🔢 Definitions
Let:
- Aₜ = Affordability ratio at time t = average house price ÷ average earnings
- HSₜ = Total housing supply delivered at time t
- HDₜ = Total housing demand at time t
- Pᵤ = Permitted sites not delivered (land banked)
- Lₐ = Land allocated in the Local Plan but not brought forward
- W = Windfall (speculative) development outside the Local Plan
- Mₑₕdc = Set of powers and tools available to EHDC to manage delivery and control speculation
- Uₑₕdc = Powers actually used by EHDC at time t
- HTₜ = Housing Target at time t (as calculated by government formulas, including affordability uplift)
🔧 Available Powers: Mₑₕdc
EHDC’s mechanisms to improve delivery and resist speculation include:
- Local Plan Delivery Phasing
- Allocation policy requiring application and delivery within defined timelines
- Phased land release tied to infrastructure triggers
- Refusal Weighting in Planning Policy
- Local Plan or SPD language deprioritising windfall applications from developers who control undelivered allocated land
- Planning Position Statements (PPS)
- Non-statutory guidance stating that speculative applications from land-bankers are discouraged
- Section 106 Legal Agreements
- Delivery milestones tied to development commencement or occupancy
- Infrastructure-first triggers
- Authority Monitoring Reports (AMRs)
- Public flagging of under-delivered sites and developer performance
- Site Deallocation Review Policy
- Triggering re-evaluation or replacement of undelivered allocations during Plan updates
- Strategic Site Selection Screens
- Conditioning new allocations on past delivery performance of landowners
- Lobbying for Legislative Reform
- Motion to government to seek legal powers to penalise land banking
📌 Premises
- Government housing targets (HTₜ) are calculated using a formula that includes:
- Baseline need (from demographic trends), and
- Affordability uplift (linked to Aₜ, the affordability ratio).
- Aₜ increases when supply is constrained:
If HSₜ < HDₜ, then average house prices rise faster than earnings ⇒ Aₜ ↑. - EHDC has multiple powers (Mₑₕdc) that can help:
- Accelerate HSₜ (housing supply),
- Reduce speculative incentives (W),
- Enforce timely use of allocated land (Lₐ), and
- Track and respond to delivery delays (Pᵤ).
- But EHDC’s actual use of these powers is incomplete:
Uₑₕdc ⊂ Mₑₕdc
⇒ i.e., some available tools are unused or underused. - Consequently:
- Land banking (Pᵤ) and allocation delays (Lₐ) continue,
- Speculative development (W) fills the gap but worsens infrastructure delivery and affordability,
- HSₜ stays suppressed, even if land is “available” on paper.
- The suppressed supply leads to rising Aₜ, which causes:
- A higher affordability uplift in the national housing formula,
- An increased Housing Target (HTₜ) for EHDC.
🔁 Construction
- Let HSₜ = f(Pᵤ, Lₐ, W, policy enforcement)
- If Uₑₕdc < Mₑₕdc, then Pᵤ and Lₐ remain inactive, and W increases
- ⇒ HSₜ < HDₜ
- ⇒ Aₜ ↑ (affordability ratio worsens)
- ⇒ Affordability uplift ↑ in housing formula
- ⇒ HTₜ ↑ (housing targets rise)
Therefore:
EHDC’s underuse of its own delivery and anti-speculation mechanisms directly leads to increased housing targets.
📎 Conclusion
The rise in EHDC’s housing targets (HTₜ) is not an unavoidable outcome of national policy or external market conditions alone. It is mathematically and procedurally linked to the Council’s own failure to fully utilise available powers (Mₑₕdc) to:
- Enforce delivery on permitted and allocated land,
- Discourage speculative windfall development,
- And actively manage the relationship between housing supply and affordability.
Thus, EHDC is partially responsible for the increase in Aₜ and the resulting inflation of housing targets, by failing to activate the full suite of tools designed to prevent this very outcome.