Our Initial Thoughts
The Letwin Review, published with the Autumn Budget, is a ‘win’ for the design sector recognising the importance of well-designed places with varying house types and tenures in distinct settings, and, landscapes and street-scapes that people want to live in. The Letwin Review concludes that the homogeneity of the types and tenures of the homes commonly available from the major housebuilders limits the rate at which the market can absorb such products.
“...if either the major house builders themselves, or others, were to offer much more housing of varying types, designs and tenures (and, indeed, more distinct settings, landscapes and street-scapes) on the large sites and if the resulting variety matched appropriately the desires of the people wanting to live in each particular part of the country, then the overall absorption rates – and hence the overall build out rates – could be substantially accelerated; the outcome at which we should aim…is more variety within those sites.”
We fully support this notion. However, if diversity is the answer to accelerate build out rates, the definition and objective of diversification needs much more exploration – an emphasis on design is important but so is affordability.
The introduction of a National Expert Committee to advise local authorities on the interpretation of diversity requirements is positive. It is welcomed that professional institutions are recognised as having a role to play. However, the current proposition is for this Committee to be voluntary; potentially a tough ask.
Increasing power to local authorities to designate large sites and lead on the masterplan and design code requirements for these sites will need care to avoid stifling innovation both in terms of design and delivery. The wrong kind of code could prevent Modern Methods of Construction being considered and unimaginative design solutions may restrict development capacity.
Resources will need to be found for local authorities to play such a pro-active role in the development process and if Government commits to this it would be a very positive move. The Autumn budget was largely silent on this and we await further announcements in the New Year. It is challenging to see how such large sites will be appropriately resourced by Local Authorities under the current regime.
The Letwin Review
The Review seeks to “explain the significant gap between housing completions and the amount of land allocated or permissioned in area of high housing demand and make recommendations for closing it”. It concludes the amended NPPF does not encourage a diverse enough housing supply on large sites to enable rapid build rates.
Letwin recommends further planning control is needed alongside innovative Local Authority led partnerships to ensure diversity is delivered on large sites of more than 1,500 homes. Where large sites fall in an area of high housing demand, the review recommends the Government should:
- Adopt a new set of planning rules specifically designed to apply to all future large sites (initially those over 1,500 units) in area of high housing demand, requiring those developing such sites to provide a diversity of offering, in line with diversification principles in a new planning document (this could be sites under construction and new larger sites not yet allocated or permitted); and
- Establish a National Expert Committee to advise local authorities on the interpretation of diversity requirements for larger sites and to arbitrate where the diversity requirements cause an appeal because of disagreement between the local authority and the developer.
What is ‘diversity’?
Diversification Principles are suggested in the Review, for example it is “not acceptable for each phase to deliver only one or two housing types”.
Whilst the Review acknowledges that diversity means more varied housing types and more distinctive settings, landscapes and streets space on large sites in areas of housing demand, it is not clearly defined. We fear this could quickly become a discursive debate.
The role of the National Expert Committee will be key to advise local authorities on what and how diversity should be interpreted. Whilst this Committee is recommended to fit within the existing appeals process, its core group of panellists (envisioned as standing members from bodies such as the RIBA, RTPI, RICS, etc), are expected to participate on a voluntary basis – potentially a challenging, time-consuming and wide-reaching role.
The Committee would need to consider the impact of ‘different tenures, housing types and sizes, design, and specialised housing” on build out rates of large sites’ with the key questions to be asked whether the masterplan and design code cause the rate of built out to be as great as possible, consistent with the viability, beauty and liveability of the development.
When would this come into force?
Letwin suggests a written ministerial statement would help to fill gap between now and the primary legislation being introduced. During the transition period of up to 2020, Letwin recommends that to improve build out rates funding is made available for large sites in areas of housing demand where large sites (1,500+ homes) conform with the new diversity provisions. Secured through the signing of a new Section 106, Letwin seeks that this approach will get large sites to agree to the new diversity rules in advance of formal legislation for the remainder of the site. Although this may mean applicants need to revisit planning consents to access the funding.
The key two challenges here will be firstly understanding what the new diversity provisions mean and secondly if the funding will be sufficient enough to attract applicants, particularly where significant amendments may result in additional consultant, architecture and planning fees outweighing the applicant’s incentive to go to back to planning to incorporate the diversity principles.
It is strongly welcomed that the Letwin Review recognises the need to create more varied housing types and more distinctive settings, landscapes and streets space on large sites in areas of housing demand to increase absorption rates and therefore build out rates.
Simon Bayliss, Managing Partner of HTA Design:
“Given recent positive signals from within Government acknowledging that housing numbers will rise only if design quality significantly increases, it is disappointing not to find any reference to the positive recommendations made in the Letwin Review of build-out rates published, presumably not by coincidence, on the same day. The review concludes that housing would be delivered more quickly if there were more ‘varying types, designs and tenures’, as well as ‘more distinct settings, landscape and street-scapes’, delivered by a more diverse group of developers and with greater oversight from local authorities. One might have hoped the budget would support this through increased investment in the planning system, reversing the vandalism of this valued institution over the past 8 years, rather than a thin promise to respond to the review in the new year at a time when one expects there may be other matters topping the political agenda”
Riette Oosthuizen, HTA Design Planning Partner:
“The Letwin Review’s focus on the need for diversification is refreshing. We hope that despite today’s silence on further funding commitments to local authorities for planning, legislative changes implemented as a result of the Letwin Review are accompanied by an appropriate funding commitment from Government. Making local authorities largely responsible for leading on the delivery of large scale schemes through appropriate masterplans and design codes would require wide ranging skills diversification and resources”.