The American poet Paul Lawrence Dunbar chided the reader 'Don’t talk to me of solemn days in autumn’s time of splendor' in his poem 'Merry Autumn'. 

Well the Chancellor certainly is in a time of splendour.  My fear is that the funding of the new affordable housing will not bear fruit in Spring - if the legislative proposals in the Housing and Planning Bill are unable to deliver the 400,000 affordable homes a year that the Chancellor requires by 2020.

One of the key measures in the Bill is the Brownfield Register. This is supposed to facilitate unlocking land to build new homes. It is to give housing sites identified in the brownfield register, local and neighbourhood plans planning permission in principle, and providing an opportunity for applicants to obtain permission in principle for small scale housing sites. The idea is that land in the Brownfield Register will obtain automatic planning in principle.

But where will the planning officers be to assess whether the land is actually deliverable in principle?  Will that matter?  Will local authorities have to make an assessment at all? Will they have to go and look at these sites, or it is intended that they simply trust that anyone offering a site has already considered if it is genuinely capable of development? Will an authority be able to simply fill up its register with any land, even unsuitable land, and report to the Secretary of State, "job done"?  Let’s hope housing associations and charities are geared up to do this essential due diligence, because planning departments have been pared to the bone.

There is a difference between ensuring there is a list of possible sites, and a proper grant of planning in principle to deliverable sites. If the starter homes and extended help to buy initiatives are to succeed, there has to be a commitment to more than compiling lists and granting planning permissions that will never be implemented.