Friday, 26 July 2013

Five Year Land Supply in East Devon: CPRE

The Campaign to Protect Rural England has been active nationally of late:
CPRE calls for a higher tax on second homes. | Save Our Sidmouth
CPRE National Campaign | Save Our Sidmouth
Save our countryside - sign our charter
Our Countryside Charter – Campaign launch - Campaign to Protect Rural England
England's 'precious, inspiration and irreplaceable' countrryside at risk from developers, say celebrities - Telegraph
Letting developers vandalise the countryside won't solve the housing crisis | Nick Herbert | Comment is free | The Guardian

Video: Nick Boles suffers heckling and walk-outs at stormy CPRE meeting - Telegraph

And the CPRE has been active locally:
campaign to protect rural england | Search Results | Sidmouth Independent News

The minutes of the Overview & Scrutiny Committee from March reflected concerns about the lack of a plan for housing:

Five Year Land Supply in East Devon

Dr Margaret Hall of the Campaign to Protect Rural England challenged the base housing need figure used which she said was now out of date – this being evidenced through the Census which showed a lower population than had been predicted. She said it was important for the Council to also acquire an up-dated strategic housing assessment, as there had similarly been a fall in housing requirements compared with that predicted. Dr Hall said that the Council should include a disaggregated 5-year land supply within its policies so that this approach would have more weight.

The East Devon branch of the Campaign to Protect Rural England (CPRE) has written to EDDC’s chief executive Mark Williams, making a convincing case for housing numbers in the Local Plan to be revised downwards.
Based on numbers drawn from the latest census of 2011, the East Devon branch’s secretary, Margaret Hall, has calculated that just 11,000 houses need to be built in East Devon until 2026, rather than the ‘at least 15,000 houses.’ currently proposed in EDDC’s Local Plan.
The paper is reproduced (with permission from Dr Hall) below.  Some of the information is quite technical and I have not been able to reproduce the table due to formatting problems, but you should get the jist.  First is the letter: 

Dear Mr Williams
I am sorry to have missed you on the telephone on December 20.
CPRE has serious concerns about the lack of 5 year housing supply, as evidenced in the two recent appeal decisions in Feniton and Ottery St Mary.
This will lead to further opportunistic planning applications by developers, and could lead to demotion of EDDC status. Enclosed is a paper dealing with Housing Need, which I hope will assist you.
The current draft plan is unsound, which needs to be corrected now, and certainly before the Examination in Public. This is because the targets are unachievable, as the wrong basis has been used for Housing Need. The key points to be understood include:
a. 2001 – population 125,700 – Census 2001 figure
b. 2006 – population 131,100 – RSS base figure
c. 2011 – population 132,500 – Census 2011 figure, not 136,600 as used
d. This leads to growth 0.54% pa between Census figures, not 1.0% used
e. 2026 – population 145,250, not 156,700 used
f. 2026 - housing need 9,700, not 15,000 used
g. 2026 – use housing figure of 11,000 – allow increased growth.
You will see that recent actual growth 2006-2011 is 0.21%. However we recommend 0.54%, which is generous, and Housing 11,000 can be accommodated in the 5 year supply.
If you need anything further, do please call Dr Margaret Hall or myself
Yours sincerely

T J W Hale
Chairman, East Devon branch CPRE
cc Matt Dickins Head of Planning Policy EDDC 

And the attached paper ............................................................................................................................................

Planning Policy is in deep trouble, following the ruling in the two recent Appeals at Feniton and Ottery that East Devon District Council do not have a five year supply of housing land. Failure to improve the situation rapidly could lead to demotion of the Council. EDDC cannot prove a five year land supply using the Devon Structure Policy 2001-16 housing figures of 8450, let alone the over-ambitious housing target in the emerging Local Plan.
Under-provision of housing over recent years means that a buffer of 20% has to be applied to the five year supply of housing land (NPPF 47). Failure to identify a five year supply of housing land will mean the Plan is considered out of date National Planning Policy Framework paragraph 49 (NPPF). This simply cannot be allowed to happen. The consequences for the Council and for the people of East Devon are very serious.
The population projections that underlie the housing targets in the new Local Plan are out of date and unsound. The housing targets are unachievable and are therefore unrealistic and unsound.
The rationale for strategic housing provision needs to take account of 4 main factors. (Taken from Devon County Council – Officer Technical Paper, Housing Provision in Devon September 2010, presented to LDF Panel Meeting 2 August 2011):
i. housing demand – as expressed through projections based on past trends and the most up to date data (including that relating to births, deaths, age structure and household formation)
ii. economic development and job growth – the extent to which employment growth is consistent with housing demand in an area (sustainable development principles at a strategic scale), having regard to the extent to which economic growth and regeneration can be secured
iii. development delivery – in terms of achievable completion rates, the ability to secure and fund essential supporting infrastructure, and
iv. housing need – as assessed through the HMA process.
Looking at these factors in turn:
Population projections.
The Council appear to be relying on the ONS/CLG 2008 population projections. These show a projected population growth of 1.0% p.a. over the period 2008-26.
We now have the benefit of the actual population figures from the 2011 Census. This shows that the population in 2011 was actually only 132,500, some 4,100 less than that predicted in the Office of National Statistics/Department for Communities & Local Government (ONS/CLG) 2008 projections.
The actual population growth rate was not 1% pa, but only 0.54% over the 10 years 2001-2011. In fact the rate of population growth over the last 5 years, 2006-2011 has been even less than that (0.21%).
The ONS/CLG 2008 projections are clearly now wrong, and it is unsound to base housing targets on these projections, which are now out of date.
The population in 2006 was estimated to be 131,100. If we use the growth figure of 0.54% pa as being a reasonable average, because it is based on a longer time period and based on the real growth figure between Censuses in 2001 and 2011, the projected population in 2026 would be 145,250, an increase of 14,150, not the 25,600 based on the ONS/CLG 2008 projections.
In terms of households, they will rise from 58,500 in 2006 (2.24 people/household) to 68,200 in 2026 (2.13 people/household), an increase of 9,700 households.
The latest projections from ONS, published 28 September 2012, show the projected East Devon population in 2021 to be 143,000. This is broadly consistent with the calculations above.
In order to meet the housing need of this population increase over the period of the new Local Plan, 2006-26, we therefore only need 9,700 new homes.
Economic development:
The calculations above do not make an allowance for extra growth at the West End, nor an element of overspill from Exeter City, nor the aspirational aims of the Council. There is inevitably a subjective element in considering aspirational aims, and even in allowing for economic growth. The economic growth rate in the South West has been significantly slower than that underpinning the draft RSS. There should therefore be caution in using these earlier RSS targets and lower targets are now appropriate.
It is probably reasonable, therefore, to increase the housing target from 9,700 to around 11,000. It is worth noting that windfalls will increase these numbers by quite a significant amount.
Development delivery:
Looking now at the phasing and predicted completion rates in the Local Plan:
The planned completion rates show a significant spurt over the next 5 years, to around 1,400 per year. With the National and South West economic situation forecast to remain depressed until 2018/9 at least, this is neither realistic nor achievable.
The Inspector at the Ottery Appeal has determined that it is not reasonable to use the ambitious completion rates at Cranbrook that have been used in the Council’s calculation of five year supply of housing land, which are also represented in the new Local Plan phasing. The Inspector also determined that the number of deliverable sites in the rest of East Devon was far lower than that suggested by the Council.
We are already 5 years into the Plan (2006-26) and completions in the first 5 years have been 1829, or 365 per year (Technical Paper April 2012). If our suggested target of 11,000 is used, there still remain 9171 homes to be built 2011-26, an average of 611 per year. Even this reduced target presents challenges, and requires a significant increase in housing completion rates.
The phasing of future house building must be changed by reducing the total numbers and by shifting the spurt to later dates, to make the housing target realistic and achievable.
Housing need – Housing Market Appraisal (HMA) process:
The HMA process produces a range of “housing need”. This depends in part on assumptions about net in-migration. The most recent document - Strategic Housing Market Assessment for the Housing Market Areas of Exeter and Torbay – East Devon update 2011 – has data for in-migration only up to 2009. These show a declining rate of net in-migration over the few years prior to 2009. This is discussed at length in the Roger Tym Report (East Devon Housing and Employment Study 2011). The conclusion is that net in-migration rates are likely to remain lower than was thought during preparation of the Regional Spatial Strategy (RSS). Using Roger Tym’s low net in-migration scenario, a housing need of 10,800 2006-26 was assessed as being reasonable.
In summary, therefore, looking at the four factors, a housing figure of 11,000 is supported by evidence, and is furthermore realistic and achievable.

Disaggregation(splitting the district in half relating to calculating a five year land supply for housing)
The Council has relied on using a policy of disaggregation in calculating five-year land supply. As was pointed out in the Ottery Appeal, there is no national or local policy to support this approach. The Inspector determined that the district-wide figures should be used. The effect of this is that failure to have sufficient deliverable sites at the West End has led to extra housing being allowed in the Rest of East Devon. This runs the risk of demolishing the Spatial Strategy.
If a robust case for using disaggregation cannot be made, it is even more important to ensure that the there is a district-wide five year supply of housing land.  CPRE will be making a detailed consultation response to the Submission Local Plan and will make representations at the Examination in Public.
M J Hall

1. At 07:12 pm on 04th Jan Chris Wakefield wrote:
It’s no small relief that someone has properly tested the arguments in the LDP. I was struggling to look at the figures in order to make some sort of response to the consultation process and I started to wade through some of the supporting documents. These are tough going for a non specialist but I did note Roger Tym’s interesting suggestion that a smaller number of houses fitted the demand in East Devon very well, and this I think points to the level of political ambition embedded in the current LDP in place of serious objective evaluation of the issues.
I particularly found the Justification for the Employment land figures (emp004 in the document library) a puzzle. There’s been a lot of publicity around these figures and EDBF’s potential influence of them, so I was keen to have a closer look to see what I could find out.
A lot of the numbers are from the 2001 census, a situation which has already caused trouble for EDDC in the Redrow appeal at Ottery. Even if this is ignored and the figures accepted at face value, there are problems because ‘aspirations’ have replaced considered estimates in the calculations. So we have 925 proposed jobs in the town of Ottery by 2026, a figure arrived at by a quite bizarre route, beginning with the ‘aspiration’ for 1 job per household in the new housing. This is highly unlikely - occupancy rates are falling - now around 2.3 per household, (which is one of the reasons why new housing is needed), and if the other figures in the table are accepted as a measure of the proportion of Ottregians actually working in Ottery (about 21%) the number of jobs from the 409 new houses (409? shouldn’t it be 300?) will be 198 rather than 409. The rest of the new ‘jobs in town’ - 516 of them - are made up of another ‘aspiration’ to persuade 50% of those who currently live in Ottery but work elsewhere, to find jobs in the town itself. There is no rationale to support such a dramatic change. It will be remarkable even if we can retain the 649 jobs that in-commuting workers occupied in 2001, given the gravitational pull of Cranbrook and associated developments immediately east of Exeter.
The figure of 198 new jobs requiring space seems more in tune with the Tym report’s recommendation for employment land at Ottery that “Site 1 should be more than sufficient to create capacity for future development in Ottery St Mary, provided concerns over highway capacity can be resolved.” (‘East Devon Housing and Employment Study
Final Report’ Roger Tym and Partners, para 7.70). Site 1 is on the Finnimore Estate and amounts to 0.67 Hectares (just over 1.5 acres). 3 hectares (7.5 acres) were proposed in the 2011 draft, but the new draft tells us that Sainsburys now accounts for one of those, something it wasn’t doing when the earlier draft was published. So now we have “up to 2 hectares” in the report - over twice the recommended amount.
My figures above are a back-of-envolope effort, but slightly more realistic I feel, than the Justification document emp004. My question is why has EDDC departed so far from a detailed evidence based study that was at their disposal.
I haven’t trawled through the figures for the other towns, but if the same has happened there, the employment land figures are demonstrably well out of kilter. If EDDC sends the LDP into an Examination in Public already holed below the waterline in this way, then Cllr Diviani’s new year aspiration to halt “the kind of uncontrolled development that both we and the people of East Devon don’t want” will join his other failures to stem the barbarism unleashed on Feniton, Ottery and very soon, dear reader, a greenfield site near you.

Claire Wright - Your Independent East Devon District Councillor for Ottery Rural

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