2020 is likely to be a difficult year for RBK and its residents.
A revised National Planning Policy Framework (NPPF), with tough new sanctions for local authorities that are failing to build sufficient housing, and a new London Plan, that significantly increases housing quotas across the capital, present RBK with a significant challenge.
A new annual Housing Delivery Test assesses a Local Authority’s house-building performance over the previous three financial years. Those that have failed to build at least 75% of their quota will be stripped of the power to determine their own planning policy for 12 months.
By 2021 RBK needs to more than double the number of new homes it is building each year if it is to deliver its increased housing quota and avoid these new sanctions. It also has to maintain that level of building for the next 20 years, probably having to build as many as 30,000 new homes by 2041.
Over the coming years residents are likely to see an increase in the number of planning applications that seek to demolish existing homes and replace them with an increased number. One such application has recently been submitted to demolish 8 semi-detached houses in Chessington and replace them with 17 smaller houses and 28 flats.
It will be tempting for residents to resist this level of housebuilding, but is that a wise move? If new houses are not forthcoming in sufficient enough numbers, sanctions will be applied and new developments will be automatically approved regardless of the views of local residents.
When launching the new rules in 2017, the Secretary of State made communities an offer – those that work with him to help solve the current housing crisis will be offered generous concessions and an exemption from the new sanctions.
Instead of objecting to planning applications they consider to be inappropriate, communities can now detail in advance what is acceptable to them and where the new housing that their area requires should be located. Crucially, a lower threshold of 45%, instead of 75%, is all that is required to pass future Housing Delivery Tests for communities that accept this offer and write a Neighbourhood Plan for their area.
To pass the 2024 Housing Delivery Test and avoid sanctions, RBK needs to have built 2,169 units over the previous three years*. For communities that write their own Neighbourhood Plan, sanctions will only apply if RBK has failed to build at least 1,302 units. That is a serious concession!
To write a Neighbourhood Plan, a community needs to identify an area that their plan will cover and establish a Neighbourhood Forum, a new type of community group that provides a platform for everyone who lives or works in the area to contribute ideas and solutions towards the plan. The Forum applies to RBK for designation and, if successful, then conducts an extensive consultation to determine how the community wishes to deliver their housing quota and how local strategic policies should be interpreted by developers.
Neighbourhood Plans that allocate sites for all future housing also protect other sites in their area from any redevelopment. Plans can also protect valuable community assets, such as open green spaces, a local pub or a local shop/service.
Current independent analysis suggests that RBK could be sanctioned for a prolonged period, possibly as long as 10 years. Malden Rushett Community has been set up so that residents in Malden Rushett have the opportunity to take full advantage of the new rules and to ensure that the village is protected from the impact of any future sanctions and is currently applying to RBK for designation.
Other communities in the South of the Borough may also conclude it could be in their interests to make the new rules work in their favour rather than to fight them.
* calculated using the London Plan’s proposed housing quota of 964 units [“Mayor’s Intend to Publish” version, Dec 2019].