Dealing with Housing through Local Plans: Key Considerations
Local Plans play a crucial role in housing provision, aiming to meet community needs, direct development effectively, achieve quality outcomes, and attract investment. Adequate housing supply is a significant challenge addressed through strategic planning in compliance with national guidelines. Inspectors' views stress the importance of objective assessment, transparent methodologies, and positive approaches to meeting housing requirements for a sound Core Strategy.
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Dealing with housing through your Local Plan John Baker/Jo Lee 12 December 2013
Why have a plan? To provide for the needs of the community To direct development to the right places and away from the wrong places To achieve development of the right quality To join up the activities of different parties to achieve common objectives To attract investment through the confidence that comes of having a strategy in place
housing provision not the only strategic issue, but the big one! 250,000 homes needed each year 125,000 homes being provided If the plan led system doesn t deliver, the presumption will!
Providing housing Is a fundamental part of setting a coherent strategy in a good and sound Local Plan Setting the level of provision: is the responsibility of the local planning authority requires evidence Must comply with the NPPF PAS Ten key principles for owning your housing number finding your objectively assessed needs http://www.pas.gov.uk/plan-making/- /journal_content/56/332612/4077684/ARTICLE
Key Issues assessing the housing requirement understanding supply and deliverability deciding on the level of provision to make in the local plan dealing with unmet requirements and neighbouring authorities
Inspectors views requirement is not the same as housing supply (Rother, East Hampshire, Ryedale, BANES, Dacorum) should not include policy judgements (Suffolk Coastal) should use national projections as the starting point (Rushcliffe, Ryedale, Dacorum) should consider the whole of the housing market area (Rushcliffe, East Hampshire, Coventry, Hart, Waverley, BANES) should use a transparent methodology and consider all relevant forecasts (Hull, BANES, North Somerset Judgement, South Worcestershire) should take a positive approach to find and meet objectively assessed need and comply with duty (Kirklees, Waverley and Hart)
Inspectors views continued In order for the Core Strategy to be found sound it must at least set out a policy framework which allows for an adequate supply of housing land over the plan period as a whole and a five year supply of deliverable sites to be identified Wigan Core Strategy Inspectors letter 14 March 2013
Appeal decisions NPPF Para 49 and 14 Five year supply Decisions upheld by Secretary of State and costs being awarded. Autumn Statement announcement Overruling employment protection, settlement boundary, landscape, green space and wedge policies and others, although not Green Belt! - Tarporley Cheshire (APP/P1133/A/12/2188938), - Shutterton Combe in Teignbridge Borough Council (APP/P1133/A/12/2188938) - Basingstoke and Deane (APP/H1705/A/12/2188125 ) and Cherwell (APP/C3105/A/12/2189191) - Ingleby Barwick, Stockton on Tees Borough Council (/APP/H0738/A/13/219538) - Guisborough, Redcar & Cleveland Borough Council (APP/V0728/A/13/2190009) - Humberston NE Lincolnshire (APP/B2002/A/13/2196572) 28th Nov 2013
Practice Guidance Be based on fact and unbiased evidence To be done at relevant functional area Assists with defining housing market area and identifying sources Must start from ONS / CLG housing projections Must not make local adjustments about migration unless they have the agreement of other LPAs within their housing market area Only test realistic scenarios not consider purely hypothetical future scenarios Supply constraints must not contaminate the assessment of housing need An allowance should be made to reflect past under delivery Increased emphasis given to market signals, land values, prices, affordability Encourages standard methodology to aid transparency Comprehensive assessment only required every 5 years, but regular local monitoring! Considerable detail on how to calculate affordable housing element
Requirement and provision The requirement must be objectively assessed The provision made through the plan can be different from the objectively assessed requirement Any difference has to be very well justified What to do with the unmet element? Before you start........
The Housing Market Area Understanding your housing market area (HMA) NPPG: The relevant functional area - market based, migration flows and contextual How does your authority area relate to the HMA? What relationship do you already have with neighbouring authorities across the HMA? What information is available for that area?
The SHMA provide evidence of the level, type, size and tenure of housing understand the affordable housing needs, affordability, homelessness, overcrowding and requirements of different sectors of population such as older people involve others by taking a corporate approach, and work with key partners, stakeholders and registered providers inform strategies across the Council and enable continuous monitoring
Establishing an objectively assessed requirement Through a comprehensive understanding of what is required to address demographic change and the implications of achievable economic potential in the area to understanding how your population will change over time. Using data and projections to identify realistic demographic scenarios for growth over the plan period
Demographic issues How did our previous policies shape the population? Is this what we wanted and needed? What would happen if past trends continue? Does the projected population profile fit our vision and aspirations? How can past trends be changed? What policy mechanisms are there to do this? What would the mix of housing be?
Key assumptions Migration rates Average household size assumptions Household formation rates Rolling forward the 2011 based household projections Employment growth Older peoples economic participation rates Unemployment rates and commuting
Migration people arriving from elsewhere in the UK (internal) and abroad and people leaving to go to other parts of the UK and abroad (international) sensitive and volatile can be varied to test different assumptions not influenced by policy choices - no prospect of zero migration so this would be a wholly inappropriate scenario
Jobs and Homes Integration between assessment of and strategies for housing and employment (as required by NPPF). But not all demand for homes is created from new jobs - considerable demand coming from existing population. key issue in the North Somerset high court challenge Jobs based scenarios are useful to: cross check and corroborate demographic information ensure housing doesn t constrain growth influence distribution of jobs and homes
Taking account of commuting Relationship between authority areas and settlements and implications of current commuting levels Travel to work data - 2011 census release due early 2014 What level of self containment do your settlements have? Is it possible to reduce in or out commuting?
approach to seeing the requirement now established by combining demographic and economic scenarios Most credible eg reflecting long term migration trend Demographic led scenarios Employment led scenarios Most credible eg reflecting sectoral forecasts and committed strategy if economic led requirement greater, take this if lower, use demographic led requirement
Relationship with supply issues SHLAA a separate assessment of suitable sites sets out what is available, suitable, deliverable Used for five year land supply Common mistakes: assuming development rates ie per site/sales outlet/pa that are higher than development industry agree not factoring in long enough lead in times between sites getting permission and delivering houses
Understanding market signals Understanding completions, as far back as possible by year to assess long term averages - indication of what was possibly under previous policies and in different /better market conditions Use Developer workshops to explore viability issues: understand market areas land and house prices likely build rates market for different types of houses
Reviewing designations and policies Review of: Landscape designations Employment land Settlement boundaries Green belt Waverley Core Strategy and Hunston judgement Using Sustainability Appraisal as a key tool to understand the implications of various options
Translating the requirement and supply into a provision target Can the requirement be met? Should the level of provision be different ? inability to deliver what is required inability to fund infrastructure needed to make the place work Factor in policy issues: economic growth, reduction in commuting, high affordable need, green belt, environmental capacity Any difference must be FULLY JUSTIFIED
The unmet requirement Effectively a distribution issue To adjacent authorities within the HMA, but what if they: cannot meet their own need are equally constrained Duty to co-operate is a legal test and soundness test ensures working together at the functional area to deliver effective spatial plans http://www.pas.gov.uk/pas/core/page.do?pageId=21337 34
Conclusions The right amount and type of housing as part of a good and sound plan through: Identification and acknowledgement of the objectively assessed requirement Up to date evidence across the Housing Market Area A clear approach - do not use a closed box method to hide assumptions Realistic assumptions - not based on very low migration, over optimistic economic activity rates or rely on large change in out-commuting Appropriate scenarios and options
Conclusions Consideration of the supply side as a separate exercise Robust SHLAA and assessment of deliverability, viability and market capacity, with involvement of developers in the process Weight to be given to addressing affordable housing need, and other market signals Review of policy constraints Deciding provision on the basis of evidence and has to be justified Regular monitoring of information to review assumptions and assess achievement against key objectives
Technical evidence in a political environment the variables that determine the requirement the relationship between the requirement and the level of provision justifying the choice to be made succeeding with your plan
Exploring a fictional scenario The questions: Set out what level of housing should be provided for in the plan and why Explain how you will deliver this level of growth Is there any unmet need to be accommodated elsewhere and how will you deal with this?
