Assessing housing need at a sub district or local level could be the key to unlocking development

What is ‘sub-district’ housing need?

Simply put ‘sub-district’ housing need is a measure of housing need in a smaller geographical area than a Local Planning Authority’s (LPA’s) overall (i.e. District or Borough) administrative area. This could be at settlement, parish, or ward level for instance.
A recovered appeal in Long Melford, Suffolk in April 2020 highlighted the value and importance of submitting evidence of the need for housing locally at sub-District level, and not just at District level. The Secretary of State (SoS), in this case, concluded that the appellant (a developer) had identified a need locally for both market and affordable housing, and this attracted significant weight in the planning balance and overall conclusions of the appeal, which was allowed.

The commonly used method of calculating ‘need’

At the moment LPAs are expected to determine minimum housing need for their administrative area (Borough or District) using the National Planning Policy Framework (NPPF’s) Standard Method, the baseline for which is the Department for Levelling Up, Housing and Communities (DLUHC) 2014-based household projections. The Standard Method, for now, provides a ‘fix’ on minimum housing need at LPA level.

A fix on minimum housing need at LPA level is one thing, but how does this inform housing need at sub-district level for a specific settlement or local area?

The answer is, it doesn’t, not without first having an understanding of settlement population, its characteristics, and Local Plan policies for the specific settlement.

In some cases, this understanding will be used to ‘divvy up’ the local authority’s need based on the Standard Method, but there are many reasons, for the sake of good plan making and sustainable development, that a bottom up, rather than top down assessment of settlement need will be required.

In the case of Long Melford, it was identified as a ‘Core Village’ in Babergh District Council’s Development Plan. In the recovered appeal decision notice the SoS referred to the ‘Bergholt judgment’ in which the High Court determined that the reference to a local housing need in the context of Core Villages was the “housing need in the village and its cluster, and perhaps in the areas immediately adjoining it.” Assessment of need in this local area was therefore of value and importance, as the Inspector’s comments ultimately highlighted.

Determining Neighbourhood Housing Requirements and Housing Need

The revised National Planning Policy Framework (NPPF, 2021) clarifies that Local Plan strategic policies should set out a housing requirement for designated neighbourhood areas – which it states should reflect the overall strategy for the pattern and scale of development, including relevant housing allocations.

The revised NPPF confirms that unless there has been a significant change in circumstances, such figures should not need re-testing at the neighbourhood plan examination, which simply emphasises the need to rigorously test such numbers at Local Plan examinations.

In the event that it is not possible to provide a requirement figure for a neighbourhood area, within the Local Plan, the revised NPPF requires that local planning authorities provide an indicative estimate. That indicative estimate should account for:

The latest evidence of local housing need;

The population of the neighbourhood area;

The most recently available planning strategy of the local planning authority.

The importance of determining adequate housing need at the local level is highlighted by the social objective underpinning the sustainable development principles of the revised NPPF. But it is also important to apply the Planning Practice Guidance (PPG) which is clear that the assessment of housing need should be ‘unconstrained’ and be carried out before and entirely separate from determining a housing requirement.

The revised NPPF refers only to ‘neighbourhood areas’, but sub district assessments can cover a number of geographical areas and can be a valuable tool to test the robustness with which a Local Plan proposes to distribute housing need across a LPA area, as well as assessing the localised need for a particular residential development.

Despite the calculation for minimum housing need at LPA level being standardised, there remains significant opportunity for interested parties to firstly test a LPA’s housing need, against wider Local Plan policies and vision, as well as testing whether the housing need identified at a sub-district level is appropriate, and where or not an alternative can be properly evidenced.

With housing need and appropriate sites such a hot topic, sub-district housing assessments will become more and more important to support Local Plan representations, planning applications, and appeals as the Long Melford decision highlights.