PPS3: Housing (November 2006)
Planning Policy Statement: 3 (PPS3) is a striking document, which puts the role of the 'evidence base' provided by the SHMA in a much more prominent role than ever before. It also contains much more specific and challenging requirements for the evidence base, as can be seen from the following summary extracts:
Para 22 of the PPS says:
'based on the findings of the Strategic Housing Market Assessment and other local evidence, Local Planning Authorities should set out in Local Development Documents:
the likely overall proportions of households that require market or affordable housing, for example, x% market housing and y% affordable housing
The likely profile of household types requiring market housing e.g. multi-person, including families and children (x %), single persons (y %), couples (z %)
The size and type of affordable housing required'
None of these requirements was in previous detailed Guidance: only a part of item (iii) was stated in (Circular 6/98). The PPS is also much more demanding as to the role of stakeholders such as developers. In para 23 it says:
'Developers should put forward proposals for market housing which reflect demand and the profile of households requiring market housing, in order to sustain mixed communities'.
This helps to explain the existence of the middle one of the three key requirements of para 22 of PPS3 quoted above. Clearly both the Steering Group for an SHMA and developers need to be aware of the likely pattern of demand from different types of households.
PPS3 and the Practice Guidance: A problem
The Practice Guidance (published in March and (slightly revised) in August 2007) provides a helpful context for carrying out an SHMA, but falls short of providing the means to producing the key outputs of PPS3: Housing (Nov 2007) which is its central purpose.
This problem has been widely realised in the field of SHMA work, but has not yet been recognised or addressed by CLG (Communities and Local Government), the Government department which issued them both.
This has caused problems, since a number of SHMAs have been done which in fact do not provide what PPS3 wants, although they do conform to the Practice Guidance. There are two reasons which underlie this situation:
- Chiefly, the Practice Guidance suggested that SHMA's could be done without using a household survey database (usually gathered for the survey in question and referred to as 'primary survey'. Since publication of the Practice Guidance the gap between the outputs of the Guidance and PPS3 have become apparent. When SHMAs done without the analysis base of household survey come to be tested, their inability to provide the key outputs of PPS3 will be exposed.
- Even where household survey data is used, the quality of some of the work in the SHMA field is poor, and as yet there is no quality control mechanism.
The wider aim of the Government, which is entirely praiseworthy, is to be able to add together subregional SHMA outputs to produce regional and national estimates of housing market behaviour for future policy. This aim will continue to be frustrated until both the points just mentioned are addressed.