement we prepared in 2021 for Red Kite Community Housing (https://redkitehousing.org.uk/) was submitted along with full planning applications to demolish, clear, and redevelop vacant and under-used garage sites in built-up areas of High Wycombe. The goal was to gain planning permission to build three well-designed, high-quality, two-storey semi-detached, three-bedroom family homes for affordable tenure (renting).

– Our client – Red Kite is a tenant-led not-for-profit charitable housing association that already manages more than 6,500 homes. Consent received from Buckinghamshire Council for its recent High Wycombe application increases this housing stock.

– Information provided – The planning statement included details of: – the site and its surroundings; planning policy, the Planning Balance (positive versus negative impacts of granting planning permission), an assessment of environmental impacts, plus a conclusion.

– Potential environmental impacts – These were considered in Enzygo’s technical documents which included: – hydrology, arboriculture, geo-environmental and transport assessments.

– After an initial response from the Council, we worked collaboratively with Red Kite to fine-tune the detailed design and layout so that: – roof heights and ground levels relate to existing neighbourhood housing; there is a shared surface area with manoeuvring space for vehicles, plus EV charge points.

Other features included: – private amenity space, off-street parking, bicycle storage, and good access to bus routes; sustainable modes of transport are encouraged.

– Good neighbour – The development is considered to be sustainable and will contribute to the surrounding community by creating a more active street frontage, natural surveillance, and proposed soft landscaping.

Construction materials will use a palette of colours that blend in with existing buildings and the local built environment.

Full documentation

In addition to the planning statement, to make decision-making by the Local Planning Authority easier, we also submitted: – a site location plan; proposed block plan; proposed site plan; surface water drainage scheme; ground investigation report; highways technical note; preliminary ecological survey; and a design and access statement.

Royal intervention

It is important to mention that in June 2023, Prince William pledged to ‘end homelessness’ and build social housing on the Duchy of Cornwall’s 130,000-acre Poundbury estate in Dorset. He also added personal comments that homelessness is only being ‘managed’ and not ‘prevented’.

As start-up finance, the Prince of Wales’s charitable foundation will provide £3 million for his five-year ‘Homewards’ campaign at six UK locations to make homelessness ‘rare, brief and unrepeated … in a modern and progressive society’.

Under the national planning policy framework, major developments with housing must offer 10% of affordable homes; Poundbury already includes 35% in addition to private homes.

The Prince is also patron of Centrepoint (www.centrepoint.org.uk), a charity providing homeless young people with accommodation, health support and life skills to help them back into education, training and employment. In June 2023, he opened Centrepoint’s new Reuben House in Peckham as a block of studio properties for 33 homeless young people with rents set at a third of their incomes.

Definitions

There is no agreed definition of what affordable housing actually means.

However, annex 2 of the National Planning Policy Framework (2021) defines it as: – ‘housing for sale or rent, for those whose needs are not met by the market (including housing that provides a subsidised route to home ownership and/or is for essential local workers); and which complies with one or more of the following definitions’ … that are shown online.

Full details at ‘National Planning Policy Framework’ (https://www.gov.uk/guidance/national-planning-policy-framework/annex-2-glossary) cover under the main heading of Affordable Housing: a) Affordable housing for rent: b) Starter homes: c) Discounted market sales housing: and d) Other affordable routes to home ownership.

Planning, and housing in particular, can at times be a complex and daunting subject. If you would like to discuss any of the issues raised above in more detail, please feel free to contact me directly.

Rob Gandy, Principal Planning Consultant, Enzygo Ltd