allison homes and others spatial planning …

AAA REF: APA/LARKF/06/0653

PROPOSAL

OUTLINE PLANNING APPLICATION (WITH ALL MATTERS RESERVED SAVE MEANS OF ACCESS) FOR: A SUSTAINABLE URBAN EXTENSION TO GRANTHAM COMPRISING; NOT MORE THAN 550 DWELLINGS; A NEIGHBOURHOOD CENTRE; A SINGLE FORM ENTRY PRIMARY SCHOOL; ANCILLARY (FORMAL AND INFORMAL) PUBLIC OPEN SPACE; INCLUDING STRUCTURAL LANDSCAPING AND BIODIVERSITY ENHANCEMENT AREAS; AND ACCESS WORKS.

SITE ADDRESS NORTH OF LONGCLIFFE ROAD, EAST OF THE EAST COAST MAIN RAILWAY LINE,

SOUTH OF BELTON LANE AND OF THE 132 KV HIGH VOLTAGE OVERHEAD

ELECTRICITY TRANSMISSION LINE (RUNNING SOUTH-EAST/NORTH-WEST BETWEEN

HIGH ROAD AND BELTON LANE) AND WEST OF THE A607 HIGH ROAD/BELTON ROAD,

GRANTHAM, LINCOLNSHIRE

APPLICANTS ALLISON HOMES AND OTHERS

SPATIAL PLANNING STATEMENT

JULY 2015

Proposed housing-led, mixed use development 1 Antony Aspbury Associates

Grantham North. Spatial Planning Statement July 2015

1.0 Introduction

1.1.1 This Spatial Planning Statement has been produced by Antony Aspbury

Associates Limited on behalf of the Applicants in support of an outline

planning application (with all matters reserved save means of access) for:

mixed-use development, comprising up to 550 dwellings, a neighbourhood

centre, a primary school, allotments and community orchard, open space,

playing fields, sustainable urban drainage systems and biodiversity

enhancements, landscaping and all other associated infrastructure.

The Application Site

1.1.2 The Application Site, amounting to some 37.82 hectares, comprises land

bounded: to the south by the northern edge of the built-up area of Grantham,

comprising suburban housing generally of a late 20th Century vintage; to the

east by Manthorpe Grange, by St John the Evangelist Parish Church and the

A607, High Road; to the north, generally by the line of A 132KV high voltage

overhead electricity transmission line (OETL) and Belton Lane; and to the west,

by the East Coast Main Railway Line (ECMRL) (See Plan 1 Application Site

Plan).

1.1.3 It mostly comprises arable farmland in large fields (ALC grade 3b). The area

south and east of the Running Furrows watercourse (a tributary of the River

Witham), which runs southwest to northeast across the eastern end of the Site,

is not actively farmed however, but is grazed from time-to-time. Gonerby

Stream, a tributary of the Running Furrows, flows west to east along the

southern boundary of the site, which is the northern edge of the Manthorpe

Estate. A public footpath runs east-west across the southern part, from the

A607, High Road at Manthorpe, to an underpass beneath the ECMRL. There

are a number of gappy, mechanically-trimmed hedgerows around and across

the Site.



The aforementioned OETL, which forms the northern boundary of the

Application Site, except at the eastern and western ends, runs diagonally from

the northwest to the east, is supported by 4 pylons in that part of the run

between Belton Lane and High Road.

1.1.4 Plan 1 shows all the land under the prospective Applicants’ control edged

respectively in red and blue. As can also be seen from both Plan 1 and Plan 2

(Illustrative Masterplan), the Application Site, encompassing the proposed

building works and engineering operations described below, occupies only part

of the combined area – for the most part, to the south of the OETL – and a

large proportion of this area, mostly to the north of the OETL will remain open,

undeveloped and continue in agricultural use. However, some structural

landscaping, comprising hedgerow restoration/ reinstatement and

reinforcement following historic field boundaries and margin planting will be

undertaken in this area as well. For the avoidance of doubt this latter area is not

be included in the defined (red line) Application Site and is, therefore, shown

outlined in blue on the Application Site Plan. The overall area of the land within

the red and blue line boundaries amounts to 53.92 hectares. The Application

Site area amounts to 37.82 hectares, or some 70% of the combined area

identified on Plan 1.

1.1.5 The trees around the boundary to (and within) the Application Site are now the

subject of a Tree Preservation Order made by the District Council on 30April

2015.

The Application Proposal

1.1.6 The proposed development (‘The Development’) comprises a housing-led

mixed-use development. The components of the development (see Illustrative

Master Plan: Plan 2) are:



The erection of not more than 550 houses, comprising a range of different

house types, sizes and tenures (including affordable housing) to be

delivered in an appropriately phased manner and thus contributing to the

sustainable provision of housing required for the Grantham area;

A neighbourhood centre, including a small supermarket/’C’ Store (UCO

Class A1) of up to 390 square metres gross internal floor area) and three

small unit shops (each up to 80 square metres gross internal floor

area)(also UCO Class A1);

A single-form-entry primary school (including a joint-use education/

community assembly hall and a joint use education/community playing

fields);

Principal vehicular, cycle and pedestrian access/egress by means of an

extension into the Application Site of Longcliffe Road and by means of an

access road running from a new priority junction on Belton Lane. The latter

junction will, during the construction phase, provide exclusive

access/egress for construction traffic. Secondary vehicular access (to up to

35 dwellings) and pedestrian and cycle access/egress to/from Rosedale

Drive.

Pedestrian access by means of: the existing public footpath that runs east

west across the southern part of the Site, this footpath being maintained

largely on its present alignment and in its present (unmade) character; and

by means of three new footpaths. The first of these would link (along the

western side of the Site) from the existing on-site footpath referred to

above, at its western end, to a footpath running across Belton Woods Golf

Course and debouching onto Belton Lane opposite the north west corner of

the Site. The second would run east-west between the north eastern edge

of the proposed built development, west of the Running Furrows, and High

Road, Manthorpe, immediately north of the Parish Church of St John the

Evangelist, crossing the Running Furrows by a new footbridge.



The third would run alongside Running Furrows on its eastern bank and link

to High Road in the north eastern corner of the Site. The second and third

new footpaths would also make provision for shared use by cyclists.

Improved transport linkages to the residential area to the south of the Site

and onwards to existing community facilities within this part of the Town, to

Grantham Town Centre and to the Town’s main employment areas and

improved pedestrian and cycle linkages to the north of the Site;

Selective off-site improvements within the transport network to limit the

significant impacts of the development, such as they are, as required by the

NPPF;

Engineering operations to create a sustainable urban drainage system

(SUDS) draining to the Running Furrows and thence to the River Witham;

Ancillary formal and informal public open space;

Landscaping, including measures to mitigate the landscape and visual

impact of the Development and to ameliorate identified impacts upon

nearby heritage assets, including the Manthorpe Conservation Area and

Belton House and its Parkland.

Retention of trees, hedgerows and other features of habitat value, and the

provision of significant biodiversity enhancement through the introduction of

new habitats in open space areas and on the land to be retained in

agricultural use and enhancements to channel of Running Furrows.

1.1.7 The net developable area would be 15.84 hectares, or about 42% of the

Application Site, and the dwelling density would be 35 per hectare.

1.1.8 The Application is accompanied by a Voluntary Environmental Statement.



Previous Planning Application and Appeal

1.1.9 In formulating the Development the subject of this request, careful regard has

been had to a previous proposal made to the Council under planning

application Ref. S10/0142/EIAOL dated 22 January 2010. That proposal, being

of a significantly greater scale and development area than that now being

proposed, comprised:

A sustainable urban extension to Grantham comprising: up to 1,000 dwelling

houses (UCO Class C3); a continuing care retirement community

(CCRC)(UCO Class C2); a neighbourhood centre (incorporating a primary

school [UCO Class D1] primary healthcare and community assembly facilities

[UCOI Class D1] and small scale [maximum 750 square metres] convenience

shopping [UCO Class A1, A3 and A5] facilities); a public house (UCO Class

A4) and lodge hotel (UCO Class C1); ancillary formal playing field/play areas

and informal open space (including structural landscaping and bio-diversity

enhancement areas; and access works, including alterations to the A607, High

Road/Belton Lane Junction.

1.1.10 An Appeal (PINS ref. APP/E2530/A/11/2150609) against a refusal of that

application (dated 12 January 2012) was lodged and subsequently recovered

for the Secretary of State’s determination.

1.1.11 Following a public local inquiry in November 2011 and a report by the Inspector,

Terry G Phillimore, dated 12 January 2012, it was dismissed by a decision letter

dated 1 March 2012.

1.1.12 The Applicants have paid careful attention to the reasons given by the

Secretary of State in his Decision Letter and to the constraints and

opportunities presented by the Application Site.



Following independent peer review and advice on landscape and heritage

considerations and a careful review of transport and sustainability issues, the

proposed Development has emerged, constraint-led but also embracing the

major opportunities available here to produce a high quality sustainable

development adjoining the urban edge of Grantham that is readily deliverable.

1.1.13 The Development, taking advantage of the opportunities now presented,

proposes the following changes when compared with the previous proposals:

A significant reduction in the extent of the developed area (by some 17.2

hectares/52% [from a NDA of 33 to 15.84 hectares]), on the northern and

eastern sides of the Site. This involves a drawing back of the northern edge

of the Development to the southern side of the 132 Kv OETL and the

removal of built development from the area north of the electricity line,

which is the most visible part of the site in views to and from Belton Park

and in the wider landscape. These changes enable this area to retain its

existing open, rural/agricultural character (and continue in productive

agricultural use) and significantly enhance the landscape fabric through

carefully considered native species tree and hedgerow planting consistent

with and reinforcing its historic character, thereby respecting the setting of

the Belton House and Parkland and on other nearby heritage assets.

Retention of the 132 Kv. OETL lines along the northern edge of the

developed area;

A 45% reduction in the number of dwelling houses and the deletion of the

Continuing Care Retirement Community;

A smaller, relocated neighbourhood centre;

The relocation of the proposed primary school;

The deletion of the public house and lodge hotel development;

The abandonment of the previously promoted four-arm roundabout at the

junction of the A607, High Road and Belton Lane and, in its place, two new

principal vehicular accesses to serve the development.



These will comprise: the extension of Longcliffe Road northwards and

eastwards into the Site, which will then continue through to a new priority

junction on Belton Lane. This road will be the axis for an extended and

rerouted scheduled bus service already operating in the existing residential

suburb immediately to the south of the prospective Application Site.

1.1.14 The cumulative effect of these changes is to significantly reduce the potential

impacts of the current proposals compared with their predecessors. The

Heritage Impact Assessment and the Landscape and Visual Impact

Assessment (forming part of the Environmental Statement) have been closely

coordinated, using common baseline information and an integrated scheme of

mitigation will be embodied in the design proposals, to ensure that heritage,

landscape and visual impacts are minimised. Furthermore, the analysis

submitted in support of the Application has been framed with reference to best

practice guidance, including English Heritage Guidance on the Setting of

Heritage Assets and Conservation Principles. There is, already, a very good

understanding of the history and significance of these assets, achieved through

the previous application/appeal and confirmed in the Inspector’s report to the

Secretary of State.



2.0 Planning Policy Context

2.1 The Provisions of the Development Plan

Introduction

2.1.1 The development plan for the purposes of Section 38 (6) of the Act comprises

the adopted South Kesteven Core Strategy (CS) Development Plan

Document (DPD) and the adopted Site Allocation and Policies DPD, which

sets out site specific allocations and policies for the whole of the District apart

from the Grantham area, together with certain saved policies from the South

Kesteven Local Plan 1995.

2.1.2 It had been intended that a suite of complementary DPDs would be completed

with the Grantham Area Action Plan which would have set out site specific

allocations and policies for the Grantham area, thereby completing

geographical coverage of the District. However, on 7 January 2013, South

Kesteven District Council resolved to withdraw the Grantham Area Action Plan

and instead to bring forward a new comprehensive Local Plan for South

Kesteven. This new Local Plan, which will eventually supersede the existing

DPDs and will cover the whole of the District for the period 2011 to 2036, is still

in its early stages of preparation.

2.1.3 Supplementary Planning Documents (SPD). Of these, the only one relevant to

the Planning Application the subject of this Statement is the Planning

Obligations SPD, adopted by the Council in June 2012.



The South Kesteven Core Strategy DPD

2.1.4 The Core Strategy (CS) for the District was adopted in 2010, and provides

strategic policies to guide development throughout the District.

2.1.5 In 2007, along with a number of other towns, Grantham was awarded ‘Growth

Point’ status by the Government and as a consequence, it has since been

anticipated that the Town would be a focus for significant and sustainable

population and economic growth – at least 7,500 new homes and about 4,000

new jobs by 2026. It anticipates a population increase in the Town of over 30%

to approximately 60,000 people by 2026. The development of new housing,

employment premises and provision of jobs would simultaneously be supported

by substantial investment in retail provision, as well as the social and physical

infrastructure required to meet the needs of the increased population. A budget

of £6M was granted by the Department of Communities and Local Government

to assist in delivering the growth ambitions. ‘Grantham Growth’ is led by a

partnership between South Kesteven District Council and Lincolnshire County

Council, with an agreed strategic programme and seeking to work closely with

the private sector to deliver growth.

2.1.6 Growth Point status has therefore underpinned spatial planning and social and

economic regeneration strategies for Grantham over the subsequent eight

years, including in the Core Strategy.

2.1.7 Amongst the Core Strategy Objectives that are particularly relevant to the

Application Proposals are:

Objective 6: To promote and strengthen the role of Grantham as a Sub-Regional Centre, and properly plan and deliver the additional housing growth expected by the Grantham Growth Point and

the Regional Spatial Strategy.



Objective 7: To ensure that new residential development includes a mix and range of housing types which are suitable for a variety of needs, including the need for affordable and local need housing in the District

Objective 11: To support new and existing community infrastructure, and to ensure that relevant community and other infrastructure costs such as facilities for leisure, open space, green infrastructure, health, education, affordable housing, transport, water infrastructure and the arts, arising from new development, are delivered through on- and off-site contributions.

2.1.8 The Application Proposals can be assessed against the following relevant

policies in the Strategy:

2.1.8.1 SP1 Spatial Strategy:

This focuses the majority of development in the District on Grantham to support

and strengthen its role as a Sub-Regional Centre and to reflect its Growth Point

status. New development proposals will be considered on appropriate,

sustainable and deliverable brownfield sites and appropriate greenfield sites

(including urban extensions), sufficient to ensure the achievement of growth

targets. Details of specific sites (including urban extension sites) were to have

been included in the Grantham Area Action Plan. However, as noted above,

that Plan has subsequently been abandoned (7 January 2013) and there is no

extant site allocations document pursuant to the Core Strategy. The Application

Site is located on the edge of the built-up area of Grantham and the proposed

development would be well-related and well-linked to the rest of the built-up

area. The Council has previously accepted that the Site would be considered as

an urban extension to Grantham. It accords with Policy SP1 therefore.



2.1.8.2 SP4 Developer Contributions:

The Application sets out the proposed Section 106 Heads of Terms relating to

the proposed Planning Obligation in accordance with the terms of this Policy.

2.1.8.3 EN1 Protection and Enhancement of the Character of the District:

The submitted Design & Access Statement and the Environmental Statement

explain how the proposed development takes into account the policies and

proposals of the South Kesteven Landscape Character Assessment (January

2007) and the Lincolnshire Biodiversity Action Plan (July 2006) amongst other

background documents. The Application Proposals are appropriate and

complementary to the character of the local landscape and environmental

features. The submitted Design and Access Statement, the Parameters Plan

and Illustrative Masterplan, amongst other Application Documents, demonstrate

how local features have been taken into account in the scheme design. As

demonstrated below, the Proposed Development constitutes ‘sustainable

development’ as defined in the Framework.

2.1.8.4 EN2 Reducing the Risk of Flooding:

The submitted Flood Risk Assessment and Drainage Strategy take into account

the recommendations of the Grantham Strategic Flood Risk Assessment (2009)

and shows how surface water discharge will be controlled through SUDs

features, to ensure the development does not have an adverse impact upon

local drainage.



2.1.8.5 EN4: Sustainable Construction and Design:

The submitted Design and Access Statement describes how the Application

Proposals will create a new place that is sustainable, and will simultaneously

meet the needs of its new community, including its future generations. The

Masterplan seeks to demonstrate how a sustainable development and a high

quality of life that improves economic, social and environmental wellbeing will

be delivered.

2.1.8.6 H1 Residential Development:

This Policy specifies that housing growth for the District should be focused at

Grantham with at least 6,992 dwellings to be provided in the period 2008-

2026. The 550 dwellings proposed on the Application Site will make a

significant contribution towards this provision and the objectives of the South

Kesteven Housing Strategy (SKHS) 2013-2018, particularly in the short to

medium term, and will help to overcome the current shortfall in housing land

supply (see below). The SKHS 2013-2018 is the product of consultation with a

range of stakeholders and draws upon multiple data sources in setting out an

ambitious vision for the future of the District within the context of the corporate

priority of creating the environment to support good housing for all. Supporting

that corporate priority are four strategic housing priorities:

Priority 1: High quality new affordable homes available to buy or rent;

Priority 2: Improved housing standards across the district and for all tenures;

Priority 3: Access to housing and wellbeing services;

Priority 4: Promotion of sustainable neighbourhoods and communities.

The proposed development will comply with all of these priorities.



2.1.8.7 H3 Affordable Housing:

The Application Proposal includes provision for affordable housing in

accordance with this Policy through the agency of the proposed Section 106

Planning Obligation.

2.1.8.8 E2 Retail Development:

The proposed neighbourhood centre within the proposed development will

accommodate limited convenience retail facilities, to meet the day-to-day needs

of the local community, comprising both the new residents of the development

and those already living in the area, and will not compete with the retail function

of Grantham Town Centre.

2.1.9 It can be seen therefore that the foregoing that the Proposed Development

complies with all of the relevant Core Strategy policies listed above.

2.1.10 Notwithstanding the foregoing, it is of relevance that the Core Strategy was

adopted in 2010, is based on supporting evidence, strategies, guidance and

policy from a number of older national, regional and local documents and other

sources which are now largely redundant and have been superseded by more

up-to-date material. Thus, it clearly pre-dates the National Planning Policy

Framework (NPPF), Moreover, its development requirements and the evidence

base underpinning them are derived from outdated Census data and

demographic projections and from the abolished East Midlands Regional Plan.

2.1.11 The Council has apparently undertaken a review of the Core Strategy to assess

its compliance with the Framework, concluding that it was compliant in all

material respects, However, this review has not been published and not made

available to the Applicant. An independent audit of this exercise has not been

possible therefore.



Moreover, the datedness of the evidence base and the fact that the Council

cannot presently demonstrate a 5-year housing land supply (See the

Framework paragraph 49 [op cit Section 2.2]) casts doubt on the contention

that the development plan is, after all, Framework compliant. Thus, DLP

Planning Consultants, on behalf of the Applicants, has undertaken an

independent review of the housing land supply in South Kesteven District and

concluded that the supply is significantly less than five years. (See Appendix 1

to the Spatial Planning Statement submitted with the Planning Application the

subject of this ES). As will be seen from the commentary in Section 2.2 below,

this has implications for the Policy in the Framework at paragraphs 14, 47 and

49.

2.1.12 It is also relevant to any assessment of how up-to-date the development plan is

that the Grantham Area Action Plan has been withdrawn by the Council. This

decision was evidently a response to strong reservations about its soundness

expressed by the Inspector appointed to examine it. As noted above, this was

to have been one of two complementary site allocation development plan

documents (along with the Site Allocations DPD [see below]) giving effect to the

Core Strategy.

2.1.13 Indeed, given the key distributional strategy of concentrating development

(including housing) in Grantham encompassed by the Core Strategy, this was

arguably the most important of the two site allocation plans and its loss was

therefore instrumental in the failure to meet the Core Strategy housing

trajectory and in rendering the Core Strategy out-of-date.

2.1.14 The section of the recently-published Regulation 18 Consultation on the New

Local Plan explaining the need for this Plan endorses the above analysis. Thus

it states that there is a need to review/update the Core Strategy to take account

of national planning policy changes and to cover the absence of up to date

policies and allocations in Grantham.



It goes on to state that the District Council, together with its Housing Market

Area partners (Rutland County Council, Peterborough City Council and South

Holland District Council), has published (in August 2014) a new Strategic

Housing Market Assessment (SHMA) which provides evidence about emerging

housing needs for the period to 2036.

2.1.15 The Core Strategy is, therefore, out of date by reference to policy in the NPPF

(the Framework) as set out in Section 2.2 below.

Site Allocation and Policies DPD

2.1.16 The Council adopted the Site Allocation and Policies DPD (SAP DPD) on the

17April 2014.

2.1.17 Although the SAP DPD does not generally relate to the Grantham Area, there is

one policy that is relevant to this Proposed Development as it relates to Belton

House and Grounds:.

2.1.18 SAP11 Protecting and Enhancing the Setting of Belton House and Park

2.1.18.1This Policy notes that Belton House and its Historic Park and Garden are

nationally and internationally significant heritage assets located in close

proximity to the northern edge of the existing built-up area of Grantham.

Protecting and enhancing their setting, using the Belton House and Park

Setting study to inform the assessment of the impacts, is important to

maintaining their significance as heritage assets. Proposals will need to

demonstrate what, if any, impact there will be on the setting of Belton House

and Park through the preparation of a Heritage Impact Statement, and how

through their location, scale, design, landscaping and materials they have taken

account of the setting of Belton, and that any adverse impacts have been

removed and/or mitigated.



2.1.19.2The Application Proposal is fundamentally landscape- and heritage-led, paying

particular regard to avoiding and mitigating any impact of development on

Belton House and Park. In its location, scale, design, landscaping and

materials, the proposal has taken full account of the setting of the House and

Park. Such impacts as there are have been shown in the Heritage Impact

Statement that forms a chapter in the Environmental Statement to be somewhat

less than substantial.

The South Kesteven Local Plan 1995

2.1.20 Certain saved policies from the 1995 Local Plan remain in force. They are

essentially policies setting out open space standards in Grantham that would

have been superseded by the provisions of the Grantham Area Action Plan had

it been pursued. They are:

2.1.20.1 Policy REC3 Public Open Space and New Housing Development

(Grantham)

2.1.20.2 Policy REC4 Playing Fields Provision in New Residential Developments

(Grantham)

2.1.20.3 Policy REC5 Play Space Provision in New Residential Developments

(Grantham)

2.1.20.4 Policy REC7 Allotments (Grantham)

These policies have been fully taken into account and the standards set out in

them have been applied to the proposed development. This is noted in the

relevant supporting documents to this Planning Application, including the

Design and Access Statement and the Spatial Planning Statement.



New Local Plan

2.1.21 As noted above, the Core Strategy is now out of date. The Council has now

embarked on the preparation of a new style Local Plan. That process is still at

an early stage however. So far, as noted above, only a Regulation 18

Consultation has been undertaken.

2.1.22 One of the first elements of the evidence base for this new Local Plan is an up-

to-date Peterborough Sub Regional Strategic Housing Market Assessment

(SHMA). The review undertaken by DLP Planning Consultants at Appendix 1 of

this Statement also includes a full objective assessment of (housing) need

(FOAN) based on the SHMA data. This assessment suggests that additional

housing provision will need to be made even without the carrying forward of the

Growth Point designation for Grantham.

The Planning Obligations SPD

2.1.23 This Supplementary Planning Document which has been drawn up pursuant to

Core Strategy SP4 (see 5.1.8.2 above) is intended to amplify and give effect to

that Policy and, amongst other things, to help to ensure development proposals

make a positive contribution to sustainable development by providing social,

economic and environmental mitigation which considers the community as a

whole. It states that contributions will only be sought from development where

there is a recognised need to mitigate the impact of the development proposal.

The SPD makes clear that the full list of Planning Obligation requirements set

out in it would not be required from every development proposal. Thus, if there

is sufficient infrastructure capacity within the catchment area of the

development site e.g. sufficient spare capacity within the school to

accommodate the pupil numbers generated by development, then contributions

will not be sought unnecessarily.



2.1.24 The SPD explains how the section 106 Planning Obligation mechanism works,

how it relates to Regulation 122 of the CIL Regulations 2010 and the provisions

of that Regulation.

2.1.25 Finally, it lists the specific categories of community infrastructure for which

contributions may be sought.

2.1.26 The Application the subject of this ES and the S106 Planning Obligation ‘Heads

of Terms’ submitted with the Application have been drawn up with full regard to

the provisions of this SPD.

2.2. The National Planning Policy Framework (‘The Framework’)

2.2.1 At paragraph 6 the Framework states that the purpose of the planning system is

to contribute to the achievement of sustainable development.

2.2.2 At paragraph 7 it sets out the three dimensions to sustainable development:

economic; social and environmental. These dimensions give rise in turn to the

need for the planning system to perform three roles:

An economic role – contributing to building a string, responsive and competitive economy.

A social role – supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations;

An environmental role – contributing to protecting and enhancing our natural, built and historic environment.

2.2.3 Paragraph 8 of the Framework states that these roles should not be undertaken

in isolation, because they are mutually dependent. Economic growth can

secure higher social and environmental standards, and well-designed buildings

and places can improve the lives of people and communities. Therefore, to

achieve sustainable development, economic, social and environmental gains

should be sought jointly and simultaneously through the planning system.



The planning system should play an active role in guiding development to

sustainable solutions.

2.2.4 Paragraph 9 continues by saying that pursuing sustainable development

involves seeking positive improvements in the quality of the built, natural and

historic environment, as well as in people’s quality of life, including (but not

limited to):

making it easier for jobs to be created in cities, towns and villages;

moving from a net loss of bio-diversity to achieving net gains for nature

replacing poor design with better design;

improving the conditions in which people live, work, travel and take leisure; and

widening the choice of high quality homes.

2.2.5 The material contained in the documents submitted with the Planning

Application and in the Environmental Statement demonstrates that the

proposed development will provide significant economic, social and

environmental benefits, consistent with the roles of the planning system cited in

Paragraph 7 of the Framework. Thus, it will stimulate and support (both directly

and indirectly) sustainable economic development through the delivery of up to

550 (market and affordable) homes, together with the requisite physical,

transportation and community infrastructure, without harm to the environment,

facilitating the growth of Grantham and contributing to the meeting of the area’s

(economic and social) needs in a sustainable manner. These facilities will

delivered an integrated fashion with, amongst other features, a high quality of

layout, design and environment, and with a net gain in bio-diversity. Thus, as

the material contained in the documents submitted with the Planning

Application and in the Environmental Statement demonstrates, development

will accord also with the policy at Paragraphs 8 and 9 of the Framework.



2.2.6 At paragraph 14 the Framework sets out a presumption in favour of sustainable

development – the “golden thread” running through both plan-making and

decision-taking process. Planning law (Section 38[6] of the Planning and

Compulsory Purchase Act 2004 and section 70[2] of the Town and Country

Planning Act 1990) requires that applications for planning permission must be

determined in accordance with the development plan, unless material

considerations indicate otherwise. The National Planning Policy Framework

must be taken into account in the preparation of local and neighbourhood plans,

and is a material consideration in planning decisions. Paragraph 14 continues,

under the sub heading “For decision-taking this means:”

approving development proposals that accord with the development plan

without delay; and

where the development plan is absent, silent or relevant policies are out-of-

date, granting permission unless:

- any adverse impacts of doing so would significantly and demonstrably

outweigh the benefits, when assessed against the policies in this

Framework taken as a whole; or

– specific policies in this Framework indicate development should be

restricted.


Application and in the Environmental Statement demonstrates that the

proposed development accords with the provisions of the development plan

but, insofar as the development plan is absent, silent or relevant policies are

out-of-date (as demonstrated in Section 2.1. above):

- the Application proposal constitutes ‘sustainable development within the

meaning of the framework;



- any adverse impacts are marginal, have been satisfactorily avoided through

careful design and are significantly and demonstrably outweighed by the

benefits; and,

- No specific policies in the Framework indicate that development should be

restricted.

Accordingly, it is concluded that the Application Proposal in this case amounts

to sustainable development within the terms of Paragraph 14 of the Framework

and should, therefore, attract the positive presumption set out in this Paragraph.

2.2.8 Paragraph 17 of the Framework sets out 12 core planning principles which

underpin both plan-making and decision-taking. These principles can be

summarised as follows: Planning should:

be genuinely plan-led by succinct and up-to-date local and neighbourhood

plans setting out a positive vision for the future of the area;

be not simply be about scrutiny, but instead be a creative exercise in finding

ways to enhance and improve the places in which people live their lives;

proactively drive and support economic development to deliver the homes,

business and industrial units, infrastructure and thriving local places that the

country needs. Every effort should be made to objectively identify and then

meet the housing, business and other development needs of an area and

respond positively to the wider opportunities for growth. Plans should take

account of market signals and set out a clear strategy for allocating

sufficient land which is suitable for development in their area;

always seek to secure high quality design and a good standard of amenity;

take account of the different roles and character of different areas,

promoting the vitality of our main urban areas, recognising the intrinsic

character and beauty of the countryside;

support the transition to a low carbon future in a changing climate;



contribute to conserving and enhancing the natural environment and

reducing pollution Allocations of land for development should prefer land of

lesser environmental value, where consistent with other policies in the

Framework;

encourage the effective use of land by reusing land that has been

previously developed (brownfield land), provided that it is not of high

environmental value;

promote mixed use-developments;

conserve heritage assets in a manner appropriate to their significance;

actively manage patterns of growth to make the fullest possible uses of

public transport, walking and cycling, and focus significant development in

locations which are or can be made sustainable; and,

take account of and support local strategies to improve health, social and

cultural well-being for all, and deliver sufficient community and cultural

facilities and services to meet local needs.


Application and in the Environmental Statement, demonstrate how the

proposed development will comply with all but one of these principles. So far

as the 8th bulleted principle is concerned, the adopted development plan

accepts that the development needs of the District cannot be met by the

exclusive, or even predominant use of previously developed land and that most

new development will need to be accommodated on greenfield sites therefore.

Thus, both of the proposed Sustainable Urban Extensions identified in the Core

Strategy and most of the major candidates for other allocations in the withdrawn

Grantham Area Action Plan are greenfield sites.

2.2.10 At paragraph 32 the Framework states that all developments that generate

significant amounts of movement should be supported by a Transport

Statement or Transport Assessment. Plans and decisions should take account

of whether:



the opportunities for sustainable transport modes have been taken up

depending on the nature and location of the site, to reduce the need for

major transport infrastructure;

safe and suitable access to the site can be achieved for all people; and

improvements can be undertaken within the transport network that cost

effectively limit the significant impacts of the development. Development

should only be prevented or refused on transport grounds where the

residual cumulative impacts of development are severe.

2.2.11 At paragraph 35, it is stated that plans should protect and exploit opportunities

for the use of sustainable transport modes for the movement of goods or

people. Therefore, developments should be located and designed where

practical to:

accommodate the efficient delivery of goods and supplies;

give priority to pedestrian and cycle movements, and have access to high

quality public transport facilities;

create safe and secure layouts which minimise conflicts between traffic and

cyclists or pedestrians, avoiding street clutter and where appropriate

establishing home zones;

incorporate facilities for charging plug-in and other ultra-low emission

vehicles; and

consider the needs of people with disabilities by all modes of transport.

2.2.12 Paragraph 36 states that a key tool to facilitate the securing of the features

listed in Paragraph 35 will be a Travel Plan. All developments which generate

significant amounts of movement should be required to provide a Travel Plan.



2.2.13 The Transport Assessment, Transport chapter in this ES and Travel Plan

submitted with this Planning Application demonstrate full compliance with the

policies at paragraphs 32, 35 and 36 of the Framework, including each of the

specific points listed in each of the paragraphs.

2.2.14 The Framework continues at paragraph 37 that planning policies should aim for

a balance of land uses within their area so that people can be encouraged to

minimise journey lengths for employment, shopping, leisure, education and

other activities.

2.2.15 Paragraph 38 says that for larger scale residential developments in particular,

planning policies should promote a mix of uses in order to provide opportunities

to undertake day-to-day activities including work on site. Where practical,

particularly within large-scale developments, key facilities such as primary

schools and local shops should be located within walking distance of most

properties. The Application proposals fully comply with the policy at Paragraphs

37 and 38.

2.2.16 Section 6 of the Framework is entitled “Delivering a wide choice of high quality

homes” and paragraph 47 opens by stating: “To boost significantly the supply of

housing, local planning authorities should”:

use their evidence base to ensure that their Local Plan meets the full,

objectively assessed needs for market and affordable housing in the

housing market area, as far as is consistent with the policies set out in this

Framework, including identifying key sites which are critical to the delivery

of the housing strategy over the plan period;

identify and update annually a supply of specific deliverable sites sufficient

to provide five years-worth of housing against their housing requirements

with an additional buffer of 5% (moved forward from later in the plan period)

to ensure choice and competition in the market for land.



Where there has been a record of persistent under delivery of housing,

local planning authorities should increase the buffer to 20% (moved forward

from later in the plan period) to provide a realistic prospect of achieving the

planned supply and to ensure choice and competition in the market for

land.

2.2.17 Paragraph 49 continues that housing applications should be considered in the

context of the presumption in favour of sustainable development. Relevant

policies for the supply of housing should not be considered up-to-date if the

local planning authority cannot demonstrate a five-year supply of deliverable

housing sites.

2.2.18 With respect to the policy set out in Paragraphs 47 and 49, as noted at 2.1.11

and 2.1.14 above, the Applicants have commissioned an audit of the Council’s

current Housing Land Supply, which also includes an objective assessment of

housing need in the District based in the emerging SHMA. This is Appended at

1. It demonstrates that there is NOT currently a 5 year housing land supply in

South Kesteven District in accordance with paragraph 47 of the Framework and

it is considered, therefore, that, in accordance with Paragraph 49, the relevant

policies for the supply of housing are not up to date and that the Paragraph 14

presumption described at paragraph 2.2.5 of this Statement should apply

accordingly.

2.2.19 Section 7 (Paragraphs 56 et seq.) of the Framework sets out the Government’s

policies in relation to requiring good design of the built environment,

emphasizing that good design is a key aspect of sustainable development, is

indivisible from good planning, and should contribute positively to making

places better for people. The material contained in the documents submitted

with the Planning Application (including the Design and Access Statement and

the Illustrative Masterplan) and in the Environmental Statement demonstrates

that the scheme design is fundamentally landscape- heritage- and design-led.



It has been carefully formulated so as to produce a scheme of high design

quality, including high-quality landscaping, and high sustainability.

2.2.20 Section 8 (paragraphs 69 et seq.) is concerned with promoting healthy

communities. Paragraph 69 states that planning policies and decisions should

aim to achieve places which promote:

opportunities for meetings between members of the community who might

not otherwise come into contact with each other, including through mixed-

use developments, strong neighbourhood centres and active street

frontages which bring together those who work, live and play in the vicinity;

safe and accessible environments where crime and disorder, and the fear

of crime, do not undermine quality of life or community cohesion; and,

safe and accessible developments, containing clear and legible pedestrian

routes, and high quality public space, which encourage the active and

continual use of public areas.

The Application Proposals demonstrate full compliance with these principles.

2.2.21 Paragraph 70 goes on to say that in order to deliver the social, recreational and

cultural facilities and services the community needs, planning policies and

decisions should:

plan positively for the provision and use of shared space, community

facilities (such as local shops, meeting places, sports venues, cultural

buildings, public houses and places of worship) and other local services to

enhance the sustainability of communities and residential environments;

ensure an integrated approach to considering the location of housing,

economic uses and community facilities and services.

Once again, this policy is fully reflected in the Application Proposals.



2.2.22 Paragraph 73 states that access to high quality open spaces and opportunities

for sport and recreation can make an important contribution to the health and

well-being of communities. The Application proposals make generous provision

for high quality open space in the proposed development which fully meet the

locally defined standards. (See 2.1.20 above).

2.2.23 Paragraph 75 states that planning policies should protect and enhance public

rights of way and access. Local authorities should seek opportunities to provide

better facilities for users, for example by adding links to existing rights of way

networks including National Trails. The Proposed Development provide for the

integration of the existing public right of way crossing the site from east to west

into the development and for new linkages into the local footpath and cycleway

network beyond the site.

2.2.24 Section 10 (paragraph 93 et seq.) of the Framework addresses the issue of

meeting the challenge of climate change, flooding and coastal change.

Paragraph 95 states that to support the move to a low carbon future, local

planning authorities should, amongst other things, plan for new development in

locations and ways which reduce greenhouse gas emissions. The Flood Risk

Assessment records that the Application Site is in Flood Zone 1 and is thus not

at risk of flooding and will not increase the risk of flooding elsewhere. The

development provides for an on-site sustainable urban drainage system which

will ensure surface water run-off from the Site (to the Running Furrows will not

exceed levels agreed with the relevant agencies.

2.2.25 The Site is in a strategically accessible and sustainable location on the edge of

Grantham. The proposals have been formulated to take full advantage of this

location and to integrate closely with the rest of the urban area by a range of

transport modes, including public transport, walking and cycling, as

demonstrated in the Transport Assessment and Draft Travel Plan.



2.2.26 Section 11 (paragraph 109 et seq.) is concerned with conserving and

enhancing the natural environment. Paragraph 109 states that the planning

system should contribute to and enhance the natural and local environment by,

amongst other things:

protecting and enhancing valued landscapes, geological conservation

interests and soils;

recognising the wider benefits of ecosystem services;

minimising impacts on biodiversity and providing net gains in biodiversity

where possible, contributing to the Government’s commitment to halt the

overall decline in biodiversity, including by establishing coherent ecological

networks that are more resilient to current and future pressures.

The Application Proposal has had full regard to this policy and provide

positively for the creation of new and enhanced open space and wildlife

habitats. Although presently open, the Application Site and the adjoining land

under the Applicants’ control is substantially comprised of an arable agricultural

‘prairie’, with strictly limited wildlife and bio-diversity value. The measures

incorporated in the Application Proposal will amount to a significant

improvement/net benefit to bio-diversity.

2.2.27 Paragraph 110 states that, in preparing plans to meet development needs, the

aim should be to minimise pollution and other adverse effects on the local and

natural environment. Plans should allocate land for development with the least

environmental or amenity value, where consistent with other policies in the

Framework. The Site, and specifically that part which is intended to be occupied

by built development is, for the most part, intensively-cultivated arable land with

limited environmental or amenity value. The Proposed Development will

significantly increase the amount of land with amenity value in this area.



2.2.28 Paragraph 112 of the Framework continues that local planning authorities

should take into account the economic and other benefits of the best and most

versatile agricultural land. Where significant development of agricultural land is

demonstrated to be necessary, local planning authorities should seek to use

areas of poorer quality land in preference to that of a higher quality. The

Application Site is ALC grade 3b and thus does not fall in to the best and most

versatile category. As noted in the preceding paragraph, generally, the Site

comprises intensively-cultivated arable land which has little environmental or

amenity value. There are no national or local landscape or biodiversity

designations affecting the Site.

2.2.29 The Proposed Development retains and incorporates and creates features of

environmental and amenity value, including mature trees and hedgerows, which

is referred to in more detail in the Landscape and Ecology chapter of the ES.

2.2.30 Paragraph 123 states that planning policies and decisions should, amongst

other things, aim to:

avoid noise from giving rise to significant adverse impacts on health and

quality of life as a result of new development;

mitigate and reduce to a minimum other adverse impacts on health and

quality of life arising from noise from new development, including through

the use of conditions;

recognise that development will often create some noise and existing

businesses wanting to develop in continuance of their business should not

have unreasonable restrictions put on them because of changes in nearby

land uses since they were established.

The Environmental Statement includes a Noise Assessment which addresses

the impact of noise from the principal noise source in the vicinity, the East

Coast Main Railway Line. The Assessment demonstrates that noise from the

latter can be satisfactorily mitigated.



It also shows that, apart from highly localised effects, the development itself will

not result in a significant adverse impact on the local noise

environment. Moreover, because of the phased development of the Site (over-

approximately 8 years), the localised increases in noise levels will be spread

over time with relatively small incremental changes in levels. Planning

conditions are proposed to regulate noise from construction activity.

2.2.31 Paragraph 124 states that planning policies should sustain compliance with and

contribute towards EU limit values or national objectives for pollutants, taking

into account the presence of Air Quality Management Areas and the cumulative

impacts on air quality from individual sites in local areas. Planning decisions

should ensure that any new development in Air Quality Management Areas is

consistent with the local air quality action plan. The development does not fall

within an AQMA, but Grantham Town Centre does. It is necessary, therefore, to

address the marginal impact of the Proposed Development on the Town Centre

AQMA. This is referred to in more detail in the Air Quality chapter of the ES.

2.2.32 Paragraph 125 states that by encouraging good design, planning policies and

decisions should limit the impact of light pollution from artificial light on local

amenity, intrinsically dark landscapes and nature conservation. A Lighting

Assessment has been undertaken and is appended to the Landscape and

Visual Impact Chapter of the ES. Its findings and recommendations have

informed the design of the development and will continue to do so through the

detailed design/approval of reserved matters stage. In formulating the

Application Proposals, therefore, full regard has been had to this policy.

2.2.33 Section 12 of the Framework is concerned with conserving and enhancing the

historic environment. Paragraph 128 states that, in determining applications,

local planning authorities should require an applicant to describe the

significance of any heritage assets affected, including any contribution made by

their setting.



The level of detail should be proportionate to the assets’ importance and no

more than is sufficient to understand the potential impact of the proposal on

their significance. As a minimum the relevant historic environment record

should have been consulted and the heritage assets assessed using

appropriate expertise where necessary. Where a site on which development is

proposed includes or has the potential to include heritage assets with

archaeological interest, local planning authorities should require developers to

submit an appropriate desk-based assessment and, where necessary, a field

evaluation.

2.2.34 Paragraph 131 states that in determining planning applications, local planning

authorities should take account of:

the desirability of sustaining and enhancing the significance of heritage

assets and putting them to viable uses consistent with their conservation;

the positive contribution that conservation of heritage assets can make to

sustainable communities including their economic vitality; and

the desirability of new development making a positive contribution to local

character and distinctiveness.

2.2.35 Paragraph 132 continues by stating when considering the impact of a proposed

development on the significance of a designated heritage asset, great weight

should be given to the asset’s conservation. The more important the asset, the

greater the weight should be. Significance can be harmed or lost through

alteration or destruction of the heritage asset or development within its setting.

As heritage assets are irreplaceable, any harm or loss should require clear and

convincing justification.



2.2.36 Paragraph 134 states that where a development proposal will lead to less than

substantial harm to the significance of a designated heritage asset, this harm

should be weighed against the public benefits of the proposal, including

securing its optimum viable use.

2.2.37 A full Heritage Impact Assessment has been undertaken by Messrs Montague

Evans and the results of this exercise are set out in the Cultural Heritage

chapter of the ES. This demonstrates that full and specific regard has been had

to heritage assets in the surrounding area and that the impact of the proposed

development on local heritage assets is less than substantial. Moreover, it also

concludes that the actual impact of the development on heritage local heritage

assets is marginal and does not in practice amount to any material harm to

those assets.

2.2.38 In summary, the Application Proposals meet all the relevant policies of the

Framework by:

2.2.38.1 Delivering Sustainable Development: The Application Site located in a

sustainable location on the edge of the built up area of Grantham. Local

facilities to meet the day-to-day needs of residents, including a neighbourhood

centre - comprising convenience shopping, a primary school, and community

assembly facilities - playing fields, children’s play space, allotments and a

community orchard and open space for informal; recreation, including walking,

are proposed. An extension of the existing bus-service operating in the

vicinity into the Site, together with new footpath and cycleway links are

proposed giving the new residents a choice of transport mode. This is set out

in more detail in the Travel Plan. The Design and Access Statement sets out

how carbon use will be controlled and managed.



2.2.38.2 Delivering a Wide Choice of Quality Homes: Within the proposed maximum

of 550 dwellings there will be a wide range of house types. There will also be

an appropriate proportion of affordable housing. The development will provide

a range and choice of housing opportunities therefore.

2.2.38.3 Delivering Good Design: The design principles set out in the NPPF are

reflected in the Design and Access Statement and in Illustrative Masterplan,

which aim to deliver an attractive, high quality development where people

want to live and work and where they can enjoy a healthy lifestyle. The

Framework also expects applicants to take account of the views of the

community. The submitted Statement of Community Involvement sets out how

the local community’s comments have been taken into account.

2.2.38.4 Promoting Healthy Communities: The proposed development will

incorporate a range of public open space and facilities to encourage walking

and cycling by providing new routes and links to existing rights of way,

including those giving access to the surrounding open countryside. The

proposed neighbourhood centre will include a good range of community

facilities, including a primary school, community assembly facilities and shops,

all within walking distance of the rest of the development and indeed of

adjoining areas of Grantham. This will facilitate social interaction and

engagement.

2.2.38.5 Conserving and enhancing the natural environment: The Proposals have

been landscape-led and are sensitive to landscape context of the Site. The

Site has limited biodiversity and is lacking in variety and quality of wildlife

habitats at present. Provision for new and enhanced habitats and increasing

biodiversity have been consciously designed in to the Proposals and these are

described in the relevant supporting documents. The Proposals involve the

loss of only Grade 3B agricultural land.



2.2.38.6 Conserving and enhancing the historic environment: The Application

Proposals have been formulated explicitly to take account of, and mitigate the

impact of development on, nearby heritage assets. Such harm as there will be

to these assets is marginal and is less than substantial. This harm is

significantly outweighed by the public benefits of the development.

2.3 On-line National Policy: Planning Practice Guidance

2.3.1 Planning Practice Guidance was first published by central government in

March 2014, with additional material being published regularly thereafter. The

Guidance covers an extensive range of issues within the planning process,

including: the value of pre-application engagement; Planning Performance

Agreements; Environmental Statements; determining applications; Planning

Obligations; and the use of planning conditions.

2.3.2 Pre-Application Engagement: The Guidance notes that pre-application

engagement by the prospective Applicants offers “significant potential to

improve both the efficiency and effectiveness of the planning application

system and improve the quality of planning applications and their likelihood of

success”.

The Applicant has engaged in pre-application engagement with the Local

Planning Authority, with key stakeholders and with the local community. This

is described in the submitted Statement of Community Consultation.

2.3.3 Environmental Impact Assessment: The NPPG also contains guidance

relating to Environmental Impact Assessment. The Application is accompanied

by a Voluntary Environmental Statement.



2.3.4 Use of Planning Conditions: Planning Practice Guidance explains the

justification for conditions, the application of the 6 tests in NPPF policy, the

approach for imposing conditions, detail in relation to time limits, and details for

discharging and modifying conditions. A list of draft planning conditions has

been submitted with the Application.

2.3.5 Planning Obligations: NPPG contains guidance on Planning Obligations.

Heads of terms for a Planning Obligation have been submitted with this

Application.

2.3.6 Other guidance: Other guidance in NPPG relates to specific technical matters

and this guidance has been taken into account in formulating the Application,

the various supporting assessments and in the relevant chapters of the ES.

2.3.7 It is concluded that this planning application submission accords with all

relevant National Planning Practice Guidance.

3.0 OTHER MATERIAL PLANNING CONSIDERATIONS

3.1 Other material considerations, including location/site-related, physical, amenity,

environmental and infrastructural considerations, have been carefully and

systematically addressed in the various technical reports, the Environmental

Statement and in the Design and Access Statement and Illustrative Master

Plan. It has been found that the Application Site is especially well-suited to new

development of the type proposed and will have no compelling adverse

impacts, warranting the withholding of planning permission on site specific

grounds.



4.0 OVERALL CONCLUSIONS

4.1 Insofar as the provisions of the development plan are up-to-date and relevant,

the proposed development accords with those provisions in all material

respects. The proposal therefore meets the Section 38(6) test.

4.2 The proposed development clearly accords with national policy as set out in the

Framework. It constitutes sustainable development. The paragraph 14

presumption therefore obtains in this case.

4.3 Notwithstanding these conclusions, the absence of a demonstrable 5-year

housing land supply in South Kesteven automatically renders the housing

policies of the development plan out of date creates a clear presumption in

favour of the development.

4.4 There are no other material planning considerations, including site-related,

layout and design, amenity, environmental, ecological, arboricultural, landscape

and visual, heritage and cultural, transport, land drainage considerations that

justify withholding planning permission in this case. Rather these

considerations, which have been addressed forensically in the Application

material, demonstrate that the Application Site is an exceptionally good one for

the development proposed.

Appendix 1 – Housing Land Supply and Objectively Assessed Housing Needs Reports

For and on behalf of Alison Homes and Others

Land Supply Report

South Kesteven

Prepared by DLP Planning Ltd

Strategic Research Unit

July 2015

Report on the Five Year Housing Land Supply

For South Kesteven District Council Roland G Bolton

2

Strategic Planning & Research Unit 4 Abbey Court Ground Floor Fraser Road V1 – Velocity Priory Business Park Tenter Street Bedford Sheffield MK44 3WH S1 4BY Tel: 01234 832740 Tel: 01142 289190 Fax: 01234 831 266 Fax: 01142 721947 DLP Consulting Group disclaims any responsibility to the client and others in respect of matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence. This report is confidential to the client and DLP Planning Consultants accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own risk.

Prepared by: …………………………………….. Roland Bolton BSc (Hons) MRTPI Senior Director

Approved by: ……………………………………. Roland Bolton

BSc (Hons) MRTPI Senior Director

Date: July 2015

Report on the Five Year Housing Land Supply For South Kesteven District Council

Roland G Bolton

3 310715.N-LI259.SKDC.RGB.Land Supply Report.FinalupplyReport.Final

Contents Page 0.0 EXECUTIVE SUMMARY 4 1.0 INTRODUCTION 6 2.0 NATIONAL PLANNING POLICY FRAMEWORK, PLANNING PRACTICE

GUIDANCE AND DECISIONS 7 3.0 SOUTH KESTEVEN DISTRICT COUNCIL’S HOUSING LAND SUPPLY

POSITION 18 Regional Spatial Strategy 18 Core Strategy 18 Local Plan 18

4.0 ANALYSIS AND THE STRATEGIC PLANNING RESEARCH UNIT’S LAND SUPPLY CALCULATIONS 24

5.0 CONCLUSION AND RECOMMENDATION 30

Appendix 1 Review of Sites


Roland G Bolton


0.0 EXECUTIVE SUMMARY

0.1 This report, prepared by the Strategic Planning & Research Unit (SPRU) within DLP Planning Ltd, provides a review of South Kesteven District Council’s current position in achieving a five year supply of housing land.

0.2 In South Kesteven District Council’s most recent Five Year Land Supply Assessment (as at April 2014), the Local Planning Authority (LPA) claims that it has a supply of 6.1 years of deliverable housing land with a 5% buffer applied or 5.3 years with a 20% buffer in accordance with paragraph 47 of the National Planning Policy Framework (‘the Framework’).

0.3 More detailed work completed by the SPRU demonstrates that this overall figure is further reduced on the basis that:

a. There has historically been a persistent under-delivery of housing against targets for Kesteven as a whole and therefore a 20% buffer should be applied across the whole District; and

b. A review of delivery and yield of individual sites.

0.4 In the first two years of the 20 year plan period housing delivery matched or exceeded the Core Strategy annualised target of 680 units. However, since 2008/2009 development rates have dipped below this target rate. The Council consider that a 5% buffer is appropriate at this time, but provide no evidence to justify this position. In light of the historic undersupply of housing within the district, as evidenced by the underachievement against requirements in the past six years, it is submitted that South Kesteven is a 20% authority in terms of paragraph 47 of the Framework. This conclusion is reinforced by the Costwold High Court decision.

0.5 Using the Chelmer Model a separate report has been prepared by DLP Planning Ltd’s SPRU on the Objectively Assessed Need for Housing, which considers the up-to-date housing needs for the District, in accordance with the Framework and Planning Practice Guidance (PPG). SPRU’s assessment outlines that in order to support the level of employment growth which reflects the Council’s growth aspirations and the LEP’s growth aspirations, a target requirement of 839 dwellings a year is required, against which to assess the five year supply.

0.6 As well as the requirement calculated by SPRU, this assessment also uses the SHMA requirement required to meet the economic growth objectives of the Council (see OAN report). This projection varies significantly over the 25 period as employment falls towards the end of the period. The assessment therefore looks at this requirement for the 10, 15, 20 and 25 year period. However in the context of calculating the five year land supply, the reliance of lower potential housing requirements in 15 years plus time, suggests that greater weight should be given to the shorter term projections.

0.7 This report concludes following a review of the sites included in the Council’s trajectory, that against the annualised target of the Core Strategy South Kesteven has 3.66 years supply of housing (+ 20%) for the period 2014/15 to 2018/19, which falls well below the five year supply (+20%) required by paragraph 47 of the Framework. When applying the conclusions of the separate report prepared by the SPRU on Objectively Assessed Need the housing land supply position would worsen and be just 2.45 years.


Roland G Bolton


0.8 The purpose of the Government’s Framework and PPG is to significantly boost the supply of housing and to plan to meet housing needs in full.

0.9 Therefore, the lack of a demonstrable five year supply of housing land is a significant material consideration in favour of proposals for new housing.


Roland G Bolton


1.0 INTRODUCTION

1.1 The Strategic Planning and Research Unit (SPRU) within DLP (Planning) Ltd is instructed by Alison Homes and Others to prepare a report which provides a detailed review and establishes the robustness or otherwise of the current five year land supply position in the administrative area of South Kesteven District Council in support of planning applications for new housing in South Kesteven.

1.2 Accordingly, this report provides an overview of the current position, assesses the yield from sites identified for development or committed and calculates the land supply position in line with guidance. The review of the land supply position is set out in the following text.


Roland G Bolton


2.0 NATIONAL PLANNING POLICY FRAMEWORK, PLANNING PRACTICE GUIDANCE AND DECISIONS

National Planning Policy Framework

2.1 In March 2012, Greg Clark, Minister of State for Communities and Local Government, announced the publication of the Framework. This swept away the previous Planning Policy Statements and Planning Policy Guidance Notes and replaced them with a single National Planning Policy Framework (‘the Framework’) with immediate effect (March 2012).

2.2 The Framework carries forward the Government’s commitment to supporting sustainable economic growth and states that significant weight should be placed on the need to support economic recovery through the planning system, including the delivery of new housing.

2.3 The Framework highlights at paragraph 14, that:

'at the heart of the National Planning Policy Framework is a presumption in favour of sustainable development, which should be seen as the golden thread running through both plan making and decision taking.’

2.4 For plan-making this means local planning authorities should set out the strategic priorities for the area including policies to deliver the homes and jobs needed (Paragraph 156), and Local Plans should be aspirational but realistic (Paragraph 154).

Delivering a Wide Choice of High Quality Homes

2.5 The Framework seeks to deliver as a main objective a wide choice of high quality homes. It states at paragraph 47 that in order to boost significantly the supply of housing, local planning authorities should:

• “Use their evidence base to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the policies set out in this Framework, including identifying key sites which are critical to the delivery of the housing strategy over the plan period;

• Identify and update annually a supply of specific deliverable sites sufficient to provide five years’ worth of housing against their housing requirements with additional buffer of 5% (moved forward from later in the plan period) to ensure choice and competition in the market for land. Where there has been a record of persistent under delivery of housing, local planning should increase the buffer to 20% (move forward from later in the plan period) to provide a realistic prospect of achieving the planned supply and to ensure choice and competition in the market for land;

• Identify a supply of specific, developable sites or broad locations for growth, for years 6 – 10 and, where possible, for years 11 – 15; and

• For market and affordable housing, illustrate the expected rate of housing delivery through a housing trajectory for the plan period and set out a housing implementation strategy for the full range of housing describing how they will maintain delivery of a five-year supply of housing land to meet their housing target.” (SPRU emphasis)


Roland G Bolton


2.6 Footnotes 11 and 12 of the Framework state:

“To be considered deliverable, sites should be available now, offer a suitable location for development now and be achievable with the prospect that housing will be delivered on the site within five years and in particular that development of the site is viable. Sites with planning permission should be considered deliverable until permission expires, unless there is clear evidence that schemes will not be implemented within five years, for example they will not be viable, there is no longer a demand for the type of units or sites have long term phasing plans.”

To be considered developable, site should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged.” (SPRU emphasis)

2.7 Paragraph 48 of the Framework further states:

“Local planning authorities may make an allowance for windfall sites in the five-year supply if they have compelling evidence that such sites have consistently become available in the local area and will continue to provide a reliable source of supply. Any allowance should be realistic having regard to the Strategic Housing Land Availability Assessment, historic windfall delivery rates and expected future trends, and should not include residential gardens.” (SPRU emphasis)

2.8 In determining the Objectively Assessed Need for housing, the Framework requires this to be based upon a consideration of demographic projections and trends (Paragraph 159) as well as meeting demand. The assessment also needs to consider the needs of the economy so that planning is not an impediment to sustainable growth (Paragraph 19).

2.9 Therefore, based on this, there are four main aspects of land supply: housing targets, historic delivery, land availability and site viability.

2.10 In summary, the core land supply principles from the Framework are as follows:

To boost significantly the supply of housing.

Local authorities need to identify and update annually five years’ worth of supply of specific deliverable sites for housing against their housing requirements, with an additional buffer of 5% applied to ensure choice and competition in the market for land.

Where there has been a record of persistent under-delivery of housing, local authorities should increase the buffer to their requirements to 20%.

This is to ensure choice and competition in the market for land.

Housing requirements should be evidenced based and objectively assessed.

Housing land supply is a dynamic and rolling target as sites are completed or are no longer viable and fall out of the supply. Therefore there is a need to continually feed the supply of housing land.

2.11 If a Council cannot demonstrate a five year supply of housing its policies relevant to that supply cannot be considered up-to-date. This triggers paragraph 14 of the


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Framework, as housing proposals should be considered in the context of the presumption in favour of sustainable development, as set out in Paragraph 49:

“Housing applications should be considered in the context of the presumption in favour of sustainable development. Relevant policies for the supply of housing should not be considered up-to-date if the local planning authority cannot demonstrate a five-year supply of deliverable housing sites.” (SPRU emphasis)

Planning Practice Guidance (PPG)

2.12 The Government’s Planning Practice Guidance was published in March 2014 and replaces a host of technical guidance including CLG’s ‘Strategic Housing Land Availability Assessments: Practice Guidance’ (July 2007).

2.13 The Guidance notes that the Framework sets out that local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide five years’ worth of housing against their housing requirements. Therefore, local planning authorities should have an identified five-year housing supply at all points during the plan period (Paragraph: 030 Reference ID: 3-030-20140306).

2.14 As part of this, local planning authorities should consider both the delivery of sites against the forecast trajectory and also the deliverability of all the sites in the five year supply. By taking a thorough approach on an annual basis, local planning authorities will be in a strong position to demonstrate a robust five year supply of sites. Demonstration of a five year supply is a key material consideration when determining housing applications and appeals. As set out in the Framework, a five year supply is also central to demonstrating that relevant policies for the supply of housing are up-to-date in applying the presumption in favour of sustainable development (Paragraph: 033 Reference ID: 3-033-20140306).

2.15 Housing requirement figures in up-to-date adopted Local Plans should be used as the starting point for calculating the five year supply. Considerable weight should be given to the housing requirement figures in adopted Local Plans, which have successfully passed through the examination process, unless significant new evidence comes to light. It should be borne in mind that evidence which dates back several years, such as that drawn from revoked Regional Spatial Strategies (RSS), may not adequately reflect current needs (Paragraph: 030 Reference ID: 3-030-20140306).

2.16 At Paragraph 015 Ref ID: 2a-015-20140306 the Guidance sets out that:

‘the household projection-based estimate of housing need may require adjustment to reflect factors affecting local demography and household formation rates which are not captured in past trends. For example, formation rates may have been supressed historically by under-supply and worsening affordability of housing. The assessment will therefore need to reflect the consequences of past under delivery of housing…local planning authorities should take a view based on available evidence of the extent to which household formation rates are or have been constrained by supply’.

2.17 In terms of adjustments to the household projections, the Guidance advises that plan makers may consider sensitivity testing specific to their local circumstances. Local circumstances could include migration patterns and demographic structure.


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2.18 The Guidance goes on to note that where evidence in Local Plans has become outdated and policies in emerging plans are not yet capable of carrying sufficient weight, information provided in the latest full assessment of housing needs should be considered. But the weight given to these assessments should take account of the fact they have not been tested or moderated against relevant constraints. Where there is no robust recent assessment of full housing needs, the household projections published by the Department for Communities and Local Government should be used as the starting point, but the weight given to these should take account of the fact that they have not been tested (which could evidence a different housing requirement to the projection, for example because past events that affect the projection are unlikely to occur again or because of market signals) or moderated against relevant constraints (for example environmental or infrastructure) (Paragraph: 030 Reference ID: 3-030-20140306).

2.19 The Guidance states that the approach to identifying a record of persistent under delivery of housing involves questions of judgment for the decision maker in order to determine whether or not a particular degree of under delivery of housing triggers the requirement to bring forward an additional supply of housing (Paragraph: 035 Reference ID: 3-035-20140306).

2.20 The factors behind persistent under delivery may vary from place to place and, therefore, there can be no universally applicable test or definition of the term. The assessment of a local delivery record is likely to be more robust if a longer term view is taken, since this is likely to take account of the peaks and troughs of the housing market cycle. Local planning authorities should aim to deal with any undersupply within the first 5 years of the plan period where possible. Where this cannot be met in the first 5 years, local planning authorities will need to work with neighbouring authorities under the ‘Duty to Cooperate’ (Paragraph: 035 Reference ID: 3-035-20140306).

2.21 The housing requirement is set at the starting point of the plan, which can be earlier than the date the plan is adopted. For a plan to be found sound it would have to be based on an Objectively Assessed Need for housing. The Guidance confirms that the assessment of development needs is an objective assessment of need based on facts and unbiased evidence. Plan makers should not apply constraints to the overall assessment of need, such as limitations imposed by the supply of land for new development, historic under performance, viability, infrastructure or environmental constraints. However, these considerations will need to be addressed when bringing evidence bases together to identify specific policies within development plans (Paragraph: 036 Reference ID: 3-036-20140306).

2.22 The Guidance notes that assessing the suitability, availability and achievability (including the economic viability of a site) will provide the information as to whether a site can be considered deliverable, developable or not currently developable for housing. The definition of ‘deliverability’ and ‘developability’ in relation to housing supply is set out in Footnotes 11 and 12 of the Framework (Paragraph: 029 Reference ID: 3-029-20140306).

2.23 The Guidance states that when assessing the suitability of sites or broad locations for development this should be guided by:

a. The development plan, emerging plan policy and national policy; and


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b. Market and industry requirements in that housing market or functional economic market area.

2.24 The Guidance goes on to state that sites in existing development plans or with planning permission will generally be considered suitable for development although it may be necessary to assess whether circumstances have changed which would alter their suitability. This will include a re-appraisal of the suitability of previously allocated land and the potential to designate allocated land for different or a wider range of uses. This should be informed by a range of factors including the suitability of the land for different uses and by market signals, which will be useful in identifying the most appropriate use (Paragraph: 019 Reference ID: 3-019-20140306).

2.25 The Guidance notes that a site is considered available for development, when, on the best information available, there is confidence that there are no legal or ownership problems, such as unresolved multiple ownerships, ransom strips tenancies or operational requirements of landowners. This will often mean that the land is controlled by a developer or landowner who has expressed an intention to develop, or the landowner has expressed an intention to sell. Because persons do not need to have an interest in the land to make planning applications, the existence of a planning permission does not necessarily mean that the site is available. Where potential problems have been identified, then an assessment will need to be made as to how and when they can realistically be overcome. Consideration should also be given to the delivery record of the developers or landowners putting forward sites, and whether the planning background of a site shows a history of unimplemented permissions (Paragraph: 020 Reference ID: 3-020-20140306).

2.26 The Guidance states that a site is considered achievable for development where there is a reasonable prospect that the particular type of development will be developed on the site at a particular point in time. This is essentially a judgement about the economic viability, and the capacity of the developer to complete and let or sell the development over a certain period (Paragraph: 021 Reference ID: 3-021-20140306).

2.27 The Guidance notes that the Local Planning Authority (LPA) should use the information on suitability, availability, achievability and constraints to assess the timescale within which each site is capable of development. This may include indicative lead-in times and build-out rates for the development of different scales of sites. On the largest sites allowance should be made for several developers to be involved. The advice of developers and local agents will be important in assessing lead-in times and build-out rates by year (Paragraph: 023 Reference ID: 3-023-20140306).

2.28 The Guidance states that deliverable sites for housing could include those that are allocated for housing in the development plan and sites with planning permission (outline or full that have not been implemented) unless there is clear evidence that schemes will not be implemented within five years. However, planning permission or allocation in a development plan is not a prerequisite for a site being deliverable in terms of the five-year supply. Local planning authorities will need to provide robust, up to date evidence to support the deliverability of sites, ensuring that their judgements on deliverability are clearly and transparently set out. If there are no significant constraints (e.g. infrastructure) to overcome such as infrastructure sites not allocated within a development plan or without planning permission can be


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considered capable of being delivered within a five-year timeframe (Paragraph: 031 Reference ID: 3-031-20140306).

2.29 The Guidance states that the size of sites will also be an important factor in identifying whether a housing site is deliverable within the first 5 years. Plan makers will need to consider the time it will take to commence development on site and build out rates to ensure a robust five-year housing supply. As part of this, local planning authorities should consider both the delivery of sites against the forecast trajectory and also the deliverability of all the sites in the five year supply. By taking a thorough approach on an annual basis, local planning authorities will be in a strong position to demonstrate a robust five year supply of sites. The Guidance is clear that the demonstration of a five year supply is a key material consideration when determining housing applications and appeals. As set out in the Framework, a five year supply is also central to demonstrating that relevant policies for the supply of housing are up-to-date in applying the presumption in favour of sustainable development (Paragraph: 033 Reference ID: 3-033-20140306).

2.30 In terms of monitoring, Paragraph 019 Ref ID: 2a-019-20140306 sets out that:

“Local planning authorities [should] monitor the stock and flows of land allocated, permissions granted and take-up of those permissions in terms of completions…If the historic rate of development shows that actual supply falls below planned supply, future supply should be increased to reflect the likelihood of under-delivery of a plan.”

High Court Decisions

Hunston Properties Ltd v Secretary of State for Communities and Local Government and St Albans City and District Council

2.31 His Honour Judge Pelling QC’s application of the Framework is important in this decision as it sets out that it is necessary to take account all of the words used in the Framework and in this case it was therefore necessary to take account of the opening words of paragraph 47, which seek to significantly boost the supply of housing. Judge Pelling states that paragraph 1 of the Framework represents a new start with a large number of policies being revoked and replaced including previous government planning policy. The decision is clear that he could not see how a constraints adjusted housing figure arrived at having regard to policy requirements as they applied at the time when the RSS took effect can be said to lead to the same conclusion when applying the first bullet point in

2.32 His Honour Judge Pelling QC stated that the approach adopted by the Inspector in this case was wrong in law. “The proper course involved assessing need, then identifying the unfulfilled need having regard to the supply of deliverable sites over the relevant period. Once that has been done it is necessary next to decide whether fulfilling the need in fact demonstrated together clearly outweighed the identified harm to the Green Belt that would be caused by the proposed development”. Judge Pelling’s judgment puts at the centre of any decision on housing proposals the requirement for Objectively Assessed Housing Needs.


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Court of Appeal Decisions

Hunston Properties Ltd v Secretary of State for Communities and Local Government and St Albans City and District Council

2.33 St Albans City and District Council challenged the Hunston decision in the Court of Appeal, but three senior judges dismissed the application and confirmed the judgement of the High Court.

2.34 The decision notes that the Inspector was only using the RSS figures as a proxy, but the Government has moved away from a top-down approach. The Judges stated that the Inspector was mistaken to use a figure for housing requirements below the full Objectively Assessed Needs figure until such time as the Local Plan process came up with a constrained figure.

2.35 The Court of Appeal Judges in their decision agreed with the High Court Judge that the Inspector had erred by adopting such as constrained figure for housing need, which led her to find that there was no shortfall in housing land supply in the District. The Judges identified that the Inspector should have concluded that there was a shortfall as the supply fell below the objectively assessed five year requirement.

2.36 The Judges noted that where the Inspector went wrong was to use a quantified figure for the five year housing requirement, which departed from the approach in the Framework, with particular regard to paragraph 47. They stated that on the figures before the Inspector, she was obliged (in the absence of a Local Plan figure) to find that there was a shortfall in housing land supply.

2.37 The Court of Appeal Judges overall conclusion is that the Inspector did err in law in the approach that she adopted to calculating the housing land requirement over the five year period. They therefore quashed her decision. The appeal by the Council to the Court of Appeal was therefore dismissed.

2.38 The Court of Appeal judgment has established that where there is no up to date plan Objectively Assessed Needs must be the starting point for any assessment of five year land supply.

2.39 This Court of Appeal case therefore highlights the following:

a. Objectively Assessed Needs cannot include consideration of constraints; and

b. Where there is no up to date plan Objectively Assessed Needs are the starting point for any assessment of 5 year land supply.

High Court Decisions

Wainhomes Holdings Limited v The Secretary of State for Communities and Local Government

2.40 An appeal decision by an Inspector (PINS Ref: APP/Y3940/A/11/2165449) was quashed because it failed to consider a material appeal decision forwarded to the Inspector before a decision was released. The case, notably, also involved the interpretation of Footnote 11 of the Framework.

2.41 In a judgment on the matter, His Hon Justice Smith concluded that there is no prior assumption that sites not having planning permission are deliverable. However, the fact that sites have been included in an emerging policy document or evidence base may (and often will) be a starting point for their inclusion to justify five year supply. In


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other words, inclusion may be evidence in support of a conclusion that the sites are deliverable. The weight to be attached to the evidence that they are deliverable will vary from case to case and is a matter of planning judgment for the Inspector. So too will be the weight to be attached to any evidence that they are not. Evidence that they cannot be delivered can in principle be specific (e.g. evidence that a site is contaminated or in delay) or general (e.g. evidence that all sites are subject to objection, though this evidence may be refined to the extent that the objections to particular sites are identified and capable of being considered).

J S Bloor, Hallam Land Management and Secretary of State V Stratford on Avon District Council

2.42 Mr Justice Hickinbottom has dismissed a s. 288 challenge in the High Court of Justice to the grant of planning permission on appeal by the Secretary of State for up to 800 dwellings, a mixed use local centre, highway and green infrastructure, and various associated works at land west of Shottery, a village to the west of Stratford-upon-Avon. The s. 288 challenge was brought by the local planning authority, Stratford-Upon-Avon District Council.

2.43 The Secretary of State considered the results of an independent report, which used the 2008 household projections to produce three main projections including one for 8,200 dwellings. While this lower projection was supported by Members of the Council, it was rejected by the Secretary of State in his decision on the appeal. The Secretary of State considered that a figure of 11,000 - 12,000 dwellings for the period 2008-2028 more closely accorded with the requirements of the Framework.

2.44 The Judge concluded for the purposes of responding to the appeal, the Secretary of State was required to assess unmet housing need, which required an assessment of housing requirements and on the basis of the evidence the figure of 8,200 dwellings was not sufficiently evidence-based.

Cotswold District Council v Secretary of State

2.45 This High Court ruling does help to clarify the test of when a Council should be considered to have a ‘persistent under-delivery of housing’ under the Framework. It helps clarify the timescales that should be used to establish a local authority’s record on the delivery of housing. This case gives greater weight to land supply cases that are looking at historic housing delivery over a shorter period.

2.46 In respect of the timescales over which a ‘persistent under-delivery of housing’ should be calculated (in reference to paragraph 47 of the Framework) the judge found that under delivery in 4 of the 5 years passed this test.

Appeal Decisions

2.47 In disagreeing with the Inspector’s decision to dismiss an appeal at Land off Abbey Road and Middlewich Road, Sandbach, Cheshire, the Secretary of State comments at paragraph 15 to 17 of his decision (PINS Ref: APP/R0660/A/10/2141564 – dated 7 February 2013):

“The Framework indicates the importance of identifying and maintaining a 5 year supply of deliverable housing sites, including a buffer of an additional 5%, or 20% where there is a record of persistent under delivery. The Framework also indicates that relevant policies for the supply of housing should not be


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considered up to date if the local planning authority cannot demonstrate a 5 year supply of deliverable housing sites. The presumption in favour of sustainable development then applies and planning permission should be granted unless the adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole. The Framework also sets out the need to boost significantly the supply of housing.” (SPRU emphasis)

2.48 A recent appeal decision at land north of Hampton Drive, Kings Sutton, Northamptonshire (PINS Ref: APP/Z2830/A/13/2194278) states:

“The Framework states at Footnote 11 that to be considered deliverable sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular that the development is viable. It goes onto say that sites with planning permission should be considered deliverable until permission expires, unless there is clear evidence that schemes will not be implemented within 5 years. While the Framework does not preclude sites without permission from being considered deliverable, there must be a real prospect that housing will be delivered on the site within 5 years.” (SPRU emphasis)

2.49 Sites with planning permission should be included in the supply of housing, unless there is a good reason to exclude them. Whereas sites without planning permission should not be excluded as a matter of principle, but they should not be included unless there is good reason to include them, such as in the case that a Council has resolved to grant permission subject to the imminent completion of a Section 106 agreement. In the case of sites without permission there needs to be compelling site specific evidence to demonstrate that the site is deliverable in order to justify its inclusion within five year supply. In the absence of site specific evidence, it has to be assumed that the site is not deliverable.

Dealing with historic under-provision

2.50 Any under provision in the delivery of housing should be addressed as part of the assessment of future supply and backlog should be specifically accounted for within the five year period (appeal decisions at Sellars Farm, Hardwicke – PINS Ref: APPC1625/A/11/2165865, Land at East of Outgang Lane, Pickering – PINS Ref: APP/Y2736/A/12/2170715 and land west of Station Road, Long Buckby – PINS Ref: APP/Y2810/A/12/2174386.

2.51 In recent appeal decisions there has been a shift towards the Sedgefield method of calculating land supply. The ‘Sedgefield method’ of calculating land supply involves adding any shortfall of housing from previous years to the five year period, whereas the ‘Liverpool method’ distributes the shortfall evenly over the whole remaining plan period. In an appeal at Honeybourne, Wychavon (PINS ref: APP/H1840/A/12/2171339) an Inspector dismissed the Council’s arguments in favour of the use the ‘Liverpool method’, saying that it would be inconsistent with the Framework by spreading additional provision over the whole plan period. In the appeal decision at Ashby-de-la-Zouch (PINS Ref: APP/G2435/A/13/2192131), the Inspector discusses the Sedgefield method vs the Liverpool method of calculating land supply. The Inspector concludes at paragraph 17 of the decision letter that the Framework is silent on this matter and there is no firm guidance elsewhere, but


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having regard to recent appeal decisions and to the Ministerial Statement Planning for Growth, to boost significantly (paragraph 47 of the Framework) implies a substantial and immediate effect, above and beyond the normal provision and for that reason the Sedgefield method is the most appropriate for recovering the shortfall and to be the most effective way of meeting the Framework objective. The Sedgefield method requires the shortfall to be dealt with as quickly as possible by adding it to the next five years of housing provision (Sandbach Road North, Alsager (PINS Ref: APP/R0660/1/13/2195201). It is also now the case that the PPG also favours the Sedgefield method of calculating supply (Paragraph: 035 Reference ID: 3-035-20140306).

2.52 Two recent Secretary of State decisions in Droitwich Spa, Worcestershire (PINS Refs: APP/H1840/A/13/2199085 & APP/H1840/A/13/2199426 – Decision date 2 July 2014) provide justification for applying the buffers required by paragraph 47 of the Framework to the total housing requirement (including historic shortfalls).

2.53 This approach is also supported by another appeal decision at land of Sandbach Road North, Alsager (PINS Ref: APP/R0660/1/13/2195201), which explicitly supports the requirement plus underachievement plus buffer approach. The Inspector stated:

“The 5 year requirement is 5,750. To that must be added the backlog of about 1,750, making a total of 7,500. Adding the 20% buffer brings a total requirement of some 9,000 dwellings over 5 years, or 1800 per annum. The fact that such a figure has rarely been reached in the past is not a reason for suggesting it is an inappropriate target. Significantly boosting supply surely implies that ambitious targets are appropriate.”

Local Appeal Decisions

2.54 An appeal decision dated 24th April 2014 at land off Bourne Road, Morton (PINS Ref: APP/E2530/A/14/2212740) states that in the Inspector’s view they were satisfied that South Kesteven District Council can currently demonstrate a five year supply of housing land plus a buffer of 5% based on the Core Strategy’s requirements.

2.55 A further appeal dated 16 September 24th July 2014 at land off Dovecote Meadows, Aveland Way, Aslackby and Laughton, Aslackby (PINS Ref: APP/E2530/A/142211568) also states that in the Inspector’s view they were satisfied that South Kesteven District Council can currently demonstrate a five year supply of housing land plus a buffer of 5% based on the Core Strategy’s requirements. It notes that the Council calculates that with the 5% buffer applied it has 5.1 years housing land supply (Paragraph 18).

2.56 In appeals APP/E2530/A/14/2224642 and APP/E2530/A/14/2224642 for the erection of 29 dwellings and 11 dwellings off Holywell Road, Castle Bytham, Grantham, the Inspector concluded (23rd December 2014) that whilst the appellants evidence questions whether all of the identified sites will be developed over the five-year period and at the rates anticipated, there was no substantive evidence to suggest that the Council cannot demonstrate a five-year supply of deliverable housing sites nor that there has been a record of persistent under delivery of housing (paragraph 9 of IR). In light of this the proposals were considered to conflict with policies which were considered up-to-date, and therefore the appeal was dismissed.


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2.57 In appeal APP/E2530/A/14/2212740 for the erection of 14 dwellings at land off Bourne Road, Morton, one of the main issues was whether the Council can demonstrate a five year supply of housing land and therefore whether the development plan policies are up-to-date for the purposes of paragraphs 49 and 14 of the Framework. The appellants challenged the delivery of five sites and based on evidence presented by both parties, the Inspector discounted only one site reducing the number of deliverable units by 72. This reduction still allowed the Council to meet the five year requirement plus the 5% buffer. Accordingly the Inspector concluded in April 2014 that the development plan policies were not out-of-date (paragraph 27 of IR).

2.58 In appeal APP/E2530/A/14/2211568 for the erection of 2 dwellings at land off Dovecote Meadows, Aveland Way, Aslackby and Laughton, housing land supply was considered under ‘other matters’. Paragraph 17 of the Inspectors Report (September 2014) highlighted that the Council’s latest Strategic housing Market Assessment indicates that the housing requirement for the District ranges from 615 to 710 dwellings per year, the Core Strategy requirement is towards the upper end of this scale. The Inspector concludes that whilst the Core Strategy housing requirement (680 dwellings per annum) was based on the East Midlands Regional Plan requirement, it is the most up-to-date figure that has been tested, 680 dwellings per annum is therefore the best figure available for calculating the housing requirement for the area. The Inspector goes on to acknowledge that past delivery rates have exceeded the requirement and therefore a 5% buffer should apply and at the time of determining the appeal in September 2014, the Council could demonstrate a 5.1 year housing land supply. Again the appellant in this case challenged the deliverability of some sites that make up the housing land supply. The Inspector concludes at paragraph 24 that the number of houses identified in the Council’s Five Year Housing Land Supply Statement is a realistic estimate of the number of houses these sites could deliver. Accordingly the Inspector concludes that the Council has a five year housing land supply including a 5% buffer and as such the policies are up-to-date.

2.59 None of the above appeals were considered in the context of the most recent Five Year Housing Supply Assessment, rather they relied on an assessment of previous iterations of this document. Overall the Inspectors in recent appeal decisions have concluded that policies are up-to-date as the Council can demonstrate a five year housing land supply however the appellants have not rigorously challenged the five year land supply.


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3.0 SOUTH KESTEVEN DISTRICT COUNCIL’S HOUSING LAND SUPPLY

POSITION

Regional Spatial Strategy

3.1 The RSS for the East Midlands Plan was adopted in March 2009 and was revoked on 12th April 2012. Policy 13a titled ‘Regional Housing Provision (excluding Northamptonshire)’ states the annual apportionment from 2006 for South Kesteven was 680 dwelling per annum, with a total housing provision from 2006-2026 of 13,600 dwellings.

3.2 Since the revocation of the RSS, and in the advent of the St Albans decision, this figure can no longer be fully relied upon by the LPA in the calculation of future supply and the Council has to consider, as required by the Framework, Objectively Assessed Need.

3.3 The RSS is relevant to considering historic achievement within the District against its adopted and tested targets that were established through evidence and tested at an Examination in Public.

Core Strategy

3.4 The South Kesteven Core Strategy was adopted on 5 July 2010. Policy H1 of the Core Strategy states that new housing development in South Kesteven during the period 2006-2026 should be planned and phased to deliver the minimum level of housing development required by the Regional Plan, 13,600 dwellings (680 per annum). The Council adopted its Site Allocations and Policies DPD in April 2014. The Council expects to commence a review of its plan towards the end of 2015. A new SHMA is in preparation in collaboration with Peterborough City Council and Rutland County Council.

Local Plan

3.5 3.5 The South Kesteven Local Plan was adopted in April 1995 and looked up to 2001. Paragraph 2.17 of the Local Plan states that South Kesteven, allowing for those built since 1988, provision needed to be made for the development of about 10,090 dwellings within the District between 1990 and 2001 in order to meet the housing requirements of the Structure Plan Alteration No.1 (917 per annum). The Local Plan and Structure Plan are out of date and time expired and therefore the housing targets within them have no relevance to the calculation of land supply.

Peterborough Sub-Regional Strategic Housing Market Assessment Final Report (July 2014)

3.6 The Sub-Regional Housing Market Assessment (‘SHMA’) for Peterborough sets out a higher level of anticipated housing need than the Core Strategy, as per paragraph 10.27 of the report.

3.7 The reported demographic projections suggest a need for 660 homes per annum, but the sensitivity analysis considering household formation rates suggested need could be higher, up to 675 homes per annum. The affordable needs evidence provides some basis for potentially higher levels of housing provision. Drawing the housing evidence together the SHMA considers that he housing need for South Kesteven would fall between 660-710 homes per annum for the period to 2031. The lower end


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of this range is based on demographic projections. The higher end of this range would support stronger affordable housing delivery and could support stronger growth in labour supply.

3.8 For the shorter time periods the dwelling requirement is much higher especially in terms of the Framework compliant projection which reflects the council’s economic growth aspirations. These projections require an average of 994 dwellings a year for the period 2011 to 2021 and for period of the development plan to 2016 there would be a requirement of 898 dwellings a year.

Five Year Housing Land Supply Assessment 2014-2019 (as at 1st April 2014) 3.9 This paper sets out an assessment of the Council’s latest position on the five year

housing land supply for the period 2014-2019.

3.10 It notes that the South Kesteven Core Strategy requires the provision of 13,600 homes to be built over the plan period 2006-2026, an average of 680 homes per year. Taking account of the 5,373 dwellings completed since 2006, the assessment states that the housing requirement over the remaining period of the Plan is 8,227 dwellings, an average of 686 per year. The assessment therefore states that the requirement for the five year period 2014-2019 is 3,430 dwellings (686 x 5 years).

3.11 The assessment states that South Kesteven currently has an identifiable and deliverable housing land supply of 4,361 homes expected to come forward over the next five years, which equates to 6.1 years supply. This is made up of:

a. 650 dwellings on housing sites (in adopted Plans)

b. 1,681 dwellings with planning permission where development has already started

c. 704 dwellings with planning permission where development has yet to start

d. 20 dwellings on sites where there has been a resolution of permit subject to completion of a Section 106 Agreement

e. 240 dwellings on small windfall sites

f. 856 dwellings on sites that are not allocated or with planning permission but which could deliver housing within the 5 year period

g. 210 dwellings on sites allocated in later phases of adopted Plans which could be brought forward

3.12 The assessment notes that it will be updated at least annually with the next update to the housing land supply position setting out the position as at April 2015.

3.13 South Kesteven’s five year land supply assessment 2014-2019 is prepared using the methodology outlined below:

a. Identification of past delivery rates in the period since 2006 and the requirement for housing provision over the next 5 year period;

b. Identification of all potential sources of housing delivery in this 5 year period. Potential sites include:

c. Housing allocations in adopted Plans;


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i. Sites that have planning permission (outline or a full planning permission);

ii. Specific sustainable sites that are not allocated to have planning permission and have the potential to make a contribution to housing delivery during the 5 year period;

iii. An allowance for small windfall sites based upon historic build rates; and

iv. Assessment of the deliverability of all potential sites in terms of the footnotes to paragraph 47 of the NPPF and the PPG.

3.14 The assessment notes that the Framework establishes that in monitoring a five year supply of housing land LPAs should provide an additional 5% buffer (moved forward from later in the plan period), unless there is evidence of persistent under-delivery in which case a 20% buffer should be provided.

3.15 The Council’s land supply assessment states that since the adoption of the Core Strategy in 2010 development rates have dipped below its target rate of 680 per annum as identified in the below table.

Housing delivery rates since 2006 Table 1:Year Core Strategy Trajectory Target Units actually delivered

2006-2007 971 971

2007-2008 886 886

2008-2009 663 663

2009-2010 440 520

2010-2011 550 550

2011-2012 590 494

*additional survey completions 2006-2011

252

2012-2013 625 497

2013-2014 645 541

Total 5370 5374

Annual Average 671 672

3.16 The Council undertook a physical survey in 2011 of all outstanding commitments. This was considered necessary by the Council as it considered that a number of sites (particularly small sites) were known to have been completed but still featured on the commitment list as sites under construction but not completed. This survey revealed that since 2006, 252 additional homes had been completed. These additional completions had been included with the committed figure in previous housing land supply assessments. As a result of the survey the sites are now counted by the Council as completions rather than commitments. However, the actual year of completion cannot be confirmed so the 252 has been added as a separate delivery figure rather than apportioning it to each year.

3.17 3.31 Table 7 (below) shows South Kesteven’s five year housing requirement based on the requirements of Policy H1 of the adopted Core Strategy plus either a 5% or 20% buffer. The table also identifies how many houses have been completed since April 2006, what the residual requirement is for the remaining plan period and,


Roland G Bolton


therefore, what the housing requirement is for the District for the five year period covered by this assessment.

Housing requirement based on the South Kesteven Core Strategy Table 2:(July 2010) and buffer

Housing Requirement Number of Dwellings

Housing Requirement 2006-2026 (Core Strategy Policy H1) 13600

Completed dwellings 01/04/06 – 31/03/14 5374

Residual Requirement 2014 – 2026 (13600 – 5367)

8226

Annual Requirement (8226/12) 686

Requirement for 5 years 2014-2019 (Residual annual average of 686 dwellings x 5 years)

3430

Buffer Requirement @ 5%

5% buffer (Requirement for 5 years (3430) x 5%) 172

Requirement for 5 years 2014-2019 plus 5% buffer (3430 + 172)

3602

Annual Requirement plus 5% buffer (3602/5) 720

Buffer Requirement @ 20%

20% buffer (Requirement for 5 years (3430) x 20%) 686

Requirement for 5 years 2014-2019 plus 20% buffer (3430 + 686)

4116

Annual Requirement plus 20% buffer (4117/5) 823

3.18 The assessment provides the following Table, which provides a review of previous delivery on small sites.

Previous delivery rates on small sites Table 3:Year Completions on sites of 10 or less dwellings (excluding

gardens)

Towns LSCs Total

08-09 09-10 10-11 11-12 12-13 13-14

85 46 100 57 23 1

28 39 60 28 14 4

113 85 160 85 37 5

Total 312 173 485

52 pa 29 pa 81 pa

3.19 The assessment states that in view of the past completion rates, and continued trend

for development on small sites, the Council consider that it would seem realistic for a windfall allowance of 80 units per annum to be made in years three to five of the five year period (2016 – 2019), assuming that any windfall allowance for the early part of the five year period will already be in the system.

3.20 The assessment states that although the Council consider that a 5% buffer is appropriate in this District at this time, it has included an assessment of housing land supply against a requirement for a 20% buffer it the Tables below.


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Table 4: Five Year Supply 2014-2019 with 5% buffer Housing Requirement



Residual Requirement 2014-2016 (13600 – 5374)

8226

Annual Requirement (8226/12)

686


3430

Buffer Requirement

5% buffer (Requirement for 5 years (3430) x 5%)

172

Requirement for 5 years 2014-2019 plus 5% buffer 3602

Annual Requirement plus 5% buffer (3602/5)

720

Supply of Sites

Number of dwelling expected to be delivered in five year period on housing sites in Local Plan documents

650

Dwelling under construction on sites with planning consent (at 31/03/14) Large sites Small sites Total

1504

177

1681

Dwellings on large sites (sites of 10 or more houses) with planning permission where construction has not begun, which are considered deliverable and likely to come forward within five years

704

Dwellings on large sites with resolution to grant planning permission subject to S106 Agreement completion

20

Windfall sites (of less than 10 houses) expected to contribute to Supply in later years (2016-2019) @ 80 per annum

240

Dwellings on large sites without planning consent in sustainable Locations and assessed as being deliverable within five years

801

Council’s Capital Programme 55

Buffer sites (allocated in later phase of plan period) 210

Total Supply 4361

Number of years supply (total divided by annual requirement – 4361/720)

6.1


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Table 5: Five Year Supply 2014-2019 with 20% buffer Housing Requirement



Residual Requirement 2014-2026 (13600 – 5374)

8226

Annual Requirement (8226/12)

686


3430

Buffer Requirement

20% buffer (Requirement for 5 years (3430)x 20%

686

Requirement for 5 years 2014-2019 plus 20% buffer 4116

Annual Requirement plus 20% buffer (4116/5)

823

Supply of Sites

Number of dwellings expected to be delivered in five year period On housing sites in Local Plan documents

650

Dwellings under construction on sites with planning consent (at 31/03/14)

Large sites

Small sites

Total

1504

177

1681

Dwellings on large sites (sites of 10 or more houses) with planning permission where construction has not begun, which are considered deliverable and likely to come forward within five years

704

Dwellings on large sites with resolution to grant planning permission subject to S106 Agreement completion

20

Windfall sites (of less than 10 houses) expected to contribute to Supply in later years (2016-2019) @ 80 per annum

240

Dwellings on large sites without planning consent in sustainable Locations and assessed as being deliverable within five years

801

Council’s Capital Programme 55

Buffer sites (allocated in later phase of plan period) 210

Total Supply 4361

Number of years supply (total divided by annual requirement – 4361/823)

5.3


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4.0 ANALYSIS AND THE STRATEGIC PLANNING RESEARCH UNIT’S LAND SUPPLY CALCULATIONS

Objectively Assessed Need

4.1 Using the Chelmer Model a separate report has been prepared by DLP Planning Ltd’s SPRU on the Objectively Assessed Need for Housing, which considers the up to date housing needs for the district, in accordance with the Framework and PPG. As discussed in the report the most up to date evidence is the 2012 Sub National Population Projections, which take account of the 2011 census.

4.2 The housing requirement resulting from these projections has been calculated using the Chelmer model and would suggest a demographic dwelling requirement of 614 per year for the period 2011 to 2031, allowing for a moderate improvement in the ability of the population to form households from the 2011 household representation rates. The impact of increasing the level of dwelling provision to meet the recent Experian employment projections would require some 781 dwellings per year. However, the employment led projection which fulfils the requirements of the Framework is the one which reflects the Council’s and the LEP’s growth aspirations, and SPRU’s assessment of this level of employment growth would result in a target requirement of 839 dwellings a year against which to assess the five year supply.

4.3 As well as using this requirement calculated by SPRU, the assessment also uses the SHMA requirement required to meet the economic growth objectives of the Council. These are also discussed in some detail in the accompanying SPRU report on the OAN. This projection varies considerably over the 25 year period as employment growth falls towards the end of the period. The assessment therefore looks at this requirement for the 10, 15, 20 and 25 year periods although in the context of calculating the five year land supply the reliance of lower potential housing requirements in 15 years plus time suggests that greater weight should be given to the shorter term projections.

Achievement against targets and needs

4.4 The following Table considers the achievement against the targets set for the District by the now revoked RSS and adopted CS, as well as needs.


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Table 6: Consideration of deliver rates against various assessments of need

Fin

an

cia

l Y

ear

Net

Dw

ellin

g

Co

mp

leti

on

s (

an

nu

al)

No

. o

f d

wellin

gs a

bo

ve

or

belo

w 6

80 a

ye

ar

No

. o

f d

wellin

gs a

bo

ve

or

belo

w

–

pa 9

94

(SH

MA

Pro

j 4 2

011

to

2021)

No

. o

f d

wellin

gs a

bo

ve

or

belo

w –

898 p

a

(SH

MA

Pro

j 4 2

011

-

2026)

No

. o

f d

wellin

gs a

bo

ve

or

belo

w –

783 p

a

(SH

MA

Pro

j 4 2

011

-

2031)

No

. o

f d

wellin

gs a

bo

ve

or

belo

w –

710 p

a

(SH

MA

Pro

j 4 2

011

-

2031)

No

. o

f d

wellin

gs a

bo

ve

or

belo

w

– S

PR

U O

AN

839 p

a t

o 2

03

1

1 2006/07 971 291 2 2007/08 886 206 3 2008/09 663 -17 4 2009/10 520 -160 5 2010/11 550 -130 6 2011/12 494 -186 -500 -404 -289 -216 -345

7 2012/13 497 -183 -497 -401 -286 -213 -342

8 2013/14 541 -139 -453 -357 -242 -169 -298

Additional survey 2006 - 2011 252 252

Total years 1-8 5,374

Under supply

-66 -1,450 -1,162 -817 -598 -985

4.5 The Table shows years of underachievement against the various targets. This only shows overachievement in the years 2006/07 and 2007/08, for the RSS/CS requirement in all other cases there has been a persistent undersupply. Even with the RS/CS requirement there has only been an oversupply in the first two years of the chosen period and then a persistent undersupply from 2008/09 – 2013/14, housing delivery has been below the targets set in the RSS/CS. Therefore, South Kesteven is a 20% authority, which is a conclusion that is reinforced by the Costwold High Court decision. It should be noted that targets set in the RSS /CS are not ceilings. The table also shows level of underachievement against up to date needs.

Non-implementation on small sites

4.6 10% discount rate is accepted as good practice, it is widely used by local authorities, and has also been endorsed by the Secretary of State in appeal decisions (PINS Refs: APP/L2820/A/07/2047741, APP/H1840/A/12/2171339, APP/X2410/A/13/2196928 & APP/X2410/A/13/2196929). It is also a reasonable


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assumption; yet South Kesteven has not made this level of lapse-rate allowance in its trajectory for small sites (under 10 dwellings). A 10% non-implementation rate has therefore been applied to small sites.

Windfalls

4.7 Paragraph 48 of the Framework and PPG state that local planning authorities may make an allowance for windfall sites in the five-year supply if they have compelling evidence that such sites have consistently become available in the local area and will continue to provide a reliable source of supply. Any allowance should be realistic having regard to the Strategic Housing Land Availability Assessment, historic windfall delivery rates and expected future trends, and should not include residential gardens.

4.8 An onward discount rate to the windfall allowance has been justified at appeal (see decision in Wincanton – PINS Ref: APP/R3325/A/12/2170082) as the number of opportunities for windfall developments coming forward, by definition, decreases in time.

4.9 The review of past windfall completions has only looked back to 2008/09. It is expected this analysis would go back much further in order to provide a review of historic windfall delivery rates, at least from the start of the Core Strategy period, being 2006/07. Windfall sites are a finite resource and will diminish over time and it is evident from the Council’s assessment that delivery on small sites is falling (see Table 8 above). It is therefore reasonable to suggest a moderate reduction, and as such a 10% discount has been applied to windfall sites.

Land supply calculations

4.10 Following the review of the potential delivery from sites attached at Appendix 1 and the consideration of an appropriate annual requirement for the district the land supply calculations are set out in the following Table.


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Table 7: SPRU Land Supply Calculations 2014/15 to 2018/19

12A: Land Supply Calculation 2014/15 to 2018/19 DLP

Annual requirement – RSS/CS 680

Five year requirement 3,400

Underachievement 66

Five year requirement + underachievement 3,466

Five year requirement + underachievement + 20% 4,159

Annualised five year requirement 832

Projected Supply 3,046

Five year supply 3.66

12B: Land Supply Calculation 2014/15 to 2018/19 DLP

Annual requirement – pa 994 (SHMA Proj 4 2011 to 2021) 994


Underachievement 1,450



Annualised five year requirement 1,541



12C: Land Supply Calculation 2014/15 to 2018/19 DLP

Annual requirement – 898 pa (SHMA Proj 4 2011 - 2026) 898








12D: Land Supply Calculation 2014/15 to 2018/19 DLP

Annual requirement – – 783 pa (SHMA Proj 4 2011 - 2031) 783


Underachievement 817







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12E: Land Supply Calculation 2014/15 to 2018/19 DLP









12F: Land Supply Calculation 2014/15 to 2018/19 DLP

Annual requirement – SPRU OAN 839 pa to 2031 839








4.11 The Tables above identify for the period 2014/15 to 2018/19 that South Kesteven’s land supply would fall below five years (+20%) required by the Framework in all situations, if SPRU’s assessment of supply and treatment of undersupply are correct.

4.12 The use of the up to date calculation of housing requirement whether it be the SHMA’s assessment based on employment growth aspirations or SPRU’s, would result in an undersupply of housing against all of the SHMA Framework compliant projections except the one even allowing for the Council’s assessment of supply and 5% buffer.

4.13 The one projection that results in there being a five year land supply in the context of the Council’s assumptions about supply, are those which extend the period to 2036. This average means that housing which is required to support the economic growth aspirations of the Council in the next 15 years is effectively not provided until 2026 to 2036. Even this only provides 5.1 years supply. Such an approach is not considered to be in accordance with the Framework which seeks to support economic growth.

4.14 This is demonstrated in the table below:


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Table 8: SKBC: Land Supply Calculations 2014/15 to 2018/19

13A: Land Supply Calculation 2014/15 to 2018/19 DLP

Annual requirement – pa 994 (SHMA Proj 4 2011 to 2021) 994






SKBC Projected Supply 4,361


13B: Land Supply Calculation 2014/15 to 2018/19 DLP









13C: Land Supply Calculation 2014/15 to 2018/19 DLP

Annual requirement – – 783 pa (SHMA Proj 4 2011 - 2031) 783








13D: Land Supply Calculation 2014/15 to 2018/19 DLP









13E: Land Supply Calculation 2014/15 to 2018/19 DLP

Annual requirement – SPRU OAN 839 pa to 2031 839









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5.0 CONCLUSION AND RECOMMENDATION

5.1 This report, prepared by the Strategic Planning & Research Unit (SPRU) within DLP Planning Ltd, provides a review of South Kesteven District Council’s current position in achieving a five year supply of housing land.

5.2 In South Kesteven District Council’s most recent Five Year Land Supply Assessment (as at April 2014), the Local Planning Authority (LPA) claims that it has a supply of 6.1 years of deliverable housing land with a 5% buffer applied or 5.3 years with a 20% buffer in accordance with paragraph 47 of the Framework.

5.3 More detailed work completed by the SPRU demonstrates that this overall figure is further reduced on the basis that:

a. There has historically been a persistent under-delivery of housing against targets for Kesteven as a whole and therefore a 20% buffer should be applied across the whole District; and

b. A review of delivery and yield of individual sites.

5.4 In the first two years of the 20 year plan period housing delivery matched or exceeded the Core Strategy annualised target of 680 units. However, since 2008/2009 development rates have dipped below this target rate. The Council consider that a 5% buffer is appropriate in this District at this time, but provides no evidence to justify this position. In light of the historic undersupply of housing within the district, as evidenced by the underachievement against requirements in the past six years, it is submitted that South Kesteven is a 20% authority in terms of paragraph 47 of the Framework. This conclusion is reinforced by the Costwold High Court decision.

5.5 Using the Chelmer Model a separate report has been prepared by DLP Planning Ltd’s SPRU on the Objectively Assessed Need for Housing, which considers the up to date housing needs for the District, in accordance with the Framework and Planning Practice Guidance (PPG). Experian projections and assumptions in the report are considered to be the most robust and provide a target requirement of 839 dwellings a year against which to assess the five year supply.

5.6 This report concludes following a review of the sites included in the Council’s trajectory that against the annualised target of the Core Strategy that South Kesteven has 3.66 years supply of housing (+ 20%) for the period 2014/15 to 2018/19, which falls well below the five year supply (+20%) required by paragraph 47 of the Framework. When applying the conclusions of the separate report prepared by the SPRU on Objectively Assessed Need, the housing land supply position would worsen and fall to just 2.45 years.

5.7 Using the framework compliant economic led projections in the Council’s own SHMA for the periods 2011 to 2021 or 2026 (the Core Strategy Period) would result in a lack of a five year land supply even when judged against the Council’s own assumptions of supply of between 3.23 and 3.67 years supply.

5.8 The purpose of the Government’s Framework and PPG is to significantly boost the supply of housing and to plan to meet housing needs in full.

5.9 Therefore, the lack of a demonstrable five year supply of housing land is a significant material consideration in favour of proposals for new housing.


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APPENDIX 1: REVIEW OF SITES


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LPA’s expected completion for 2014/15 – 2018/19

DLP’s Land Supply Assessment of South Kesteven District Council Five Year Supply Period 2014/15 – 2018/19

Site Location SHLAA Ref LPA or Application Ref

14/15 15/16 16/17 17/18 18/19 Total 2014 -2019 -Deliverable

Non deliverable Comments

Small Sites with Planning Permission under construction

184 166 18

A 10% non-implementation rate has been applied.

Windfall Sites 240 80 72 65 217 23 A 10% annual discount rate has been applied.

Site Allocated in Local Plans without Planning Permission

1 Southern Quadrant, Grantham

SK/GRA/01 Outline application S14/2169

150

50

50

100

This site is allocated for up to 4,000 homes in the Core Strategy (Policy H2B). An outline application for a mixed use urban extension comprising 3,700 units was submitted by a Trust in September 2014 and is yet to be determined (LPA Ref: S14/2169) . Based on the Colin Buchanan Housing Delivery on Strategic Sites Research Study (2005), the average time lag between submission of an application and the first year of build is five years for strategic extensions of this scale. Assuming house builders are signed up within the five years, the S106 Agreement agreed and outline planning consent is forthcoming, reserved matters approved and conditions discharged, it is only likely that 50 units will come forward at most towards the end of the five year period 2014 -2019.

2

North West Quadrant, Grantham (Phase 2)

GRA14-197

GRA14-198

GRA14-199

225 0

225

This whole site is allocated for 3,500 houses in the Core Strategy (Policy H2A). The site is identified in the SHLAA for 1,127 units, with the LPA expecting 225 units to be developed in the five year period. However, the SHLAA identifies that 202 units are likely to come forward in 2019 – 2024 and access to the site cannot be achieved until adjacent development progresses further. No planning applications are currently pending consideration on the site. The site cannot be currently directly accessed from an existing highway.

Site Allocation and Policies Plan

3 Former Aveland School, Billinborough

SK/BIL/15

Outline planning application S14/1316

35 20 5 25

10

This site is allocated in the Site Allocations and Policies Plan for 35 units. An outline application for 25 units was submitted by the Lincolnshire County Council in May 14 and has yet to be determined. Assuming outline planning approval is obtained, reserved matters will need to be approved and conditions discharged. The site would then need to be marketed and sold to a developer. It is however expected all 25 units will come forward in the five year period 2014/15 – 2018/19.

4 Site off Bridge End Road, Colsterworth

SK/COL/07 Full planning application S13/1931

40 20 28 40

-8

This site is allocated in the Site Allocations and Policies Plan for 40 units. A full planning application was submitted by a national house builder in August 2013 for 48 units, but has yet to be determined. Given that Item 7 below was refused on grounds including scale and density, despite being policy compliant in terms of overall housing numbers, there is uncertainty over whether the Council would support this application as it seeks 8 units above that set out in the Site Allocations and Policies Plan. Nevertheless, assuming full planning permission is granted in 2015/16 and conditions discharged, construction could commence 2016/17. It is therefore expected all 48 units could come forward within the five year period 2014/15 – 2018/19.

5

Land between Peterborough Road and Towngate East, Market Deeping

SK/DEE/25 EIA screening S13/1782

150 35 35 35 45 150

0

This site is allocated in the Site Allocations and Policies Plan for 200 units, with development expected 2016 - 2026. A request for an EIA Screening opinion was made in respect of residential development of up to 250 dwellings in June 2013 and the LPA confirmed that an EIA would be required in July 2013. No planning applications have been made in relation to the site. The site is under the control of a national house builder. Assuming an outline application was forthcoming in 2014/15, this would need to be approved, reserved matters approved and then conditions discharged. It is therefore unlikely that any development could commence prior to 2016/17. It is anticipated that 55 units could come forward in the five year period 2014/15 – 2018/19.






6 South of Kettering Road, Stamford

SK/STA/31

Refused full planning application S13/3322

Full planning application S14/3078

50

39

39

-11

This site is allocated in the Site Allocations and Policies Plan for 50 units. An application was made for full planning permission for 48 units in January 2014 and refused May 2014 (LPA Ref: S13/3322). The grounds for refusal were that the scale, density, layout, design and appearance of the development failed to preserve and enhance the character and setting of the area. Subsequently, a full planning application for 39 units has recently been sought, November 2014 and is yet to be determined (LPA Ref: S14/3078). The site is under the control of a national house builder and the LPA has considered the site available for development. Assuming this application is approved 2015/16, conditions could be discharged 2016/17 and construction commence that year. It is therefore likely that 39 units will come forward in the five year period 2014/15 – 2018/19.

Sites with Planning Permission under Construction

7 Elsea Park, Bourne

Multiple reserved matters approvals

Outline planning permission SK94/0125

552 100 105 110 116 121 552

0

This site has outline planning permission for 2,000 units, which was approved in January 2001 (LPA Ref: SK94/0125). Around 943 units have been completed with an annual completion rate of 86 units per year during the period 2006 – 2014. The LPA assumes completions will have an annual increase of 5% in the five year period 2014/15 – 2018/19, equating to a total of 552 units. The site is under the control of four national house builders and the completion rate put forward by the LPA appears reasonable.

8 Land off Burghley Street, Bourne

Full planning permission S11/2953

14 14 14

0

This site has planning full permission for the demolition of existing buildings and a residential and retail development including 14 units, sought December 2011 and approved March 2012 (LPA Ref: S11/2953). The site is under the control of a developer and it is expected all 14 units will be completed in the five year period 2014/15 – 2018/19.

9 Old Corn Mill and adjacent land, Bourne


18 0 0

18

The site has full planning permission for 24 retirement flats (C2 Use), submitted December 2006 and approved March 2007 (LPA Ref: S06/1625). Construction is underway and it is expected the remaining 18 units will be completed in the five year period. However, the recent Secretary of State appeal decision at Droitwich Spa concluded that C2 use should not be included as dwellings in the context of land supply due to their “institutional form and occupational age.” (PINS Ref: APP/H1840/A/13/2199085 & APP/H1840/A/13/2199426)

10

Former Raymond Mays Garage, Spalding Road, Bourne

Reserved Matters Approval

S10/1650

Outline planning permission S08/0286

15

15

15

0

The site has reserved matters permission for 29 units, submitted August 2010 and approved November 2010 (LPA Ref: S10/1650). Outline planning permission was sought in March 2008 and approved in June 2008 (LPA Ref: S08/0286). The site is under the control of a national house builder with construction underway. It is expected all remaining units will come forward within the five year period 2014/15 – 2018/19.

11 The Croft, North Road, Bourne

SK/BOU/15 Full planning permission S09/1699

43

23

20

43

0

The site has full planning permission for ‘restoration and conversion of The Croft to wardens accommodation & communal facilities and erection of 68 retirement dwellings and associated infrastructure’. The application was submitted in July 2009 and approved November 2009. Construction is underway and the site is being actively marketed by a national house builder. It is expected that all remaining units will come forward within the five year period 2014/15 – 2018/19.






12

Rainbow Superstore, Manning Road, Bourne

Reserved Matters Approval S10/1645


33 33 33

0

The site has planning permission for 79 units. Reserved matters were sought in August 2010 and approved November 2010 (LPA Ref: S10/1645). Outline planning permission was sought in October 2006 and approved in June 2008 (S06/1388). The site is under the control of a national house builder and construction is underway. It is expected all remaining units will come forward within the five year period 2014/15 – 2018/19.

13

Fossitt & Thorne, Eastgate, Bourne

Certificate of lawful use S14/0325

Time extension S10/1204


11 11 11

0

This site has full planning permission for the demolition of the existing garage and erection of 11 units (approved May 2007) (LPA Ref: S06/1206). A time extension was sought in May 2010 and approved in January 2011 (LPA Ref: S10/1204). A lawful use certificate for commencement was sought and approved in February 2014, the applicant being a Bank (LPA Ref: S14/0325). Although the site has been cleared, the most recent application being made by a Bank casts considerable doubt of the likelihood of any units being completed within the five year period 2014/15 – 2018/19. Despite the likely delays 11 dwellings from this site have been included in the five year period.

14

Adjacent to Back Lane and West of Stephens Way, Deeping St James


11 11

11

0

This site has full planning permission for 11 units, all of which are affordable homes. The application was submitted in November 2006 and approved November 2007 (LPA Ref: S06/1493). The site is under the control of a local house builder with construction underway and it is expected that all 11 units will be completed in the five year period 2014/15 – 2018/19.

15

Land North of Spalding Road, Deeping St. James

Full Planning Permission S11/2050

1 1 1

0 The site has full planning permission for 18 units. The application was submitted in September 2011 and approved September 2012 (LPA Ref: S11/2050). It is expected all remaining units will come forward within the five year period 2014/15 – 2018/19.

16

Land off Spalding Road, Deeping St. James


13 13 13

0

This site has full planning permission for 13 units. The application was submitted in July 2013 and approved January 2014 (LPA Ref: S13/2001). An application to discharge conditions was sought January 14 and approved April 14 (LPA Ref: S14/0070). The site is under the control of a national house builder and construction is underway. It is expected all 13 units will come forward within the five year period 2014/15- 2018/19.

17

North West Quadrant, Grantham (Poplar Farm East) (phase 1)

SK/GRA/02 Outline planning permission S08/1231

410

82

82

82

82

82

410

0

This site has outline planning permission for a mixed use urban extension including up to 1,800 units, submitted June 2009 and approved June 2011 (LPA Ref: S08/1231). The site is controlled by two national house builders and a regional construction company. Construction is underway. Based on previous completion rates the LPA expects 68 units to come forward annually. There are three reserved matters approvals which are currently being built out, providing for 274 dwellings in total. Application S13/3444 was submitted in December 2013 and approved March 2014. Application S12/1468 was submitted in January 2012 and approved October 2013. Application S12/1331 was submitted in June 2012 and approved October 2012. Based on previous completion rates it is expected further reserved matters applications will be sought and approved and 340 units is a reasonable estimate for the number of units which will come forward within the five year period 2014/15 – 2018/19.






18 Mount Street, Grantham

Confirmation of commencement S10/2783 Reserved matters approval S08/0829 Outline planning permission S04/1566

Outline permission S03/1744

16 0

16

An outline planning application was submitted in October 2004 and approved in February 2005 for 16 flats. Outline planning permission for 20 flats was granted on appeal in November 2005 (PINS Ref: APP/E23530/A/04/1163641). Reserved matters approval was sought in July 2008 and approved October 2008. Confirmation of commencement of the development was sought in December 2010 and approved in February 2011. Construction is underway and foundations have been dug on the site. The site is however now overgrown and there is no evidence of further construction. The site has poor access and is bound to the north by the East Coast Mainline Railway, which runs above the level of the site which will impact marketability.

19

49 St Catherines Road, Grantham


42

0

42

The site has full planning permission for retirement accommodation (C2) comprising 42 units. This was approved by the Secretary of State in August 2010 (PINS Ref: APP/E2530/A/12/2171469). The site is under the control of a national retirement home developer with construction underway. It is expected all 42 units will come forward in the five year period 2014/15 – 2018/19. However, the recent Secretary of State appeal decision at Droitwich Spa concluded that C2 use should not be included as dwellings in the context of land supply due to their “institutional form and occupational age.” (PINS Ref: APP/H1840/A/13/2199085 & APP/H1840/A/13/2199426).

20

Land off Springfield Road & Caunt Road, Grantham


1 1 1

0

The site has full planning permission for 67 units. The application was submitted in February 2010 and approved in September 2010. The site is under the control of a national house builder and construction is underway. It is expected all remaining units will come forward within the five year period 2014/15 – 2018/19.

21

Land off Springfield Road, Grantham


40

0

40

This site has full planning permission for a 64 bed nursing home and 72 extra care apartments, sought June 2011 and approved March 2012 (LPA Ref: S13/1931). Conditions in relation to Phase 1 have been discharged and the nursing home has come forward as Phase 1. However, not all the conditions requiring to be discharged for the extra care facility have been discharged and therefore construction on the extra care facility has yet to commence. There is no clear indication of when this will come forward, but it is expected within the five year period 2014/15 – 2018/19. However, the recent Secretary of State appeal decision at Droitwich Spa concluded that C2 use should not be included as dwellings in the context of land supply due to there “institutional form and occupational age.” (PINS Ref: APP/H1840/A/13/2199085 & APP/H1840/A/13/2199426).

22 Land off Dysart Road, Autumn Park, Grantham

SK/GRA/48

Reserved matters approval S05/1156 Outline planning permission S04/1610

24 24 24

0

This site has outline planning permission for 166 units, which was submitted in October 2004 and approved in May 2005. Reserved matters were submitted August 2005 and approved November 2005. The site is under the control of a national house builder, with construction underway. The remaining 24 units are expected to come forward within the five year plan period 2014/15 – 2018/19.

23

IMPRESS Canning Works, Springfield, Grantham

Reserved Matters Approval S07/0588


45 35 10

45

0

This site has reserved matters approval for 246 units, which was submitted in April 2007 and approved November 2007. Outline planning permission was sought in February 2005 and approved in March 2006. The site is under the control of a national house builder and it is expected the remaining 45 units will be completed in the five year period 2014/15 – 2018/19.






24

Springfield Park, Springfield Road, Grantham

Full planning permission S07/0017 Reserved matters approval S05/0185


33 33 33

0

The site has planning permission for 385 units. Construction is underway, with 351 complete.

Outline planning permission was sought for a mixed use development in September 2002 and approved April 2004. Reserved matters approval was sought in February 2005 and approved in July 2005 for 363 units. Full planning permission was sought in January 2007 and approved in April 2007 to provide 19 additional units. The site is under the control of a national house builder and the remaining 33 units are expected to be completed in the five year period 2014/15.

25 Land to rear of 45-59 Harrowby Lane, Grantham

Full planning permission S10/2106 – demolition of existing dwelling and garage and construction of entrance foyer and additional car parking.

12 12 12

0

The site has full planning permission for 13 units, sought January 2011 and approved May 2012 (LPA Ref: S10/2106). Application to discharge conditions was sought December 2012 and approved March 2013 (LPA Ref: S12/3130). The site is under the control of a regional house builder and construction is underway. It is expected all 12 units will come forward within the five year period 2014/15- 2018/19.

26 Harrison House, Grantham

SK/GRA/63 Full planning permission S13/1324

14 14 14 0 The site has full planning permission for the conversion of a vacant rest home to dentist’s surgery and 14 residential units. This application was submitted in June 2013 and approved September 2013. It is expected all 14 units will come forward within the period 2014/15 – 2018/19.

27 Elm Farm, Lilley Street, Long Bennington


4 4 0 The site has full planning permission for 21 units. The application was submitted in October 2010 and approved September 2011 (LPA Ref: S10/2176). The site is under the control of a regional house builder and it is expected all the remaining units will come forward within the five year period 2014/15 – 2018/19.

28

Land between Godsey Land and Towngate East, Market Deeping

SK/DEE/08A

Reserved matters approval S11/1050


102 60 42

102

0

The site has planning permission for 120 units. Outline approval was sought in April 2010 and approved in January 2011 (LPA Ref: S10/0934). Reserved matters approval was submitted in May 2011 and approved August 2011 (LPA Ref: S11/1050). The site is under the control of a national house builder and it is expected the remaining 102 units will be completed in the five year period 2014/15 – 2018/19.

29

Corner of Great Close/ Templars Way, South Witham

Full Planning permission S06/1626

1 1 1

0 The site has full planning permission for 11 units. The application was submitted in December 2006 and approved in February 2007. It is expected that all remaining units will come forward within the five year period 2014/15 – 2018/19.

30 Land to rear of Belvoir Close, Stamford

SK/STA/25 S06/0765

S13/0150

22

7

15

22

0

The site has planning permission for 22 units under separate permissions. Phase 1, being 15 units, which was approved under full planning application LPA Ref: S13/0150, submitted in February 2013 and approved September 2013. Construction is underway on Phase 1. Phase 2, being 7 units, was approved under full planning permission LPA Ref: S13/2586, submitted December 2013 and approved February 2014. Discharge of conditions in relation to Phase 1 were submitted in May 2014 and approved July 2014 (LPA Ref: S14/0404). The site is under the control of a national house builder and it is expected all 22 units will come forward in the five year period 2014/15 – 2018/19.






31

Former Welland Motor Factory Site, North Street, Stamford


13 13 13

0

The site has full planning permission for 13 units, submitted in April 2010 and approved July 2010. Conditions have been discharged, most recently (LPA Ref: S13/1806) to discharge conditions 4, 5 & 10 were submitted July 2013 and approved June 2014. It is unclear who the site is under the control of, however it is expected all 13 units could be delivered in the five year period 2014/15 – 2018/19.

32 Mears Motors, Thurlby



14

14

14

0

The site has reserved matters approval for 14 units, which was submitted in June 2012 and approved October 2012 (LPA Ref: S12/1483). Outline planning permission was sought in April 2009 and approved July 2009 (LPA Ref: S09/0420). Application S13/2261 to amend access arrangements was sought in August 2013 and approved August 2014. Application S13/3141 to vary internal and external features was sought in November 2013 and August 2014. Application S13/3349 to discharge conditions was sought in December 2013 and approved August 2014. The site is under the control of a national house builder and it is expected all 14 units will come forward within the five year period 2014/15 – 2018/19.

Deliverable Large Sites with Planning Permission

33 Chesham Drive, Baston

SK/BAS/02

Full planning permission S13/1124 Discharge of Conditions S13/3351

49 20 29 49

0

The site has full planning permission for 49 units for occupiers over 55, sought April 2013 and approved July 2013. Discharge of conditions sought February 2014 and approved June 14. The site is under the control of a national house builder and it is expected all 49 units will come forward within the period 2014/15 – 2018/19.

34

Wherrys Yard, South Road, Phase II, Bourne

Application to modify unilateral undertaking S14/1424


46

46

46

0

The site has full planning permission for 46 units (LPA Ref: S11/1374). The site is under the control of a national house builder. The planning application was made in June 2011 and refused October 2011, but granted on appeal by the Secretary of State in June 2012 (PINS Ref: APP/E2530/A/12/2168416). In May 2014 an application to modify the unilateral undertaking to not provide affordable homes was made (LPA Ref: S14/1424). This has yet to be determined and casts significant doubts over the viability of the development in its current form. However, 46 dwellings are expected to come forward in the five year period 2014/15 – 2018/19.

35

Grantham Station Approach, Grantham

Outline planning approval S11/2511

72 0

72

The site has outline planning permission for the redevelopment of the Station Approach Area, including demolition of existing buildings, construction of offices, hotel, retail and 72 residential units. A variation was made in July 2012 and approved September 2012 to vary floor areas of the business area and hotel (LPA Ref: S12/1720). Reserved Matters Approval for the Business Incubation Centre was submitted in September 2012 and approved October 2012 (LPA Ref: S12/2249).

No Reserved Matters approval has been sought in relation to the residential element of the proposal, however the Grantham Growth Point indicate on their website that the site is suitable for 62 units, rather than 72. Assuming reserved matters were to be sought and approved for the residential development, and all applicable conditions would need to be discharged before construction could commence.

36

Springfield Park, Caunt Road, Grantham

Reserved matters approval

S14/0471


62

20

35

6

61

1

The site has reserved matters approval for 61 units, which was submitted in February 2014 and approved June 2014 (LPA Ref: S14/0471). This is a reduction of 1 unit from the outline planning approval, sought in May 2010 and approved March 2011 (LPA Ref: S10/1038). Assuming conditions are discharged in 2014/15, development could be expected to commence 2015/16. It is expected all 61 units will come forward in the period 2014/15 – 2018/19.






37

Barrack Gardens / Beacon Land Allotments, Grantham



55

20

35

55

0

Outline planning approval was sought for 43 units in January 2008 (LPA Ref: S08/0013 and approved by the Secretary of State in August 2009 (PINS Ref: APP/E2530/A/09/2101377). In February 2012 outline planning permission was sought for a revised scheme of 55 units and was approved in November 2013 (LPA Ref: S12/0484). Reserved matters were sought in January 2013 and approved May 2014 (LPA Ref: S13/3292). Discharge of conditions were sought in November 2013 and approved May 2014 (LPA Ref: S13/3250). The site is under the control of a regional house builder and it is expected all 55 units will come forward in the period 2014/15 – 2018/19.

38 Land at Main Road, Long Bennington


35 20 15 35

0

The site has outline planning permission for 35 units, submitted in August 2011 and approved July 2013. Reserved matters approval has yet to be sought and the site is currently marketed for sale. The outline planning permission includes conditions requiring archaeological and ecological investigations, which may delay development. If reserved matters were to be sought and approved and conditions discharged in 2015/16 it is expected construction could commence in 2016/17 at the earliest. It is expected all 35 units could come forward in the five year period 2013/14 - 2017/18.

39

Land behind Tesco off Godseys Lane, Market Deeping

SK/DEE/27

Reserved matters application S14/1551 Outline planning permission S13/2802

85 20 35 30 85

0

The site has outline planning permission for 85 units. The application was submitted in November 2011 and approved February 2013 (LPA Ref: S13/2802). The reserved matters application (LPA Ref: S14/1551) was submitted in June 2014 and approved September 2014. The site is under the control of a national house builder and it is expected all 85 units will come forward in the five year period 2014/15 – 2018/19.

40 Coronation Villas, Stamford

SK/STA/30 Outline planning permission S11/2283

20 20 20

0

The site has outline planning permission for 20 units, all of which are affordable housing (LPA Ref: S11/2283), submitted September 2011 and approved December 2012. The applicant was an investor and an application for reserved matters has yet to come forward. The outline planning permission contains conditions which require ecological and contamination investigations which may delay development of the site. It is expected all 20 units will come forward in the five year period 2014/15 – 2018/19.

41 2A Radcliffe Road, Stamford


10 10 10

0

The site has full planning permission for 10 units, sought March 2012 and approved April 2013. A non-material amendment was sought and approved in March 2014 (LPA Ref: S14/0525). An application to discharge conditions has been sought, October 2014 and is yet to be determined (LPA Ref: S14/2904) and a condition requiring contamination investigation may delay development of the site. The site is under the control of a national house builder and it is expected all 10 units will come forward within the five year period 2014/15 – 2018/19.

42 Stamford AFC, Kettering Road, Stamford

SK/STA/10 Outline planning permission S11/2300

55 20 35 55

0

The site has outline planning permission for 55 units, sought September 2011 and approved December 2012 (LPA Ref: S11/2300). The outline planning permission contains conditions which require archaeological investigations as well as investigations into potential public highway and cycleway improvements. These conditions may delay the development coming forward, particularly if it is determined changes are required to the highways network. The use of the stadium was expected to cease September 2014. Reserved matters approval has yet to be sought. It is expected all 55 units will come forward in the five year period 2014/15 – 2018/19.






43

Land between Empingham Road and Kettering Road, Stamford

SK/STA/09

Application to vary outline planning permission S13/2771


215 30 35 65

150

The site has outline planning permission for a mixed use development including 400 units, sought in April 2012 and approved May 2013 (LPA Ref: S12/0864). An application to vary the outline planning permission to allow vehicle access points to be built during the development was sought in October 2013 and approved October 2014 (LPA Ref: S13/2771). Assuming reserved matters is approved and conditions discharged in 2016/17, construction commences in 2017/18, then It is expected that 65 units could come forward in the five year period 2014/15 – 2018/19. The site is under the control of a trust.

Sites with Resolution to Permit Subject to s106 Agreement

44

Old Hunt Stables, Main Street, Woolsthorpe by Belvoir


20 20 20

0

The site has full planning permission for 20 units. Application submitted in October 2013 and approved May 14 (LPA Ref: S13/1917). Assuming conditions discharged in 2015/16, construction could commence 2016/17. The site is under the control of a local property management company and it is expected all 20 units will be complete in the five year period 2014/15- 2018/19.

Identifiable Large Sites which Could Came Forward in the Next Five Years

45 12 West Street, Barkston

BKN14-12B

10

3

3

7

There have been 3 planning application submissions on the site. An outline application) for 2 units, submitted in February 2012 and refused February 2013 (LPA Ref: S12/0319). A full application for 3 units, sought Oct 13 approved Mar 14 (LPA Ref: S13/2761) and a full application for 1 unit, submitted in September 2014 and refused October 2014 (LPA Ref: S14/2484). The refusals are due to the sitting and access of the developments impacting on the conservation area. The SHLAA (2014) identifies that the development would require access to the site through third party land, this in addition to the impact on the conservation area means it is unlikely that 7 of the 10 units will be developed in the five year period 2014/15 - 2018/19.

46 Grimer’s transport, Station Road

BIL14-113

Full planning application S14/3010

Full application for change of use S14/0927

23 23 23

0

The site has had two planning applications submitted on it by an independent property management company. A full application for 23 units, submitted in April 2014 is yet to be determined (LPA Ref: S14/0927) and a full application for change of use, sought November 2014 that is also yet to be determined (LPA Ref: S14/3010). The site is identified as an employment site in the Core Strategy, although application S14/0927 establishes a segment of the site as being redundant and suitable for residential use. Application S14/3010 stipulates an agreement between parties to retain the site as B8 use for 36 months before redevelopment for residential. Given the above it is unlikely the site will be developed for residential purposes until the end of the five year period 2014/15 – 2018/19 at the earliest.

47

Land at Southfields, Business Park, Bourne

BOU14-190

Refused full planning application S14/1684

23 0

23

The site is identified as an employment site in the Core Strategy. A full application has been submitted for the site for 23 units, which was submitted in June 2014 and refused November 2014 (LPA Ref: S14/1684). The reasons for refusal are due to the development being contrary to Policy H1 of the Core Strategy, Policy SAPH1 of the Site Allocations Policy DPD, poor design and overdevelopment. Due to these policy constraints, it is unreasonable to expect any units to be developed on the site in the five year period 2014/15 – 2018/19.






48 West of Southfields, Bourne

BOU14-145 15 0

15

The site is identified in the SHLAA 2014 for 15 units and is identified as having the following constraints; public footpath; adjacent SWI and potential wildlife interest. Vehicular access to the site will be provided by the adjacent development off Wherrys Yard (LPA Ref; S07/1323). It appears that no planning application has been made in relation to the site and its present use as wild area continues. The site has been considered available for development and policy compliant by the LPA, yet no planning application has been made, casting doubt over the likelihood of the site coming forward. The site is not controlled by a house builder and it is currently unmanaged and overgrown and has the potential for ecological interest.

49 Wherrys Land Phase 2, Bourne

BOU14-213 14 0

14

Wherrys Land Phase 1 has full planning permission for 14 units and 7 retail units under phase 1 of the development, submitted in December 2011 and approved March 2012 (LPA Ref: S11/2953). However, it appears that no planning application has been made in relation to Phase 2. The site is under the control of South Kesteven District Council; therefore, the Council will need to commission a buyer to develop the 14 units, which is likely to cause delays to development coming forward. There retail units on the ground floor are unoccupied therefore casting doubts over viability.

50

Former School, Launder Terrace, Grantham

GRA14-59 15 0

15

The site is identified in the SHLAA (2014) for 15 units and is currently in retail use, with no clear indication as to cease of lease. The LPA has considered the site available for development, yet no planning application has been made, casting doubt over the likelihood of the site coming forward. Based on the sites current operation and no planning application being submitted it is unlikely the site will be developed in the five year period 2014 – 2019.

51

ACC, Springfield Road, Grantham

GRA14-205 25 0

25

The site is identified in the SHLAA (2014) for 25 units and is identified as having potential contamination constraints which introduces viability concerns due to the possible remediation. Other potential constraints are amenity issues due to unneighbourly uses and loss of employment. The LPA has considered the site available for development, yet no planning application has been made, casting doubt over the likelihood of the site coming forward. The site is controlled by a company that are not recognised house builders. The site is vacant and open, but surrounded by a number of industrial uses including two high rise buildings, which cast shadow over the site. The adjoining industrial uses also generate potential noise and air pollution impacts to any nearby residential properties.

52 Old Maltings, Spring Garden, Grantham

GRA14-203 20 0

20

The site is identified in the SHLAA (2014) for 20 units and is identified as having the following constraints: possible contamination, local historic interest; noise issues and suitable to employment use. The site is surrounded by industrial and commercial units and appears no planning application has been sought, casting significant doubt over the likelihood of the site coming forward. Based on the above, it is unreasonable to expect any units to come forward on the site in the five year period 2014/15 – 2018/19.

53 Land north of Dysart Road, Grantham

GRA14-149 Full planning application S14/2953

190 35 35 35 35 140

50

The site has the submission of a full application for 227 units, sought Oct 14 and yet to be determined (LPA Ref: S14/2953). The site is identified in the SHLAA (2014) for 230 units, with the LPA expecting 190 units coming forward in the period of 2014 – 2019 and 40 units in the period 2019 – 2024. Assuming permission was approved in 2014/15, conditions could be discharged 2015/16 and construction could commence. The site is under the control of a local house builder and it is likely that 140 units will be developed in the five year period 2014 – 2019.






54 Land south of Barrowby Road, Grantham

GRA14-119

270

30

30

60

120

150

The site is identified in the SHLAA (2014) for 350 units, with the LPA expecting 270 units being developed in the period 2014 – 2019 and 80 units in the period 2019 – 2024. The site was also allocated in the GAAP for employment development but the plan was not adopted. The site is identified as Agricultural classification grade 1-2. There has been no planning application submitted. It is understood that the current owner of the land is development promotion company. It will therefore need to be sold to a house builder once and if outline planning permission is forthcoming, conditions will need to be discharged and reserved matters submitted. Therefore it is not likely that dwellings will be delivered before April 2016 at the earliest. In light of the linear nature of the site with only one access to the north. Therefore the first phase of the development is only likely to be suitable for one developer. With one developer on site in 2016/17 and 2017/18 completing 30 dwellings and then two developers in 2018/19 completing 60 dwellings. Completions rates in this area will be influenced by the market pressures from the North West Quadrant as well as Land North of Dysart Road, which has just been subject of a full planning application by a house builder.

55 Land east of Stamford Street

GRA14-140 10 0

10

The site is identified in the SHLAA (2014) for 10 units and is identified as having potential access constraint which may reduce the quantity of units. The LPA has considered the site available for development, yet no planning application has been made, casting doubt over the likelihood of the site coming forward. The site is constrained by the access off Stamford Road. The proposed access arrangement would present amenity issues to the adjoining properties particularly No 67 as the primary elevation and front door faces directly onto the proposed access. There could also be visibility issues caused by the proximity of the dwellings along Stamford Road to the highway. Stamford Street is also a one way road and any traffic entering the site of Springfield Road would need to navigate Victoria Street before turning back onto Springfield road, both of which have a thin carriageway with parked cars on both sides. This could be particularly difficult for construction traffic as well as providing amenity issues for existing residents. There is also a structure blocking the access which will need to be cleared. Site is not under the ownership of a house builder.

56 91-93 Westgate, Grantham

GRA14-204 10 0

10

The site is identified in the SHLAA (2014) for 10 units and is identified with the following constraints: No. 93 is a listed building and within a conservation area. The LPA has considered the site available for redevelopment and conversion, yet no planning application has been made, casting doubt over the likelihood of the site coming forward. The site is surrounded by retail uses and is not attractive for residential development as evidenced by the lapse of permission for 33 dwellings at land to the rear of 98 and 99 Westgate in a similar location.

57

Former Church Hill (High) School, Grantham

GRA14-239 Full planning application S14/2837

44 20 24 44

0

The site is identified in the SHLAA (2014) for 44 units. A full planning application for 44 units was sought October 2014 and is yet to be determined (LPA Ref: S14/2837). The site is predominately surrounded by residential dwellings and is under the control of a regional housing association. Assuming the application is approved 2014/15, conditions could be discharged 2015/16 and construction could commence 2015/16/ It is expected all 44 units will come forward within the five year period 2014/15- 2018/19.

58

The Old Tannery, Earlsfield Lane, Grantham

SK/GRA/44

Lapsed outline planning permission

S06/0965

20

0

20

There is a lapsed outline planning permission associated within the site for 20 units, submitted July 2006 and approved September 2006 (LPA Ref: S06/0965). The site has previously been unsuccessfully marketed for sale. It is unlikely the site will be developed in the five year period 2014/15 – 2018/19.






59 Former Gravel Works, Stowe Road, Langtoft

LAN14-72

LAN14-74 25 0

25

The site is identified in the SHLAA (2014) for 25 units and is identified with the following constraints; Contrary to Policy SAP H1, Naturally regenerated greenfield site, possible contamination and access to the site. The LPA has considered the site available for development, yet no planning application has been made, casting significant doubt over the likelihood of the site coming forward. Given the above, it is unlikely any units could be developed in the five year period 2014/15 – 2018/19.

60 Alma Farm, Long Bennington

LON14-58 15 0

15

The site is identified in the SHLAA (2014) for 15 units and is located adjacent a listed building. The SHLAA identifies the current land use as farm which introduces uncertainty over the likelihood of the site coming forward as residential development. The LPA has considered the site available for development, yet no planning application has been made, casting significant doubt over the likelihood of the site coming forward. Based on the above, it is unlikely any units could be developed in the five year period 2014/15 – 2018/19.

61

Land rear of the Royal Oak PH, Main Street, Long Bennington

LON14-195 10 0

10

The site is identified in the SHLAA 2014 for 10 units with part of the site suitable for development as the reminder is contrary to policy SAP H1. The LPA has considered the site available for development, yet no planning application has been made, casting doubt over the likelihood of the site coming forward. There are access issues with bringing the site forward and it is not controlled by a house builder.

62 East of Cherryholt Road, Stamford

STA14-108 25 0

25

The site is identified in the SHLAA (2014) for 25 units with part of the site is suitable for development as the reminder of the site is within a flood zone 3 area and has pylons and low voltage power lines. Access is also considered a constraint as it would likely go through the flood zone and would also require the relocation of the pylons. This could cause significant delays and may not be feasible. The alternative access route would require access through third party land which would also lead to significant delays. The LPA has considered the site available for development, yet no planning application has been made, casting significant doubt over the likelihood of the site coming forward. Based on the above constraints and that no application has come forward it is unlikely any units could be developed in the five year period 2014/15 – 2018/19.

63

Land at the Agricultural Engineers

on Barnack Road, Stamford

Planning application S14/0082

37 0

37

The site is allocated in the 1995 Local Plan for 20 units. An application for full planning permission for the demolition of the existing building and a 37 unit retirement home (C2) was submitted Jan 14 and has yet to be determined. Assuming this application is approved 2014/15, conditions could be discharged 2015/16 and construction commence 2016/17. The site is under the control of a national retirement home developer and it is expected all 37 units will come forward in the five year period 2014/15 – 2018/19. However, the recent Secretary of State appeal decision at Droitwich Spa concluded that C2 use should not be included as dwellings in the context of land supply due to their “institutional form and occupational age.” (PINS Ref: APP/H1840/A/13/2199085 & APP/H1840/A/13/2199426).

The Council’s Capital Programme

64 Trent Road, Grantham

35 0

35

The LP expects 35 units to come forward under the Council’s Capital Programme. . It appears no planning application has been made in relation to the site, therefore it is unlikely any units will come forward in the five year period 2014/15 – 2018/19.






65 Lincoln Road, Stamford

Discharge of conditions application S14/1647


20 20 20

0

The site has full planning permission for 20 units, submitted Nov 13 and approved Apr 14. An application to discharge conditions was submitted Jun 14 and has yet to be determined. It is expected all 20 units will come forward in the five year period 2014/15 – 2018/19.

Sites Allocated in Emerging Plans Which Could Be Brought Forward to Provide Buffer

66 Land south of Uffington Road, Stamford

STM1c 50 0

50

The site is identified in the Site Allocation and Policies DPD for delivery 2016-2021. The LPA considers 50 units could be brought forward to provide a 5% buffer. It appears that no planning application has been made in relation to the site. The site is currently occupied by a number of businesses and is potentially contaminated. Given the existing uses on site, the potential for contamination, and that no applications have come forward for the site, it is unlikely any units will be provided in the five year period 2014/15 – 2018/19.

67

Land West of Linchfield Road & North of Cowslip Drive, Market Deeping

DE1c 100 30 30 60

40

The site is identified in the Site Allocation and Policies DPD for delivery 2021-2026. The LPA considers 100 units could be brought forward. It appears that no planning application has been made in relation to the site. If an application were to come forward in 2015/16, this would need to be approved, along with reserved matters and discharge of conditions. Furthermore a detailed Traffic Assessment will be required to support any application as the Linchfield Road/Horsegate/Park Road junction is at capacity and highway and junction improvements are likely to be required. If an application were to come forward in 2015/16, this would need to be approved, along with conditions discharged and possibly reserved matters approved. Any units could only come forward later in the five year period 2017/18 – 2018/19.

68

Land off Swinstead Road, Corby Glen

LSC1c 30 30 30

0

The site is identified in the Site Allocation and Policies DPD for delivery 2016-2021. The LPA considers 30 units could be brought forward to provide a 5% buffer. It appears that no planning application has been made in relation to the site. If an application were to come forward in 2014/15, this would need to be approved, along with conditions discharged and possibly reserved matters. Any units could only come forward later in the five year period 2014/15 – 2018/19.

69

Land at Easthorpe Road, Great Gonerby

LSC1d 30 30 30

0

The site is identified in the Site Allocation and Policies DPD for delivery 2021-2026. The LPA considers 30 units could be brought forward to provide a 5% buffer. It appears that no planning application has been made in relation to the site. If an application were to come forward in 2014/15, this would need to be approved, along with conditions discharged and possibly reserved matters. Any units could only come forward later in the five year period 2014/15 – 2018/19.

4,368 Total 3,046 1,303

For and on behalf of

Alison Homes and Others

Report on the Objectively Assessed Need for Housing For the emerging Local Plan for South Kesteven

on behalf of Alison Homes and Others

Prepared by

Roland G Bolton Strategic Planning Research Unit

DLP Planning Limited

July 2015

Report on the Objectively Assessed Need for Housing


Prepared By:

Roland Bolton BSc (Hons) MTRPI Senior Director

Approved by:

Roland Bolton BSc (Hons) MTRPI Senior Director

Date:

July 2015 Strategic Planning & Research Unit Ground Floor V1 – Velocity Tenter Street Sheffield S1 4BY

4 Abbey Court Fraser Road Priory Business Park Bedford MK44 3WH

Tel: 01142 289190 Tel: 01234 832740 Fax: 01142 721947 Fax: 01234 831 266

DLP Consulting Group disclaims any responsibility to the client and others in respect of matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence. This

report is confidential to the client and DLP Planning Limited accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies

upon the report at their own risk.



Contents Page 0.0 Executive Summary ..................................................................................................... 5 1.0 Introduction .................................................................................................................. 8

Purpose 8 The Chelmer Model 8

2.0 National Policy ........................................................................................................... 10 Legislation 10 National Planning Policy Framework 10 The Approach to Objectively Assessed Need in the Framework 10 The National Planning Policy Guidance 11 The importance of considering the need to support economic growth as part of the Objective Assessment of Housing Need 14 The importance of the Objective Assessment of Need in the determination of planning applications and appeals 15 Conclusion on Approach to the Objectively Assessed Need for Housing 18

3.0 The Development Plan .............................................................................................. 20 South Kesteven Development Plan 20 The revoked East Midlands RSS 20 Core Strategy 20 The withdrawn Grantham Area Action Plan (GAAP) 20 Sites and Allocations DPD 21 The Peterborough Sub-Regional Strategic Housing Market Assessment (March 2014) 22

4.0 Review of demographic evidence on the housing requirement for South Kesteven ... 26 “Geography of Housing Market Areas” (DCLG 2010) 26 The Sub National Population Projections (SNPP) 27 The Sub National Household Projections (2012) 29 The 2012 Household Representation Rates 29

5.0 Indictors of Market Demand ....................................................................................... 32 Employment growth 32 South Kesteven Employment Land Capacity Study 32 The Greater Lincolnshire LEP Economic Plan 2014 33 The Peterborough Sub-Regional Strategic Housing Market Assessment (March 2014) 34

6.0 House prices and affordability .................................................................................... 36 Full Objectively Assessed Need for Affordable Housing 38 Overall conclusion on evidence of demand 40

7.0 The Objectively Assessed Need for Housing ............................................................. 41 The approach to the Objectively Assessed Need for housing 41 The two stages to determining the Objectively Assessed Need for Housing 42 The Chelmer model 42 The Evidence base 42 Commentary on output of modelled scenarios including comparison with the 2012 DCLG Sub National Household Projections 53 Conclusion on Objectively Assessed Need for Housing from the Chelmer Model 58

8.0 Conclusions ............................................................................................................... 60 Appendix 1: Glossary ........................................................................................................... 62



Appendix 2: The approach to be taken to define a housing requirement in determining a planning application in the absence of an up to date development plan ..................... 63

Appendix 3: The approach to Objectively Assessed Need for housing being adopted in development plan examinations ................................................................................. 66 High Court decision: Gallagher Homes Limited - And - Solihull Metropolitan Borough Council 70

Report on the Objectively Assessed Need for Housing For South Kesteven District Council

Roland G Bolton

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0.0 EXECUTIVE SUMMARY

0.1 This report has been produced by the Strategic Planning and Research Unit (SPRU) of DLP Planning Ltd and sets out the approach to calculating the housing requirement to use as the basis for the future level of housing provision in the emerging local plan.

0.2 This work has been undertaken using the well respected and recognised Chelmer Model and the 2012 Sub National Population Projections (SNPP). The base assumptions are comparable to the recently published 2012 Household Projections and as such represent a sound basis on which to consider the future housing requirements for the local plan area.

0.3 This independent modelling concluded that the Objectively Assessed Need for housing in the District, taking into account the requirement to integrate employment and housing strategies (National Planning Policy Framework (The Framework) Paragraph 158), is likely to be some 16,785 dwellings (839 dwellings a year to 2031). This is higher than the Strategic Housing Market Assessment (SHMA) assessment of the same level of employment growth of 783 dwellings a year to 2031 the difference between the two projections being due to assumptions regarding headship rates and economic activity rates.

0.4 Both these requirements are higher than the levels in the now revoked Regional Strategy Policy (RSS) 13a which required 680 dwellings a year (13,600 for 2006 to 2026), which while responding to the growth agenda which sought to strengthen the role of Grantham, was nevertheless based on what is now considerably outdated projections (2004).

0.5 These most recent projections by SPRU and the 2014 SHMA are based upon the economic aspirations as suggested by the Economic Strategy and key investment proposals. These figures are based upon the ‘Aspirational’ Economic Scenario from the SHMA which suggests 20% uplift in employment growth on a year-on-year basis to 2036. At 10,440 additional jobs in the period to 2031, this is below past rates of job growth for the District.

0.6 This approach is supported by the Strategic Economic Plan for the LEP which seeks to achieve an additional 13,000 new jobs by 2030 within the wider LEP area.

0.7 While these economic based housing figures are higher than the recommended level of dwelling provision in the SHMA (paragraph 10.25) of between 660 and 710 for the period to 2036. It is important to note that the SHMA projections model a higher level of need in the first 10 – 15 years the plan period to support economic growth where there is a modelled need in excess of at 898 dwellings a year to meet the economic growth aspirations. This need reduces substantially in the later parts of the plan period.

0.8 The SHMA itself is based on older population and household formation data and as such care is required in considering its usefulness in the future planning of the District or in reaching decisions on planning applications.

0.9 The development plan comprises the adopted Core Strategy (5th July 2010); Policy H1 of which conforms to the RSS requirement of 13,600 dwellings (680 per year) for the period 2006 to 2026. The Council adopted its Site Allocations and Policies Development Plan Document (DPD) in April 2014; this was again in accordance with the Core Strategy and RSS.


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0.10 In these circumstances were plans are based upon the RSS and evidence that has been superseded both the National Planning Practice Guidance (NPPG) and by the Hunston High Court decisions (Appendix 2), would require an assessment of the five year supply to be based upon an up to date Objectively Assessed Need for housing based upon the most up-to-date evidence. Any other approach would simply undermine the Government’s objective of achieving a step change in housing supply based upon up-to-date development plans.

0.11 The most up-to-date population projections are the 2012 Sub National Population Projections (SNPP) which takes account of the 2011 census. These of course take into account the impact of the housing crisis and recession upon migration. Likewise the most recent Household Representation Rates (HRR) are the 2012 household Projections and these model the impact of the housing shortfall and the recession in terms of the ability of households to form.

0.12 In accordance with the NPPG these national based projections form the starting point for the analysis of the Objectively Assessed Need. The Chelmer Model has been used to model both the demographic led housing requirement as well as the employment led requirement. In accordance with the NPPG as well as decisions by inspectors, including the Inspector for the Vale of Aylesbury Plan and South Worcestershire, the modelling of the dwelling requirement to meet the employment requirements (while maintaining existing patterns of commuting), is the “second step” in establishing the Objectively Assessed Need for housing. This work would suggest that the final Objectively Assessed Need, taking into account the future range of employment growth and maintaining existing patterns of commuting, would be between 781 and 839 dwellings a year for the South Kesteven District.

0.13 Lastly we have also considered the level of housing required to deliver the full assessment of affordable housing need in order to reflect the Warrington Judgement. This requires a slighter higher level of provision than is being proposed above however given the assumptions in arriving at this assessment we consider the employment based figure to be more reliable.

0.14 All of this evidence will need to be considered as part of the Examination of the Local Plan, but as the NPPG (Paragraph: 030 Reference ID: 3-030-20140306) and the Hunston Properties judgement from the High Court (as confirmed in the Court of Appeal) (Appendix 2) suggests, in the absence of an adopted Local Plan, Inspectors need to have an understanding of full Objectively Assessed Need, when faced with considering the merits of housing proposals. What the results of this report demonstrate is that the demographic based projections are unlikely to be sufficient to address the Objectively Assessed Need for housing for South Kesteven District Council and the likely requirement taking into account the economic strategy, is in the order of 781 to 839 dwellings a year to 2031. The lower of these two figures is that recommended by the SHMA for this period to support the Council’s growth aspirations for the period to 2031.

In the context of considering the five year land supply one should also consider the evidence relating to the period under consideration, in this case 2011 to 2021 or the context of the extant plan (to 2026). The requirement for the last five years and the next five years in the context of calculating the five year land supply, then the housing requirement from the SHMA compatible with the Council’s growth aspirations would be 994 dwellings a year. The requirement for the longer period of the development


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plan would be 898 dwellings a year. Our evidence suggests that this would result in a requirement of 783 to 825 dwellings (10 year and 15 year).The utilisation of average annual housing requirement figures, extended to 2036 for the purposes of local plan preparation, would unreasonably reduce the requirement in the early part of the plan period to that which was substantially lower than what is required to support the required economic growth, and as such would not be compatible with the Framework (paragraph 14, 17 19, 21 and 158).


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1.0 INTRODUCTION

Purpose

1.1 The purpose of this report is to consider the appropriate housing requirement for the future level of housing provision in the emerging local plan taking into account guidance, good practice including recent inspector’s reports on examination and High Court judgements.

The Chelmer Model

1.2 The Chelmer Model was developed by Professor David King Associate Dean in the Faculty of Science and Technology at Anglia Ruskin University, and since 1986 has been used widely by regional and local government bodies and by planning consultants working for the development industry. Professor King was also instrumental in developing government projections of future numbers of households and was lead advisor to the Department for Communities and Local Government and the Office for National Statistics.

1.3 The Chelmer Model is therefore a variant of the variants of the official government projection methodology developed by Professor King (page 39 Strategic Housing Market Assessments – Practice Guidance).

1.4 Professor King developed the model as there was at the time, a lack of tools for strategic planning in the UK. The purpose of the model was that it should encourage collaboration and debate on the mechanics of modelling and particularly on the implications of the projections. As a result, debate at many planning inquiries became focused not on alternative methodologies but on future migration patterns and the relationship between housing markets – hence saving hours of debate and consequential costs.

1.5 The model has been used extensively and Robin Edwards (ex Hampshire CC) is quoted as saying:

“At Hampshire County Council we made great use of the Chelmer Model which I regarded as head and shoulders above other available forecasting models. I firmly believe the Population and Housing Research Group made a massive contribution to improving the quality of local authority demographic work. (Planning 26th February 2012)”

1.6 More recently, use of the Chelmer Model has been accepted by the Planning Inspectorate in appeals:

a. APP/J3720/A/10/2139071 regarding Land South of Kipling Road, Stratford-upon-Avon: the Planning Inspector described the Chelmer Model as:

“A reliable and robust forecasting mechanism employed by many local authorities”.

b. APP/H1840/A/12/2171339: regarding Station Road, Honeybourne, Worcestershire the Planning Inspector stated in determining the 5 year land supply:

“More up to date information is available in the CLG 2008 projections and the 2010 population figures adjusted using the Chelmer model is now available and relevant.”


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Features of the Chelmer model

1.7 Key features of the model include:

a. provides projections of population, housing numbers, household composition and labour supply

b. identifies household numbers disaggregated by type (e.g. single, married etc.)

c. allows for the running of 'what-if' scenarios

d. operates at different spatial levels; region, county, unitary authority, district

e. projections can be migration-led, housing-led or population-led

f. user-friendly software application to facilitate in-house analysis providing a range of summary/detailed results tables

Broad structure of the Chelmer model

1.8 The model projects the change in the population between two dates by calculating births, deaths, out-migrants and in-migrants. The projection of private households is made from the private household population through assumptions for age/gender-specific headship rates. The implied increase for the number of dwellings is then derived from assumptions for rates of sharing dwellings by multiple households and for vacancy rates.

1.9 It is possible to reverse the direction of causation described above to consider the impact that a particular profile for future house building in an area would have on the size and character of the population. In this case the population growth and migration assumptions are derived from the assumed capacity of an area to accommodate dwellings.


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2.0 NATIONAL POLICY

Legislation

2.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 and Section 70(2) of the Town and Country Planning Act 1990 requires that applications for planning permission must be determined in accordance with the development plan, unless material considerations indicate otherwise.

National Planning Policy Framework

2.2 The National Planning Policy Framework (Framework) is a material consideration in planning decisions (paragraph 3).

2.3 In summary, the Framework states that the presumption should be in favour of sustainable development where the development plan is absent, silent or relevant

policies are out‑of‑date; permission should be granted unless any adverse impacts of

doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole; or specific policies in the Framework indicate development should be restricted.

2.4 The Framework requires that;

a. planning should proactively drive and support sustainable economic development to deliver the homes that the country needs. The Framework requires that every effort should be made, objectively, to identify and then meet the housing needs of an area and take account of market signals (such as land prices and housing affordability), setting out a clear strategy for allocating sufficient land which is suitable for development in the local area, taking account of these needs (paragraph 17);

b. local authorities should significantly boost the supply of housing (paragraph 47);

c. housing applications should be considered in the context of the presumption in favour of sustainable development and that policies regarding the supply of housing should not be considered up-to-date if the local planning authority cannot demonstrate a five-year supply of deliverable housing sites (paragraph 49);

d. the evidence base for the objective assessment of housing needs should be adequate, up-to-date and relevant (paragraph 158) and include Strategic Housing Market Assessments (SHMA) for the whole of the housing market area taking into account household and population projections including migration and demographic change (paragraph 159); and the objectively assessed need for housing has to be determined prior to applying any constraints or engaging the Duty to Cooperate (Framework paragraphs 152 and 179).

The Approach to Objectively Assessed Need in the Framework

2.5 In determining the Objectively Assessed Need for housing, the Framework requires that this should be based upon a consideration of demographic projections and trends (paragraph 159 of the Framework) as well as meeting demand. The assessment also needs to consider the needs of the economy so that planning is not an impediment to sustainable growth (paragraph 19).


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2.6 Local planning authorities are required to ensure that their assessment of, and strategies for, housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals (paragraph 158 of Framework).

2.7 The Framework sets out a clear process for local authorities to follow to set a housing requirement for their local plan. The first is to produce a SHMA to assess the full needs for the Housing Market Area (paragraph 159) this should:

a. Meet projected needs taking account migration;

b. Assess needs for all types of housing; and

c. Provide the scale of supply to meet housing demand.

2.8 The Framework then sets out how to proceed from establishing this Objectively Assessed Housing Need to determine the housing requirement. This second part of the procedure consists of three stages:

a. To test alternative strategies to meet this need in full (Framework paragraph 152) including working with other authorities to meet these needs across local authority boundaries (paragraph 179 Framework);

b. Consideration of measures to mitigate negative impacts if these are unavoidable (Framework paragraph 152);

c. Consideration of compensatory measures where mitigation measures are not possible (Framework paragraph 152).

2.9 A fuller explanation of the interpretation of the Framework with regard to the Objective Assessment of the Need for Housing is set out in the National Planning Policy Guidance.

The National Planning Policy Guidance

2.10 In respect of the calculation of the five year housing land supply the Guidance states (Paragraph: 030 Reference ID: 3-030-20140306) that at the time of writing, the starting point for the five-year housing supply should be the housing requirement figures in up-to-date adopted Local Plans. It also states that considerable weight should be given to the housing requirement figures in adopted Local Plans.

2.11 The Guidance goes on to warn that evidence which dates back several years, such as that drawn from revoked Regional Strategies, may not adequately reflect current needs.

2.12 In such circumstances where evidence in Local Plans has become outdated and policies in emerging plans are not yet capable of carrying sufficient weight, then the Guidance suggests that the following should be considered:

a. Information provided in the latest full assessment of housing needs.

b. Where there is no robust recent assessment of full housing needs, the household projections published by the Department for Communities and Local Government (DCLG) should be used as the starting point.

2.13 In both cases the weight given to the above should take account of the fact that they have not been tested (which could evidence a different housing requirement to the projection, for example, because past events that affect the projection are unlikely to


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occur again or because of market signals) or moderated against relevant constraints (for example environmental or infrastructure).

2.14 The Guidance states that the definition of need requires the identification of the scale and mix of housing and should cater for the housing demand of the area, identifying the scale of housing supply necessary to meet that demand.

2.15 The assessment of development needs should be proportionate and include those future scenarios that could be reasonably expected to occur.

2.16 Plan makers should not apply constraints to the overall assessment of need, such as limitations imposed by the supply of land for new development, historic under performance, viability, infrastructure or environmental constraints.

2.17 Local planning authorities are required to assess their development needs working with the other local authorities in their relevant Housing Market Area or functional economic market area in line with the Duty to Cooperate.

2.18 Where local plans are at different stages of production, local planning authorities are required to co-ordinate future housing reviews so they take place at the same time.

2.19 The starting point for the Objective Assessment of Housing Need is the Household Projections published by the DCLG. These are trend based and do not predict the impact that future government policies, changing economic circumstances, or other factors, might have on demographic behaviour. As such the household projection-based estimate of housing need may require adjustment to reflect factors affecting local demography and household formation rates which are not captured in past trends. For example:

a. Household formation rates may have been suppressed historically by under-supply and worsening affordability of housing - the assessment will therefore need to reflect the consequences of past under delivery of housing.

b. Unmet housing need - evidence of the extent to which household formation rates are or have been constrained by supply will need to be taken into account.

2.20 Local needs assessments should be informed by the latest available information and a meaningful change in the housing situation should be considered in the context of the requirement for the local plans to be kept up-to-date.

2.21 At the time of writing the Guidance the most recent Household Projections were (and still are) the 2011-based Interim Household Projections, these only extend to 2021, so the Guidance states that plan makers will need to assess likely trends after this date.

2.22 The Guidance confirms that the Household Projections produced by the Department for Communities and Local Government are statistically robust and are based on nationally consistent assumptions but suggests that plan makers may consider sensitivity testing, specific to their local circumstances, based on alternative assumptions in relation to the underlying demographic projections and household formation rates. Such testing should take into account the most recent demographic evidence including the latest Office of National Statistics (ONS) population estimates.

2.23 In terms of population projections these are the 2012 SNPP, the dwelling requirement derived from these projections has been modelled using the Chelmer model.


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2.24 The Guidance states that changes from the DCLG projections are required to be clearly explained and justified on the basis of established sources of robust evidence.

2.25 Consideration must be given to whether the DCLG projections are appropriate on issues such as:

a. Migration levels;

b. Demographic structure that may be affected by local circumstances or policies;

c. Employment trends - In such circumstances where the supply of working age population that is economically active (labour force supply) is less than the projected job growth, plan makers will need to consider how the location of new housing or infrastructure development could help to address these problems.

d. Market signals - The housing need number suggested by household projections (the starting point) should be adjusted to reflect appropriate market signals, as well as other market indicators. Prices or rents rising faster than the national/local average may well indicate particular market undersupply relative to demand. Relevant signals may include the following:

i. Land Prices.

ii. House Prices - longer term changes may indicate an imbalance between the demand for and the supply of housing.

iii. Mix adjusted house prices (adjusted to allow for the different types of houses sold in each period) measure inflation in house prices.

iv. Rents - the Office for National Statistics publishes a monthly Private Rental Index.

v. Affordability - the Department for Communities and Local Government publishes quarterly the ratio of lower quartile house price to lower quartile earnings by local authority district.

vi. Rate of Development - if the historic rate of development shows that actual supply falls below planned supply, future supply should be increased to reflect the likelihood of under-delivery of a plan.

vii. Overcrowding - the number of households accepted as homeless and in temporary accommodation is published in the quarterly Statutory Homelessness release.

2.26 In respect of market signals, the Guidance states that plan makers should not attempt to estimate the precise impact of an increase in housing supply, but should increase planned supply by an amount that, on reasonable assumptions and consistent with principles of sustainable development, could be expected to improve affordability, and monitor the response of the market over the plan period.

2.27 In areas where an upward adjustment is required, plan makers should set this adjustment at a level that is reasonable. The more significant the affordability constraints (as reflected in rising prices and rents, and worsening affordability ratio) and the stronger other indicators of high demand (e.g. the differential between land prices), the larger the improvement in affordability needed and, therefore, the larger the additional supply response should be.


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2.28 Any cross-boundary migration assumptions, particularly where one area decides to assume a lower internal migration figure than the Housing Market Area figures suggest, will need to be agreed with the other relevant local planning authorities under the Duty to Cooperate. Failure to do so will mean that there would be an increase in unmet housing need.

The importance of considering the need to support economic growth as part of the Objective Assessment of Housing Need

2.29 Paragraph 158 requires the integration of economic and housing strategies and the Guidance above suggests that this should take the form of a comparison of the changes to working age population and employment growth.

2.30 This is an area which inspectors at examination have taken considerable interest in for example Mr Clewes at the South Worcestershire Plan Examination (Inspector’s Interim Conclusions on the Stage 1 Matters) criticised trend based demographic projection scenarios in paragraph 37 as follows:

“However, each of these scenarios is essentially trend-based and does not include the necessary additional step of factoring in the effect of future employment growth on in-migration”. (our emphasise)

2.31 A similar concern resulted in the Vale of Aylesbury Plan being found unsound with the Inspector stating in paragraph 37 and 42:

“Despite the doubts expressed by the Council in its statement and at the hearing sessions in relation to the implementation of existing commitments, the Plan is clearly based on a strategy of delivering some 16,000 additional jobs between 2011 and 2031. The Council’s evidence indicates that significantly more housing than that planned would be required to support this level of jobs growth. There is no substantive evidence that the jobs density or patterns of out-commuting are likely to change to the extent required to support the planned level of employment growth without the need for significantly more housing. In simple terms there is a clear and substantial mismatch between the level of housing and jobs planned

Taking all of the above into account, I consider that in relation to the overall provision for housing and jobs, the Plan has not been positively prepared, it is not justified or effective and it is not consistent with national policy. It is therefore not sound.”

2.32 At the Cherwell Core Strategy Examination the Inspector indicated that the submitted plan was unsound as it was not based upon an Objective Assessment of Need. In finding the amended plan sound the inspector stated in paragraph 46:

“This re-assessment has led to a net new housing requirement of 22,840 homes for the district, equivalent to an average of 1,140 units per year from 2011 to 2031 to meet local needs. It is based on the Council’s conclusions, supported by other relevant Councils, that the district’s sustainable development can realistically only be fully met through the very positive “Committed Economic Growth” scenario set out in the SHMA. As a policy decision by the Council over and above the numbers needed to meet population and demographic projections alone, this takes into account the present level of employment commitments in the district and nearby, the very positive prospects for the county’s economy, the relevant county and district Strategic Economic Plans, the Oxford/Oxfordshire City Deal (2014) and the objectives of the two Local Economic Partnerships involved.”


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2.33 The position is put succulently by the Inspector for the Cornwall Plan Examination in outlining his concerns regarding the soundness of the plan in his interim findings stated (paragraphs 3.2 and 3.27):

“The demographic projection is only a starting point and national policy and guidance requires consideration of a number of other matters, including whether any uplift is required in response to market signals or to meet in full affordable housing needs and to ensure alignment between the economic strategy and future workforce availability. …

Following the further work required by the Council in ensuring that the plan is delivering the economic strategy and clarification in relation to job expectations, the Council will need to demonstrate that there would be a suitable alignment between economic development, job and workforce growth and the housing requirement.”

2.34 The Inspector at the Examination of the Durham Plan found it unsound on the grounds of an over ambitious employment growth strategy but nevertheless suggested that an alternative employment led housing requirement might be suitable (paragraph 43).

The importance of the Objective Assessment of Need in the determination of planning applications and appeals

Hunston Properties Ltd vs Secretary Of State for Communities and Local Government & St Albans City and District Council

2.35 The first decision in this case (High Court of Justice Queen's Bench Division 5th September 2013) concerned the refusal of planning permission for a housing development in the Green Belt. The Judge is very clear on the approach that should be taken to the Objective Assessment of Housing Needs, which is of relevance in the interpretation of the Framework, both for development management decisions and development plans.

5.1 In paragraph 20 of the decision, the Judge finds that the reasoning of the Inspector in Planning Appeal APP/X1165/A/11/2165846 to be entirely convincing. The Inspector in that appeal is quoted in paragraph 47 of the decision:

"… constraints do not bear upon the actual need for dwellings … the stage at which growth constraints should be taken into account is when assessing how the identified need can be addressed …they cannot reasonably be used … simply to reduce the number of dwellings calculated as necessary to meet housing need."

2.36 In paragraph 30 the Judge states that the proper course in determining a housing requirement would be;

a. assessing need;

b. then identifying the unfulfilled need having regard to the supply of specific deliverable sites over the relevant period; and

c. then to decide on the policy implications of meeting this need.

2.37 In the second decision in the Court Of Appeal (Civil Division) on Appeal from the Queen’s Bench Division Administrative Court Judge Pelling QC found that:

a. An Inspector is not required to undertake some sort of local plan process as part of determining the appeal, so as to arrive at a constrained housing requirement figure (paragraph 26).


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b. The Inspector had been mistaken to use a figure for housing requirements below the full objectively assessed needs figure until such time as the Local Plan process came up with a constrained figure (paragraph 26).

c. Self-evidently, one of the considerations to be reflected in the decision on “very special circumstances” is likely to be the scale of the shortfall (paragraph 28).

The consideration of up-to-date evidence on housing needs: J S Bloor, Hallam Land Management and Secretary of State v Stratford on Avon District Council

2.38 Justice Hickinbottom has dismissed a s.288 challenge in the High Court of Justice to grant of planning permission on appeal by the Secretary of State for up to 800 dwellings, a mixed use local centre, highway and green infrastructure, and various associated works at land west of Shottery, a village to the west of Stratford-Upon-Avon. The s.288 challenge was brought by the Local Planning Authority; Stratford-Upon-Avon District Council.

2.39 The Secretary of State considered the results of an independent report, which used the 2008 Household Projections to produce three main projections, including one for 8,200 dwellings. While this lower projection was supported by Members of the Council, it was rejected by the Secretary of State in his decision on the appeal. The Secretary of State considered that a figure of 11,000 - 12,000 dwellings for the period 2008-2028 more closely accorded with the requirements of the Framework.

2.40 The Judge concluded for the purposes of responding to the appeal, the Secretary of State was required to assess unmet housing need, which required an assessment of housing requirements. On the basis of this evidence, the figure of 8,200 dwellings was considered not sufficiently evidence-based.

Cotswold District Council v Secretary of State and Hannick Homes and Development Limited

2.41 In the case of decisions of the Secretary of State heard by Mr Justice Lewis in respect of the ‘Tetbury’ appeals, planning permission was granted for housing development within an Area of Outstanding Natural Beauty in the Cotswolds (APP/F1610/A/12/2165778).

2.42 Here the Judge explained that: Paragraph 47 is directed towards the obligations of local planning authorities in preparing their development plans. However, the Structure Plan in the present case expired in 2011. In this case the Council had not adopted a Local Plan identifying its housing requirements for the next local plan period or the next five years. The Judge stated that in dealing with a planning application, the Council, and an Inspector or the Secretary of State on an appeal, will have to address the question of what the Council’s five year housing requirement is likely to be and whether the Council has significant supply of housing land to meet that requirement. This will be a material consideration in determining whether planning permission should be granted (paragraph 10).

Appeal decisions – Objectively Assessed Need

2.43 It is further noted that in a number of cases in which Inspectors have considered the Objectively Assessed Need for Housing, they have emphasised that such assessments not only take into account the demographic drivers of need, but also the economic drivers of need and demand (Land between Leasowes Road and Laurels


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Road, Offenham, Worcestershire, WR11 8RE (Appeal Ref: APP/H1840/A/13/2203924), four appeals at Broom Hill, Swanley, Kent (Appeal Ref: (APP/G2245/A/13/2195874, APP/G2245/A/13/2195875, APP/G2245/A/13/2197478 and APP/G2245/A/13/2197479), and Pulley Lane, Droitwich Spa decisions by the Secretary of State (APP/H1840/A/13/2199085 and APP/H1840/A/13/2199426)).

2.44 These recent decisions and the High Court decision confirm that substantial weight may be placed upon the most recent evidence of the Objectively Assessed Need for Housing and that assessments using recognised projection models such as Chelmer, and based upon up-to-date evidence that take into account changes to the economy and household representation rates, should be given significant weight in the determination of planning applications where there is no up-to-date Objective Assessment of Need.

The importance of meeting affordable housing needs

2.45 In the recent Judgement of Satnam Millennium Limited and Warrington Borough Council (Case No: CO/4055/2014), the question of compliance with policy was considered, including the required response to evidence of affordable housing needs. The Judge found that the Local Plan Core Strategy (Local Plan) for Warrington was not in compliance with the Framework for the following reasons:

‘(i) The assessed need for affordable housing was 477 dpa.

(ii) This assessed need was never expressed or included as part of the Objective Assessed Need (OAN).

(iii) Under the “Housing Requirements” section of the Report the Inspector does not deal with affordable housing. Paragraphs 102 – 104 set out above is under a section entitled “Other Housing Needs”. This is in the context of Policy SN2 which relates to the percentage of housing developments that should incorporate affordable housing.

(iv) Nor is there anything in Mr Bell’s statement which suggests that the proper exercise was undertaken. This exercise is:

(a) having identified the OAN for affordable housing, that should then be considered in the context of its likely delivery as a proportion of mixed market/affordable housing development; an increase in the total housing figures included in the local plan should be considered where it could help deliver the required number of affordable homes;

(b) the Local Plan should then meet the OAN for affordable housing, subject only to the constraints referred to in the Framework; paragraphs 14 and 47.’

The Minsters letter to the Planning Inspectorate (19th December 2014)

2.46 It is appropriate to consider the content of the Minister’s letter of the 19th December 2014 to the Planning Inspectorate, in which he states that Strategic Housing Market Assessments which are untested, should not automatically be seen as a proxy for a final housing requirement in Local Plans and that they do not immediately or in itself invalidate housing numbers in existing Local Plans.

2.47 In this letter the Minister is correctly drawing the Inspectors attention to the approach set out in the Guidance regarding the weight to be attached to assessments which have emerged since the adoption of the extant plan and referred up-to-date evidence. This does not mean that the weight to be attached to a plan should not be judged in


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the context of its conformity with the Framework (paragraph 215) and the degree to which it is up-to-date (paragraph 17, 158 and 159).

Conclusion on Approach to the Objectively Assessed Need for Housing

2.48 The SPRU would argue that the Framework does provide an appropriate background against which to approach the choice of assumptions as part of the Objective Assessment of need for housing. The following sets a clear framework in which to approach and take these decisions:

a. The objective is to provide a supply of housing to meet needs of both this and future generations (paragraph 7).

b. There is also the requirement to increase the opportunity for home ownership based upon not just current but also future demographic trends, market trends and the needs of different groups in the community (paragraph 50).

c. The planning system does everything it can to support sustainable economic growth. Planning should operate to encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system (paragraph 19).

d. Finally, the general approach is for plans to be positively prepared.

2.49 These principles should not be applied to the outcome of the projections but should inform the choice of assumptions made as part of the process of modelling the Objectively Assessed Need. The consequence of applying these principles to the modelling process are as follows:

a. Where there is a choice of reasonable alternatives regarding the future propensity of persons to form households, then the requirement to increase the opportunity for home ownership and plan positively requires one to choose the more favourable assumptions that would allow more, rather than fewer people to form their own households and achieve home ownership (Framework paragraphs 7 and 50).

b. Where there are a number of reasonable projections of future employment growth one should plan to accommodate the highest of these projections as failure to do so might actually contribute to these higher levels of growth not being achieved. In such circumstances the lower level of provision could be regarded as impeding sustainable economic growth and could be regarded as being inconsistent with Framework paragraph 19.

c. No constraints should be applied to the calculation of the overall assessment of need. It is acknowledged that these considerations will need to be addressed when bringing evidence bases together to identify specific policies within development plans (NPPG Paragraph: 004 Reference ID: 2a-004-20140306).

d. The final level of provision should be able to deliver the objectively assessed level of affordable housing in full.

e. As confirmed in the Hunston decisions, once an Objectively Assessed Need has been arrived at following these principles, then the housing requirement maybe set at less than the need if:


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i. Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole; or specific policies in the Framework indicate development should be restricted, and

ii. The Council has engaged the Duty to Cooperate (Framework paragraphs 178 to 181) so that these needs are met elsewhere so as to fulfil the core principle of the delivering the homes the Country needs (Framework paragraph 17).

2.50 This approach of applying the objectives of the Framework in the selection of the assumptions was supported by the Inspector at the South Worcestershire Plan Examination (Further Interim Findings paragraphs 59 and 60) who stated:

“I have taken into account the argument of DLP that (in summary), where there is a choice of reasonable alternative assumptions on, for example, future HRR trends or employment growth, guidance in the NPPF indicates that one should choose the highest reasonable assumption when modelling future housing need. Similar arguments were put by other participants who considered the SENS2 and SENS3 figures to be too low.”

2.51 As DLP point out, the NPPF seeks to promote sustainable economic growth and a sufficient supply of housing to meet the current and future needs of the whole community. In this regard its specific requirement in Local Plan preparation is for a full, objective assessment of likely housing need over the plan period.


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3.0 THE DEVELOPMENT PLAN

South Kesteven Development Plan

3.1 The South Kesteven Local Plan was adopted in April 1995 and covered the period up to 2001. Paragraph 2.17 of the Local Plan states that South Kesteven, allowing for those dwellings built since 1988, the provision is about 10,090 dwellings within the District between 1990 and 2001, in order to meet the housing requirements of the Structure Plan Alteration No.1 (917 per annum). The Local Plan and Structure Plan are out of date and have expired, therefore the housing targets within them have no relevance to the calculation of land supply.

The revoked East Midlands RSS

3.2 The evidence base for East Midlands Regional Spatial Strategy (RSS) housing policies dates from the 2004 based Household Projections. This evidence is out of date and it is no longer appropriate to place weight on these projections. The RSS housing requirement was 680 dwellings per annum.

Core Strategy

3.3 The South Kesteven Core Strategy was adopted on the 5th July 2010 and therefore predates the Framework and the Guidance.

3.4 Policy H1 of the Core Strategy states that new housing development in South Kesteven during the period 2006-2026 should be planned and phased to deliver the minimum level of housing development required by the Regional Plan; 13,600 dwellings (680 per annum).

3.5 As this was based upon the 2004 Household Projections it is, like the RSS, out of date.

The withdrawn Grantham Area Action Plan (GAAP)

3.6 The Grantham Area Action Plan was withdrawn on the 7th January 2013.

3.7 In response to the Inspector’s initial concerns the Council published and consulted on a number of Main Modifications to the GAAP in June 2012. These dealt with the matters of concern to the Inspector as well as changes to the DPD as a consequence of the publication of the Framework in March 2012. At this stage the Inspector made clear that the cumulative number of modifications could eventually amount to a re-write of the Plan, in which case a formal request for him to make Main Modifications would be inappropriate.

3.8 During the course of the hearings held between the 2nd and 11th October 2012, the Inspector identified a number of concerns and these were set out formally in his letter to the Council on the 31st October 2012. The Inspector’s three main concerns related to:

a. housing flexibility and delivery;

b. delivery of the sustainable urban extensions and other allocated sites; and

c. the site selection process.

3.9 The Inspector also raised concerns that if the delivery of housing were to stall in respect of the two sustainable urban extensions; the GAAP does not provide the mechanisms to provide suitably scaled alternative sites in the short-term to make good any shortfall.


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3.10 The Inspector concluded that even if the Council put forward Main Modifications to address the issues identified, they would be sufficient enough when coupled with the Main Modifications already proposed, to require the DPD to be re-written. This suggested to him that the most appropriate course of action was for the Council to withdraw the DPD to allow for the necessary changes to be made and to republish the Plan for consultation and submit the revised DPD for Examination.

3.11 In light of this recommendation the Council decided to withdraw the Plan.

Sites and Allocations DPD

3.12 The Council adopted its Site Allocations and Policies DPD in April 2014. The Council expects to commence a review of its Plan towards the end of 2015.

3.13 In terms of the evidence base for housing, paragraph 1.4.2 identifies the sole background report relating to overall need to be the 2008 Peterborough Sub Regional Strategic Housing Market Assessment (2008) (joint study for Peterborough City, South Holland District, South Kesteven District, Rutland County, Huntingdonshire District, Fenland District and East Northamptonshire Councils) (Updated 2010).

3.14 Objective 1 is to provide for at least 5,940 new homes across the District (excluding Grantham) up to 2026, it therefore neither relates to, nor proposes to meet in full, the Objectively Assessed Need of the District.

3.15 Table 1 (page 14) highlights that to meet or slightly exceed the RSS and Core Strategy requirement there will need to be a further 3,700 allocated in Grantham.

3.16 It is noted that issue 3 of the Inspector’s Report to the Sites and Allocations DPD does not discuss the appropriateness of using 2004 based evidence. This is in contrast to the Inspector at the more recent (2014) Doncaster Sites and Allocations Examination who concluded in respect of 2004 based RSS figures:

“19. In my view neither the adopted Core Strategy nor this DPD is NPPF-compliant. Contrary to paragraph 159 of the NPPF, neither document is supported by an objective assessment of the need for housing. The evidence base which supports the Council’s housing requirement is out-dated and has not been systematically re-appraised. No review focusing on the specific issues involved has taken place nor has the evidence been supplemented by up-to-date, robust local evidence as is required by NPPF paragraph 218. No review is imminent to address these deficiencies. Whilst a SCR-wide SHMA would produce definitive answers to the housing market area/housing needs issues, no such assessment is in prospect in the near future.

20. The Council considers that the DPD should be prepared in-line with the adopted Core Strategy requirements, the 2 documents together forming the Local Plan for the borough. However, in 2 recent similar cases - Gladman Homes v Wokingham Borough Council and Gallagher Homes Ltd and Lioncourt Homes Ltd v Solihull Metropolitan Borough Council - a Council’s decision to adopt a Local Plan has been challenged in the Courts partly on the basis that the documents failed to comply with the NPPF in that they were not based on an up-to-date objective assessment of housing need. The former case is yet to be heard and I understand that the Council in the latter case is submitting an application to appeal to the Court of Appeal following a refusal of permission to appeal in the High Court. Nonetheless, in these circumstances it may be that, even if I considered that the Council’s approach was sound, this may not be accepted by the Courts.”


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3.17 It is now known that the Solihull challenge has been upheld on ground 1 in which Mr

Justice Hickinbottom concludes:

“101. For those reasons, I do not consider that the Inspector’s approach to the policy requirements of the NPPF in relation to housing provision was correct or lawful. As a result, he failed to comply with the relevant procedural requirements; and the SLP with modifications, which he endorsed and the Council adopted, is not sound because it is not based on a strategy which seeks to meet objectively assessed development requirements nor is it consistent with the NPPF.”

3.18 In the Wokingham case (2-014 EWC2320 (admin)) the court found that it was lawful to produce a sites and allocations document in accordance with a plan which was not based on an Objective Assessment of Need (paragraphs 44 and 45) and that in this case the Inspector was careful to state that in determining the soundness of this subsidiary plan he was not considering the issue of Objectively Assessed Need. (paragraphs 13 to 14).

3.19 In both cases it is clear that an up-to-date local plan or core strategy would have to address the issue of the Objectively Assessed Need for housing and that plans that do not including subsidiary plans such as the South Kesteven Sites and Allocations DPD may only be attributed weight in terms of their compliance with paragraph 215 of the Framework. As the Hunston and other decisions considered above illustrates that plans not based upon the Objective Assessment of Housing are not compliant with the Framework and may only be given very limited weight by decision makers.

3.20 What is clear is that the Core Strategy and the Sites and Allocations DPD for South Kesteven are both out of date, and as such paragraph 14 of the Framework applies and the presumption in favour of sustainable development should be applied.

The Peterborough Sub-Regional Strategic Housing Market Assessment (March 2014)

3.21 This report concludes that there is a Peterborough Sub-Regional Housing Market Area (HMA) and the best fit of local authority boundaries to this HMA for the purposes of strategic planning includes Peterborough, South Holland, South Kesteven and Rutland.

3.22 The report considers the demographic requirements as well as adjustments to be made in response to market pressure, meeting affordable housing need and the needs of the economy. In respect of HMA the report’s findings are as follows:

a. There is no need to adjust headship rates to address affordability or market demand

b. While there would need to be an increase in the rate of delivery from 2,462 dwellings a year to 3,000 dwellings a year across the HMA to provide the required 1,350 affordable homes, the consultants state that this higher rate of delivery is unlikely to be achieved (paragraph 10.50). This is described as a significant quantitative shortfall in affordable housing which could justify an uplift in housing requirements compared to the demographic projections (paragraphs 10.16 and 10.17). This shortfall it is suggested might be reduced by setting a different threshold for affordability and the use of the Private Rented sector as an alternative to affordable housing provision. The report concludes that there is no need to increase provision to deliver the required


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number of affordable homes providing the Private Rented sector continues to meet this need (paragraph 10.18).

c. While the report states that there is no requirement to increase the overall level of housing to meet economic growth based on 2013 economic projections there may be a case for considering the redistribution (paragraph 10.10). Critically the assessment does not seek to align the employment housing and other uses as required by the Framework in paragraph 158 (paragraph 10.21)

3.23 In respect of South Kesteven the report’s findings draws together the evidence to suggest that there is a housing need of between 660 – 710 dwellings a year between 2011 and 2036. In particular the report states:

a. There is some justification to increase the dwelling requirement based upon improved household formation rates so as to respond to market demand

b. The affordable housing needs also to support a higher level of provision to the demographic based projection.

c. The higher end of the range would support both affordable housing delivery and stronger economic growth (paragraph 10.27)

The appropriate time period to be considered in determining a planning application

3.24 The SHMA averages are over the long term from 2011 to 2036.

3.25 The actual need for housing fluctuates over this period as the impact of the aging population, migration and economic growth all interact. The table on the next page illustrates that for all of the projections the housing need decreases after 2021.

3.26 The projection which fully reflects the requirements of the Framework is the economic growth - PROJ 4 (Experian job led with uplift). This produces a requirement to 2036 of an average of 710 dwellings a year, over the slightly shorter time period to 2031 the average requirement is 784 dwellings a year. Most importantly however is that to support the Council’s economic growth strategy, a higher portion of the growth is required to be delivered in the earlier part of the plan period.

3.27 The LEP sets the economic strategy to 2030 and over this period the average dwelling requirement would be 783 dwellings.

3.28 The Core Strategy runs from 2006 to 2026, the projections in the SHMA only start at 2011 but for the period to 2026 the dwellings requirement would be 898 dwellings a year. Even the projection that reflects the baseline economic position (rather than the Framework paragraph 158 position) would require an average of 811 dwellings over the period to 2026.

3.29 For the five year assessment of housing land supply, the period would be to 2020 although in order to calculate any backlog one would have to look back to 2010 or in this case 2011 as this is the start of the projections. Over the period 2011 to 2021 the average requirement is 994 dwellings a year. In the context of the five year assessment this would appear to be the most appropriate.

3.30 What this report clearly demonstrates is that the 680 dwellings a year in the extant Core Strategy does not reflect the Objectively Assessed Housing Need for the period of that plan.


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Table 1 Changes to housing demand over time

Period

PROJ 1 (2011-based SNPP)

PROJ 2 (2011-based SNPP (updated))

PROJ 2A(reduced household formation constraint)

PROJ 3 (Experian job led)

PROJ 4 (Experian job led with uplift)

2011/12 746 703 732 840 921

2012/13 702 656 682 794 878

2013/14 733 686 718 835 921

2014/15 752 704 733 855 945

2015/16 763 714 735 859 951

Average 2011-16 739 693 720 837 923

2016/17 736 687 718 955 1,063

2017/18 696 645 682 927 1,039

2018/19 723 670 708 959 1,073

2019/20 716 662 699 957 1,072

2020/21 711 657 695 956 1,073

Average 2016-21 716 664 700 951 1,064

Average 2011-21 728 678 710 894 994

2021/22 714 660 701 680 741

2022/23 686 631 667 644 706

2023/24 692 637 682 654 716

2024/25 667 612 658 625 686

2025/26 659 604 660 625 686

Average 2021-26 684 629 674 646 707

Average 2011-26 713 662 698 811 898

2026/27 680 624 670 458 490

2027/28 648 591 641 422 455

2028/29 628 570 623 398 430

2029/30 616 558 615 381 414

2030/31 613 555 610 371 403

Average 2026-31 637 580 632 406 438

Average 2011-31 694 641 681 710 783

2031/32 635 576 627 431 458

2032/33 605 545 598 399 427

2033/34 568 507 568 367 395

2034/35 550 489 551 346 375

2035/36 503 441 508 303 332

Average 2031-36 572 512 570 369 397

Average 2011-36 670 615 659 642 706 Source: Table 28 Peterborough Sub-Regional Strategic Housing Market Assessment (March 2014) Appendix


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The SHMA Assumptions

3.31 There are a number of assumptions within the SHMA we would consider are not in accordance with the approach set out in the Framework and the Guidance:

a. The approach to household representations rates is considered to be too pessimistic and an alternative approach is set out in this submission which is considered to better reflect the objectives of the Framework in terms of allowing for an improved access to housing as the economy comes out of recession.

b. The approach to modelling the impact of the change in pension rates is not considered to be appropriate and an alternative which is based upon research by DWP is set out in the next section.

c. The approach to modelling the level of housing required to provide for the projected levels of employment growth is unclear in terms of using the percentage increase rather than considering the actual level of additional labour force required. In addition the contention that the level of activity will continue to increase for the period of projection is not supported. The chart below shows that over the long term there has been little change in activity rates in England as a whole, with only a very modest level of increase in activity rates. The second chart shows that for the East Midlands the trend in terms of economic activity is a marked decrease in the rate of economic activity.

5.2 In light of this the employment led projections in the SHMA are likely to represent an underestimation of the likely level of housing required to meet the assumed levels of employment.


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4.0 REVIEW OF DEMOGRAPHIC EVIDENCE ON THE HOUSING REQUIREMENT FOR

SOUTH KESTEVEN

“Geography of Housing Market Areas” (DCLG 2010)

4.1 This research sought to identify the optimal areas within which planning for housing should be carried out. It links places where people live, work, and move home. Published by the DCLG it was commissioned by the National Housing Planning Advisory Unit (NHPAU). The NHPAU commissioned this work because they considered that there was a fundamental argument in support of planning for housing on a scale that is larger than most local authorities because market dynamics and population changes do not respect administrative boundaries but cut across them, operating at different scales.

4.2 The Executive Summary states that analysis and decision making within areas which are functionally as self-contained as possible, allows the various factors that affect housing supply to be weighed against demand pressures, with minimum distortion due to ‘out of area’ effects. It goes onto state:

“The need for joint planning will vary across the country. It is determined by the level of interdependence between adjoining areas within which jobs are created, people search for work or housing, and where they shop and play. This will be based on labour markets, housing markets, and other – often local - factors. In areas that are critical to the economic, social or environmental health of the country, joint planning is a critical requirement. Here, local plans must consider the wider spatial context, land resources and development outcomes (positive, negative, and displacement effects) of surrounding areas. Local communities need the confidence of knowing that they will be supported by, and not undermined by, the planning decisions of adjoining areas. Local initiative cannot be effective otherwise Housing Market Area which was to deliver.”

4.3 Within England, the work defined a set of 75 Framework Housing Market Areas (HMA’s), with a tier of 280 local housing market areas nested wholly within them.

4.4 This states that the upper tier of Framework Housing Market Areas would be most effective in providing a longer term overview of projected household changes, transport connectivity, housing land availability, housing market change and urban capacity, thereby addressing major initiatives like growth areas. As such the report states that this upper tier is the most suitable for delivering a strategic planning Framework.

4.5 This work identifies that South Kesteven is within the Peterborough Housing Market Area together with the following Local Authorities:


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Table 2 Extract from table 27 of The Geography of Housing Market Areas in England Centre for Regional Development Studies

LA Code LA Housing Market Area

00FP Rutland 32

00JA Peterborough 32

12UD Fenland 32

32UG South Kesteven 32

The Sub National Population Projections (SNPP)

4.6 A comparison between the Sub National Population Projections (SNPP) that form the basis of the 2004 and 2008 Household Projections are set out below and compared with the more recent 2010 SNPP and the Interim 2011 SNPP.

Table 3 Comparison of Sub National Population Projections (SNPP) for South Kesteven from 2011 to 2031

2011 to 2031 2004* 2006 2008 2010 2012*

Population at 2011 134,950 136,700 132,800 134,700 135,000

Natural change -6,900 -2,000 -300 2,000 1,700

Migration 21,700 29,500 20,500 28,400 18,000

Ave migration 1,276 1,475 1,025 1,420 947

Final population at 2031 150,800 164,300 152,000 164,000 153,900 Note 2004 based 17 year period 2011 to 2029 and 2012 19 year period 2012 to 2031

Source: ONS

4.7 This table highlights that the most recent projections (2012 SNPP) suggest that there will be a higher population at the end of the period than projected by the 2004 based projections which formed the basis for the RSS and Core Strategy.

4.8 In terms of migration this has fluctuated widely but the most recent projections do represent the lowest level of migration, which is perhaps unsurprising given both the recession and the underperformance of delivering dwellings needed to meet the higher projections. Chart 1 on the next page illustrates the range of migration assumptions used in the DCLG projections.

4.9 An important point to consider here is that the circumstances surrounding natural change and migration have changed significantly since there was the consideration of levels of dwelling provision in the Core Strategy. This means that scales of provision that might have been regarded as representing a growth agenda, might in themselves now be inadequate to meet the Objectively Assessed Need of the District.


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Chart 1: Comparison of DCLG Migration assumptions for South Kesteven

Chart 2: Comparison of Migration and Natural Growth assumptions in DCLG projections for South Kesteven


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The Sub National Household Projections (2012)

4.10 The Sub National Household Projections (2012) were released on 28th March 2015. These use the 2012 SNPP’s above and apply trend based assumptions regarding household formation rates in order to establish the future level of housing need.

4.11 As highlighted above in accordance with government guidance these will form the starting point of the Objective Assessment of Need for housing. Again as highlighted above these need to be tested in terms of their assumptions regarding future levels of migration, the needs of the local economy and whether they represent an appropriate response to issues of affordability. Including the delivery of the full requirement of affordable housing.

Table 4 Comparison of the 2012 Sub National Household Projections to SHMA findings

2012 Sub National Population Projections (Table 406) 2

011

2031

2036

Vac

an

cy R

ate

s (

SH

LA

A

ap

pen

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pa

rag

rap

h 1

.31)

20 y

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av

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ge h

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s

20 y

ear

av

era

ge r

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t fo

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inc v

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25 y

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av

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25 y

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av

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SH

MA

20

14 (

Tab

le 8

5:

PR

OJ 2

A

(Ad

juste

d H

ead

sh

ip)

Pro

jecti

on

s)

Peterborough UA 74,355 92,586 47,447 3.6% 912 944 892 924 1,107

Rutland UA 15,130 17,045 17,506 5.4% 96 101 95 100 138

South Holland 37,325 45,523 410 3.7% 422 438 405 420 558

South Kesteven 57,530 68,568 70,825 3.7% 552 572 532 551 659

184,340 223,722 136,188 0 1,981 2,055 1,924 1,996 2,462

4.12 It is notable that the main demographic projection in the SHMA suggests that a higher

level of dwellings might be required than the level now suggested by the 2012 Sub National Household Projections.

4.13 The differences between the two projections are that the SHMA utilises the 2011 interim household projection and the underlying population projections.

The 2012 Household Representation Rates

4.14 At the national level the 2012-based Household Projections have a very similar rate of household growth as the 2011-based Interim projections for the comparable period from 2012 to 2022. Population growth is lower than the previous Interim Projections but this is off set by higher projected household formation in the 2012 Household Projections (DCLG Housing Statistical Release 27th February 2015).

4.15 These are trend based projections and as such reflect previous levels of under provision that have led to the present housing crisis. The PPG makes it clear that


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these projections do not reflect unmet need (Paragraph: 015 Reference ID: 2a-015-20140306).

4.16 The changes between 2001 and 2011 reflected in these projections are:

a. The 36% rise for those living in Other households without dependent children.

b. The 30% rise between 2001 and 2011 for those living in Other households with dependent children.

c. Households with six or more people rose 25% between 2001 and 2011.

d. Households with six or more people saw the largest proportion at almost 50%.

e. 18% of all occupied household spaces were privately rented, an increase from 12% in 2001. This was the largest increase of all housing tenure types.

f. Owner occupation declined from 69% to 64% over the same period

Source: 2011 Census Analysis, Households and Household Composition in England and Wales, 2001-2011

4.17 In respect of the growth in Other households, not only have these increased substantially but they have also increased in average size. The average size of Other households without dependent children increased from 2.92 people in 2001 to 3.06 in 2011 and saw the largest percentage increase (5.1%). Within this main category, the Other category includes unrelated adults sharing a household space and multi-family households with no dependent children; this category increased by 4.1% from 2.90 people to 3.02. It is suggested by the Office for National Statistics that this may reflect an increase in young working adults sharing accommodation and multigenerational households.

4.18 The 2012 Household Projection Methodology (page 19) provides further details of how the short term trend have been weighted in this new projection:

f. Projecting household representative rates The procedure followed to project the household representative rates at the national level is consistent with the 2011-interim projections, with 5 observations to project forward but there remain issues that some of the Census points (particularly the 1991 Census) look to be quite strange.

The projections of the household representative rates use a combination of two fitted trends:

1. A simple logistics trend - a straight line fitted to ln (Xt / (1-Xt))

2. A dampened logistics trends where an S-shaped curve is fitted to ln (Xt / (1-Xt))

These functions were developed as part of the development for the Stage One methodological review to fit through the Census points as some of the trends are linear whilst others have a curve.

As with previous vintages of the projections, it is still not clear which of these is the most appropriate. The dampened trend provides a better fit for the Census data. But consideration has to be given to the extent to which data errors may have affected measured past trends and also to the fact that the data for 2011 by demographic type are estimates based on the trends by age from the LFS as well as some data from the 2011 Census. Further detail on concerns with some of the previous Census points (particularly 1991) is provided in the 2008-based methodology document.


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Given the uncertainty, the alternative projections are weighted together using the following weights:

15 to 29 year olds: 80:20 weights for dampened / simple trend

30 year olds and over: 60:40 for dampened/ simple trend

The reason for the differential weights is that Labour Force Survey (LFS) data indicate declining aggregate household representative rates for the younger age groups and, consequently, there is evidence that it is more appropriate to give a bigger weight to the dampened trend in these cases.

4.19 In conclusion it is considered inappropriate to utilise the Household Representation Rates in the 2012 Household Projections as these project forward the continuation of above trends which are in conflict with the Framework notably in terms of:

a. Not meeting housing demand (Framework paragraph 159)

b. Not delivering a wide choice of homes and widen home ownership (Framework paragraph 50).

4.20 It is important to note that SPRU have run the Chelmer Model using the up-to-date 2012 SNPP and our own assumptions on household formation and these have a much closer alignment with the recent published figures above modelling as they do a dwelling requirement of 562 dwellings a year compared to the slightly higher requirement the 2012 Sub National Household Projections of 572 dwellings for the same period (2011 to 2031). In these circumstances the remainder of the analysis undertaken in this report can be regarded as being both conservative and comparable to the recently published Government projections.


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5.0 INDICTORS OF MARKET DEMAND

Employment growth

5.3 The Peterborough HMA has experienced employment growth and the chart below suggests that the trend for all districts is positive despite some slowing down and reductions during the period of the recession.

5.4 On average Peterborough has been the fastest growing at 750 jobs a year with South Kesteven growing at some 583 jobs a year between 2000 and 2012.

5.5 The Guidance recognises job growth in the future may influence future patterns of migration.

Chart 3: Increase in jobs in HMA 2000 to 2011

South Kesteven Employment Land Capacity Study

5.6 To assist in planning for employment growth, two alternative growth scenarios were modelled, adapting the base 2009 Experian Growth forecasts in the following ways:

a. Scenario 1: Grantham Growth Point: This scenario factors in the potentially positive impact of the designation of Grantham as a new Growth Point to 2016. The anticipated employment increase as a result of the step change in house building and employment creation as a result of the additional infrastructure funding and other stimuli has been estimated to be in the order of 4,800 new jobs created to the period 2016 (including unimplemented planning permissions). SKDC estimate that around 2,500 of these jobs are likely to be created in the banking, finance and insurance services and other office based public sector work. NLP understands that the predominantly trend-based


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Experian forecasts are unlikely to have factored in the full impact of Grantham’s growth point designation; hence it is considered justifiable to plan for the likely increase in employment land needs likely to result. However, as this employment outcome has merely been added on to the Experian baseline forecast, without modelling the extent of self-containment (i.e. the proportion of those jobs taken by non-residents), the approach is not a sophisticated approach to the modelling and may therefore artificially inflate the findings. For this reason an element of caution should be applied in interpreting the results. Under this scenario, the 2,500 B1-based employment projections have been factored into the office forecasts, whilst the remaining 2,300 employees have been distributed across the remaining industrial sectors on a pro-rata basis to 2016.

b. Scenario 2: Reducing out commuting: This reduced the level of out commuting and so increased the level of employment locally (in the order of 5,950 additional employees, achieved by providing more land for employment purposes) has been factored into the 2009 Experian employment projections on a pro-rata basis over time.

5.7 It should be noted that more recently Inspectors have rejected projections based upon assumptions of changing commuting patterns, as there has been no evidence provided that the desired changes might actually occur (Aylesbury Vale and South Worcester).

The Greater Lincolnshire LEP Economic Plan 2014

5.8 The Strategic Economic Plan sets out the following targets to achieved by 2030:

a. create 13,000 new jobs

b. support 22,000 businesses

c. increase the value of the Greater Lincolnshire economy by £3.2 billion by 2030

d. deliver up to 100,000 new homes

5.9 Major projects include:

a. Grantham southern relief road – will create 17 hectares of employment land and 1,600 housing units, levering £260m of private sector funding.

b. Grantham College – will create 43 new jobs and assist 300 businesses.

5.10 This Economic Plan confirms the role of Grantham as a future Growth Point (appendix page 31) and states:

“With an increasing population and changing economy the Core Strategy seeks to broaden and diversify the employment base of the District by identifying opportunities and sites for specific employment sectors in the towns and by encouraging appropriate employment, tourist related and diversification schemes in the rural area. This includes high quality business park and office developments in Grantham and Stamford which can take advantage of good access to the strategic road network.

To complement the planned growth in housing and employment, growth within and around the town centres, particularly in Grantham, will be focused on improving the town centre offer including new retail opportunities and potential regeneration for mixed use schemes.”


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The Peterborough Sub-Regional Strategic Housing Market Assessment (March 2014)

5.11 In section 4 the SHMA considers the potential level of employment growth. We have sought to interrogate econometric forecasts prepared by Experian (from Experian’s September 2013 run of its regional model). These forecasts provided a starting point for the SHMA consideration of the economic growth potential of the HMA and the impact on the need for housing.

5.12 Table 18 “Review of Employment Forecasts against Past Employment Growth: Change in Jobs 2011-31” highlights that for South Kesteven the predicted level of employment growth is 8,800 jobs between 2011 and 2031 and that this was lower than the Linear Trend 1998-2008 which would suggested an increase of 13,800 jobs.

5.13 The Experian projection is also lower than 14,100 jobs suggested by the Linear Trend 2001-11 which includes the impact of the recession.

5.14 Paragraph 4.57 the SHMA states that in drawing the analysis together, they considered that the baseline Experian forecasts for the four authorities seemed to provide a reasonable projection for future performance. While noting that the Economic Strategy and key investments provide some upside assessment to this, there were also some downside risks making it prudent in their view to test the potential to support stronger performance. They have therefore sought to model a second ‘Aspirational’ Economic Scenario based on a 20% uplift in employment growth on a year-on-year basis in all four authorities over the period to 2036.

5.15 For South Kesteven a 20% uplift in the Experian forecast (8,700 jobs) would be 10,440 jobs.

5.16 Table 37 illustrates that the outcome of the GL Hearn projections for South Kesteven would be 710 dwellings to meet the Experian projections of 8,700 jobs over the Plan period 2011 to 2031. This would increase to 783 dwellings a year if applied to the higher “aspirational” level of job growth of 10,440 (522 jobs a year).

5.17 It should be noted that both these levels of job growth are below the average achieved in the period 2000 to 2012 of 583 jobs a year.

Commentary on methodology of the SHMA

5.18 There are a number of assumptions within the SHMA we would consider are not in accordance with the approach set out in the Framework and the Guidance:

a. The approach to household representations rates is considered to be too pessimistic and an alternative approach is set out in the next section which is considered to better reflect the objectives of the Framework in terms of allowing for an improved access to housing as the economy comes out of recession.

b. The approach to modelling the impact of the change in pension rates is not considered to be appropriate and an alternative which is based upon research by DWP is set out in the next section.

c. The approach to modelling the level of housing required to provide for the projected levels of employment growth is unclear in terms of using the percentage increase rather than considering the actual level of additional labour force required. In addition the contention that the level of activity will


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continue to increase for the period of projection is not supported. The chart below shows that over the long term there has been little change in activity rates in England as a whole with only a very modest level of increase in activity rates. The second chart shows that for the East Midlands the trend in terms of economic activity is a marked decrease in the rate of economic activity.

5.19 In light of this the employment led projections in the SHMA are likely to represent an underestimation of the likely level of housing required to meet the assumed levels of employment.


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6.0 HOUSE PRICES AND AFFORDABILITY

6.2 The following charts illustrate that South Kesteven has consistently had higher house prices than the regional average and is the second highest district in the HMA with only Rutland being higher. Both these factors would suggest that consideration should be given to higher levels of provision to address the issue of affordability.

6.3 In terms of affordability ratios, South Kesteven is less affordable than both England as a whole and the East Midlands. Again this would suggest that consideration should be given to increasing the level of housing provision. Within the HMA it is less affordable than both Peterborough and Fenland again suggesting that there should be a positive response in terms of additional provision to this indicator of market demand.

Chart 4: Mean House Prices for South Kesteven compared to East Midlands


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Chart 5: Mean House Prices for South Kesteven compared to HMA

Chart 6: Ratio of lower quartile house price to lower quartile earnings South Kesteven compared to South East and England


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Chart 7: Ratio of lower quartile house price to lower quartile earnings by district, from 1997 for LA’s in HMA

Full Objectively Assessed Need for Affordable Housing

6.4 The Peterborough Sub-Regional Strategic Housing Market Assessment (March 2014) undertakes the most recent assessment of affordable housing market needs. This assessment however does not follow the process of making sure that the final level of housing will deliver the full affordable housing needs which they identify.

6.5 In paragraph 10.13 the SHMA states:

“The affordable needs evidence could provide some justification for considering an upwards adjustment to the level of housing need projected. In total the affordable housing need identified would equate to 55% of the level of housing identified in the PROJ 2A demographic projection.

10.14 The Planning Practice Guidance is not specific regarding what scale of adjustment might be appropriate….”

6.6 The report suggests that there are two key factors which have to be taken into account in interpreting their results these being;

a. The number of households who are adequately housed already but are paying more than 30% of household income for housing

b. The role of the private rented sector

6.7 While meeting the needs of those currently spending more than 30% of household income on housing would not require a net increase in provision (as presumably they are either in owner occupancy or rented accommodation) the provision of additional properties for private rent does require additional net provision.


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6.8 In effect the authors are suggesting that their reported finding regarding affordable housing need might be an over estimation of the actual need for new dwellings and as such there is no requirement to alter the levels of housing projected for the HMA.

6.9 This approach has clearly been superseded by the Warrington Judgement which requires consideration be given to the level of housing required to deliver the full assessment of need for affordable housing.

6.10 This of course is dependent upon the viability of housing provision within the area. As no viability testing has been undertaken recently in support of the SHMA the table below uses the affordable housing requirements in the development plans for the area. It is recognised that more recent assessments on individual application have led to a reduction in provision at the present time. Until this is established as a longer term trend in viability however we have decided to use the higher levels of delivery envisaged and tested though the development plan process. Even with these higher rates of provision the level of housing requirement in all parts of the HMA is substantially above the levels being recommended in the SHMA.

6.11 The table below undertakes the calculation of the overall level of housing required to deliver the net affordable housing needs as identified in the SHMA using the development plan policies concerning the required level of affordable housing.


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Table 5 Calculation of the overall level of housing required to deliver the net affordable housing needs as identified in the SHMA

Impact of affordable N

et

Aff

ord

ab

le a

nn

ual n

eed

(SH

MA

Tab

le 5

3:

As

ses

se

d

Aff

ord

ab

le H

ou

sin

g N

eed

(2013

-

36)

– in

clu

din

g D

ev

elo

pm

en

t

Pip

elin

e)

Pro

po

rtio

n o

f d

ev

elo

pm

en

t th

at

can

be d

elive

red

as a

ffo

rdab

le

ho

usin

g

Level o

f d

well

ing

s r

eq

uir

ed

to

delive

r aff

ord

ab

le h

ou

sin

g O

AN

25 y

ear

av

era

ge r

eq

uir

em

en

t fo

r

dw

ellin

gs (

inc v

ac

an

cy)

SH

MA

20

14 (

Tab

le 8

5:

PR

OJ 2

A

(Ad

juste

d H

ead

sh

ip)

Pro

jecti

on

s)

Note

Peterborough UA 592 30% 1,973 924 1,107

No more recent viability testing than though the CS so CS policy used

Rutland UA 47 35% 134 100 138

No more recent viability testing than though the LP so LP policy used

South Holland 258 33% 782 420 558

No more recent viability testing than though the LP so LP policy used

South Kesteven 300 35% 857 551 659

No more recent viability testing than though the CS so CS policy used

SHMA 1,350

3,747 1,996 2,462

Overall conclusion on evidence of demand

6.12 The indicators of demand considered above suggest that there has remained a strong market demand for housing within South Kesteven in that house prices have continued to be higher than both regional and national averages, as well as two out of the three other districts in the HMA. This would suggest that demand in the area is not being met.

6.13 This conclusion is supported by the worsening affordability in the District, not just over time but also in relation to the districts of Peterborough and Fenland within the HMA.

6.14 It is further concluded that in order to deliver the identified affordable housing requirement, would require a higher level of overall dwelling provision.

6.15 Evidence of employment growth within the HMA and within the District together with the continued support from the LEP for the Growth Point at Grantham, also suggest there will continue to be high levels of demand with South Kesteven.


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7.0 THE OBJECTIVELY ASSESSED NEED FOR HOUSING

The approach to the Objectively Assessed Need for housing

7.1 The Framework provides the background against which to approach the choice of assumptions as part of the Objective Assessment of Need for housing. The following summarises the framework in which to approach these assumptions and make these choices:

a. The objective is to provide a supply of housing to meet needs of both this and future generations (paragraph 7);

b. There is also the requirement to increase the opportunity for home ownership based upon not just current but also future demographic trends, market trends and the needs of different groups in the community (paragraph 50);

c. The planning system does everything it can to support sustainable economic growth. Planning should operate to encourage, and not act as an impediment, to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system (paragraph 19); and

d. Finally, the general approach is for plans to be positively prepared.

7.2 These principles should not be applied to the outcome of the projections but should inform the choice of assumptions made as part of the process of modelling the Objectively Assessed Need. The consequence of applying these principles to the modelling process are as follows:

a. Where there is a choice of reasonable alternatives regarding the future propensity of persons to form households, then the requirement to increase the opportunity for home ownership and plan positively requires one to choose the more favourable assumptions that would allow more, rather than less, people to form their own households and achieve greater home ownership.

b. Where there are a number of reasonable projections of future employment growth one should plan to accommodate the highest of these projections as failure to do so might actually contribute to these higher levels of growth not being achieved.

c. As confirmed in the Hunston decisions, once an Objectively Assessed Need has been arrived at following these principles, then the housing requirement maybe set at less than the need if:

i. Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole; or specific policies in this framework indicate development should be restricted; and

ii. The Council has engaged the Duty to Cooperate (Framework paragraphs 178 to 181) so that these needs are met elsewhere, so as to fulfil the core principle of the delivering the homes the Country needs (paragraph 17).

7.3 In light of the evidence on demand in the earlier section it is considered that not only is effective demand returning to the housing market, but that those who have been


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excluded from the market by past conditions, as well as those entering into the age of potential home ownership, are all wishing to enter the housing market. This means that the low level of Household Representation Rates included in the 2011 interim Household Projections are inappropriate for modelling the Objectively Assessed Need for Housing.

The two stages to determining the Objectively Assessed Need for Housing

7.4 In determining the Objectively Assessed Need for Housing the Framework requires that a two stage approach is taken. This may be summarised as follows:

a. Consideration of demographic projections and trends (paragraph 159 of the Framework);

b. Consideration of the needs of the economy (paragraph 158 of the Framework). This has been described as the “final step” in the assessment in the South Worcestershire Development Plan Inspectors letter and the balance between employment growth and housing provision also featured strongly in the Inspectors letter finding the Vale of Aylesbury Plan unsound.

The Chelmer model

7.5 This is a version of the DCLG model. It is a five year model and is a recognised tool for testing scenarios as highlighted by the former SHMA Practice Guide and various appeal decisions.

7.6 The model takes a given population and “ages” this population between 2011 and 2036 by applying the death rates which are appropriate to each age group.

7.7 It also adds births to the population according to the level of fertility recorded for each age group for females.

7.8 The likely level of out-migration and in-migration for each age sex cohort is also applied which will add or remove persons from the area.

7.9 The likelihood of people to be economically active at each age is calculated taking into account the propensity of these persons to work depending on their age and sex.

7.10 The likelihood of a person at each age to become a head of household (Household Representation Rates) is also applied to each age/sex group giving the likely level of housing requirement.

The Evidence base

The starting point – the 2012 SNPP

7.11 The 2012 Sub National Population Projections take into account 2011 census results in terms of population age and sex as well as recent migration patterns.

7.12 These have been used as an input to the Chelmer Model to provide a population led forecast providing a demographic forecasts for future housing needs in each of the districts in the HMA.

Changes made to the DCLG assumptions

7.13 Household representation rates – the 2011 Interim Household Projections contain the most recent Household Representation Rates produced by the Government on a sub national level. These projected rates however have two issues:


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a. They only extend to 2021; and

b. They model forward the negative impact of undersupply and recession – for example the inability of under 35’s to enter the housing market so these assumptions model forward the present situation of more under 35’s staying at home and a greater number of unrelated adults living together (shared housing).

7.14 These have been extended to 2031 and amended to reflect that the Framework’s requirement for plans to increase the supply of housing and choice (paragraph 50). Therefore, rather than to continue recent short term trends, the Household Representation Rates used in the model have been based on the 2011 interim CLG projections to 2016, and then they are amended to track the earlier 2008-based projections from 2016 onwards. This approach does not therefore catch up with the long term trends by 2031 and as such could still represent a level of unmet demand.

7.15 It is recognised that using such an assumption, while a reasonable option in terms of a statistical approach, could be argued does not fulfil the requirements of the Framework, in particular paragraph 17, of meeting the housing needs of the Country, or increasing the opportunity for home ownership.

7.16 Activity Rates – The context for this is that the Chelmer Model holds Economic Activity Rates at a constant level from 2011.

7.17 This is considered to be a reasonable assumption given that the long term trend for England is only for a very marginal upwards trend, while the long term trend for the East Midlands is for reduced activity rates. These trends are illustrated by the charts below which are extracted from the official Nomis database.


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Chart 8: Long term evidence on changes to activity rates in England

Chart 9: Long term evidence on changes to activity rates in East Midlands


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7.18 It is therefore reasonable to consider if this adequately reflects future changes such as

the impact of equalising the pension age to 65 and then the rising of the age to 66.

7.19 The most recent research on activity rates is contained in the UK Commission for Employment and Skills Working Futures 2012-2022 Evidence Report (March 2014). Table 2 on page 17 is based upon the analysis of changes across age/sex and concludes that activity rates for males (16+) will decrease by one percentage point, while activity rates for females (16+) will increase by one percentage point. The report comments:

“Both population and working age population are forecast to rise faster for males than for females, but the labour force for females is expected to increase faster than the male labour force (continuing recent trends). This reflects the increasing participation of women in the labour force and, over the period 2012-22, the gradually increasing pension age for women from 59 to 64. Overall participation rates are expected to increase slightly over 2012-17 but then see little change, such that the rate in 2022 will be about the same as in 2012.”

7.20 This suggests that changes that occur due to the state pension age are limited in terms of overall activity rates.

7.21 The SPRU has considered various approaches, the first is based upon the ONS assessment of the changes of the state pension age as set out in Edge Analytics report of January 2014, which stated:

“ONS published its last set of economic activity rate forecasts from a 2006 base (ONS January 2006, Projections of the UK labour force, 2006 to 2020). These incorporated an increase in SPA for women to 65 by 2020 but this has since been altered to an accelerated transition by 2018 plus a further extension to 66 by 2020. Over the 2011–2020 period, the ONS forecasts suggested that male economic activity rates would rise by 5.6% and 11.9% in the 60-64 and 65-69 age groups respectively. Corresponding female rates would rise by 33.4% and 16.3% (Figure 14). Given the accelerated pace of change in the female SPA and the clear trends for increased female labour force participation across all age-groups in the last decade, these 2011–2020 rate increases would appear to be relatively conservative assumptions.”


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Chart 10: ONS Labour Force Projections

Source Edge Analytics (December 2013)

7.22 In summary this would require the following amendments to the baseline activity rates to take into account rising pension ages. This increases the level of labour force that might be expected from any level of dwelling provision:

a. Males 60 to 64 age group increased by a total 5.6% between 2011 and 2021 and then held constant.

b. Males 65 to 69 age group increased by 11.6% between 2011 and 2021 and then held constant.

c. Females 60 to 64 age group increased by 33.4% between 2011 and 2021 and then held constant.

d. Females 65 to 69 age groups increased by 16.3% between 2011 to 2021 and then held constant.

7.23 It is important to note that these increases are slightly higher than those found as being realistic by the Inspector at the South Worcestershire Development Plan (paragraph 34 page 7 Inspectors Interim Conclusions on the stage 1 Matters and paragraph 4.3.3 page 15 NLP Miller Strategic land “Updated Assessment of Housing Requirements to inform Examination Matter 1”). In that case the following assumptions were considered to represent a reasonable response to the changes to the pension age:

a. Males 60 to 64: No change.

b. Males 65 to 69: 2 percentage points between 2012 and 2018.


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c. Females 60 to 64: 8 percentage points between 2012 and 2018.

d. Females 65 to 69: 2 percentage points between 2012 and 2018.

7.24 Further to this evidence account has been taken of the findings of the Institute of Fiscal Studies “Incentives, shocks or signals: labour supply effects of increasing the female state pension age in the UK” (IFS Working Paper W13/03):

a. This tested for an impact of the change of pension age on activity rates of those below 60 and found that there was no impact (Appendix B and footnote 21 pages 16 and 17).

b. This found the impact of raising the state pension age was to increase employment rates by 7.3 percentage points for women and unemployment rates by 1.3 percentage points (page 8).

c. There was a corresponding increase of 4.2 percentage points in their male partner’s employment rates (page 28). This suggests that an increase in the activity rates for males in the 60 to 64 age group is appropriate, but that as this increase only related to male partners and not all males. As only 52.8% of all households are formed of couples (2011 interim Household Projections table 420 England) then at best this increase in activity can only be applied to this percentage of the male population. This would suggest an increase of 2.2 percentage points.

7.25 The SPRU have also considered further evidence produced by the Government concerning the impact of the changes as published in the Department of Work and Pensions report; “When the State pension Age will increase to 66” Equality Assessment (January 2011). Table 4 in the appendix of the report suggests the bringing forward of the state pension age to 66 will have an additional impact of increasing the numbers in employment by just over 4% at 2020, but that this impact will reduce to under 1% by 2026 (table 4).

7.26 Lastly the data from the Office for Budget Responsibility has been considered. In particular the Charts and Tables from the Fiscal Sustainability Report (FSR) July 2013. Chart 4.9: 65-74 economic activity rate scenarios and the accompanying tables, suggest that economic activity rates amongst this age group will increase by over 42% as compared to a forecast which retains the previous age of retirement.


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Table 6 65-74 economic activity rate scenarios

Source: Office for Budget Responsibility Chart 4.9 from the Fiscal Sustainability Report (FSR) July 2013

7.27 The table below combines these impacts and the result is higher rates of change to that previously found sound. The table below summarises this set of assumptions.

Table 7 Summary of assumptions used to reflect impact of changes to pension age

Source Age group Sex

2011-16

2016-21

2021-26

2026-31

Impact of equalisation of pension age - IFS working Paper W13/03 percentage point increase 60-65 men 2.2% 2.2% 2.2% 2.2%

60-65 women 8.6% 8.6% 8.6% 8.6%

Increase to 66 DWP Equality impact Assessment 2011 (percentage change) 55- 65 men 1.5% 4.2% 0.8%

55- 65 women 4.8% 4.7% 0.8%

Post 65 economic Activity OBR RFS 2013 (percentage change from baseline forecast) 65 - 74

increase above baseline both sexes 13.3% 27.6% 42.5% 47.9%

7.28 The impact of combining these assumptions as inputs to the model is shown the

tables below.


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Table 8 Activity Rates from the Chelmer Model used in the Alternative Activity Rate Projection

Males 2006-11 2011-16 2016-21 2021-26 2026-31 Percentage Change

60-64 58.4% 61.5% 63.1% 61.1% 60.6% 3.77%

65-69 42.9% 48.6% 54.7% 61.1% 63.4% 47.89%

70-74 18.5% 21.0% 23.6% 26.4% 27.4% 47.89%

Females 2006-11 2011-16 2016-21 2021-26 2026-31 Percentage Change

60-64 31.2% 41.7% 41.7% 40.1% 39.8% 27.56%

65-69 20.3% 23.0% 25.9% 28.9% 30.0% 47.89%

70-74 8.0% 9.1% 10.2% 11.4% 11.8% 47.89%

Table 9 Activity Rates from the Chelmer Model used in the Alternative

Activity Rate Projection - Percentage points increase from 2011

Males 2011-16 2016-21 2021-26 2026-31

60-64 3.1% 4.7% 2.7% 2.2%

65-69 5.7% 11.8% 18.2% 20.5%

70-74 2.5% 5.1% 7.9% 8.9%

Females 2011-16 2016-21 2021-26 2026-31

60-64 10.5% 10.5% 8.9% 8.6%

65-69 2.7% 5.6% 8.6% 9.7%

70-74 1.1% 2.2% 3.4% 3.8%

7.29 The difference between utilising these assumptions compared to the lower levels of

change that have previously been found sound, is that these higher levels of activity rates for the post 60 age groups will be to increase the labour supply from the same population. In general terms therefore this will reduce the number of dwellings required to support the same level of employment growth.

7.30 Unemployment – For employment led projections an allowance has been made for the number of unemployed in the District to reduce from the 2011 level (the start of the projection period) to the lowest recorded level in the last decade as recorded by the Nomis data base. The table on the next page sets out this approach.

7.31 The impact of reducing the target jobs by assuming a decrease in unemployment has a similar effect of increasing activity rates, but is grounded in the actual local evidence base rather than applying national trends.


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Table 10 Future changes to unemployment to be assumed in the projections

Period Unemployed

Jan 2004-Dec 2004 1600

Jan 2005-Dec 2005 2000

Jan 2006-Dec 2006 3200

Jan 2007-Dec 2007 2700

Jan 2008-Dec 2008 3200

Jan 2009-Dec 2009 4100

Jan 2010-Dec 2010 3500

Jan 2011-Dec 2011 4300

Adjustment made to reduce unemployment (number of unemployed at start of projection minus lowest level of unemployment in preceding decade) 2700

Nomis 2014

7.32 Commuting - For employment led projections the increase in the Labour Force has been amended to take into account the present pattern of out-commuting in the districts as determined by the Nomis data base. This means for this District where there is net out commuting, more dwellings are likely be needed to provide for a certain level of job growth, as some of the new residents will choose to work in neighbouring districts to the same extent as existing residents. This approach of holding commuting patterns constant has been held to be sound by Inspectors at the Examination of the South Worcester and Aylesbury Vale Plans.

Table 11 Calculation of additions to labour force required to support employment growth taking account of decreases in unemployment and existing patterns of commuting

Projection Ann

ua

l jo

b r

ate

Tota

l

Reduce

d

unem

plo

ym

en

t

Jobs a

t 2

011

Nom

is

Work

ers

at 2

011

Ratio W

ork

ers

to

jobs

Add

itio

nal

work

ers

require

d

to m

eet

job

fore

cast

Ann

ua

l gro

wth

in

lab

our

forc

e

PROJ 3 (Experian job-led) 435 8,700 2,700 62,000 68,900 1.11 6,668 333

PROJ 4 (Experian job-led with uplift) 522 10,440 2,700 62,000 68,900 1.11 8,601 430


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Summary of projections and associated assumptions:

7.33 This report contains two projections for each District these are summarised as follows:

a. 2010 SNPP - this projection is a population led projection in which the 2010 Sub National Population Projections are used to drive the model and return the dwelling requirement and changes to the economically active.

b. 2012 SNPP - this projection is a population led projection in which the 2012 Sub National Population Projections are used to drive the model and return the dwelling requirement and changes to the economically active.

c. Baseline – this is the baseline forecast from Cambridge Econometrics and is based on the model defaults this is a migration led forecast based upon recent migration rates.

d. 2012 SNPP Partial Return to Trend - this projection is a population led projection in which the 2012 Sub National Population Projections are used to drive the model but the household representation rates have been increased to reflect a partial return to the 2008 levels from 2016 onwards.

e. 2012 SNPP Partial Return to Trend PA - this projection is a population led projection in which the 2012 Sub National Population Projections are used to drive the model but the following have been adjusted:

i. Household representation rates have been increased to reflect a partial return to the 2008 levels from 2016 onwards.

ii. Activity rates have been changed to reflect the impact of the change to pensionable age.

f. Experian Jobs Partial Return to Trend PA - this projection is a migration led projection which is based on the 2012 Sub National Population Projections but then migration levels are adjusted to result in the level of workforce required to support the level of jobs in the SHMA Experian projection of 8,700 taking into account:

i. Decrease in unemployment

ii. Impact of existing commuting patterns

iii. Household representation rates being increased to reflect a partial return to the 2008 levels from 2016 onwards

iv. Activity rates have been changed to reflect the impact of the change to pensionable age

g. Experian Jobs with Uplift Partial Return to Trend PA - this projection is a migration led projection which is based on the 2012 Sub National Population Projections but then migration levels are adjusted to result in the level of workforce required to support the level of jobs in the SHMA Experian projection of 10,440 jobs. Again this is the same adjustments as the earlier Experian based projection.

7.34 The summary of these projections, undertaken with the Chelmer Model, are set out in the tables below on the following pages.


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Table 12 Summary of Chelmer Projections for South Kesteven

Dwelling change 2011-2016

2016-2021

2021-2026

2026-2031

2011 2031

Annual Average

2010 SNPP -55 855 769 836 12,027 601

2012 SNPP 485 622 662 481 11,248 562

Baseline 668 616 570 508 11,811 591

2012 SNPP Partial Return to Trend 650 656 664 484 12,271 614

2012 SNPP Partial Return to Trend PA 650 656 664 484 12,271 614

Experian Jobs Partial Return to Trend PA 650 848 860 766 15,622 781

Experian Jobs with Uplift Partial Return to Trend PA 650 915 912 880 16,785 839

Labour force change 2011-2016

2016-2021

2021-2026

2026-2031

2011 2031

Annual Average

2010 SNPP 47 457 196 305 5,023 251

2012 SNPP 85 -25 -48 -33 -106 -5

Baseline 257 -75 -148 -0 166 8

2012 SNPP Partial Return to Trend 85 -25 -48 -33 -106 -5


Experian Jobs Partial Return to Trend PA 316 407 315 336 6,865 343

Experian Jobs with Uplift Partial Return to Trend PA 316 516 387 502 8,599 430

Population change 2011-2016

2016-2021

2021-2026

2026-2031

2011 2031

Annual Average

2010 SNPP 100 1,580 1,440 1,580 23,500 1,175

2012 SNPP 920 1,160 1,080 820 19,900 995

Baseline 1,247 1,110 1,004 904 21,326 1,066

2012 SNPP Partial Return to Trend 920 1,160 1,080 820 19,900 995

2012 SNPP Partial Return to Trend PA 920 1,160 1,080 820 19,900 995

Experian Jobs Partial Return to Trend PA 920 1,604 1,606 1,472 28,009 1,400

Experian Jobs with Uplift Partial Return to Trend PA 920 1,784 1,732 1,766 31,007 1,550


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Migration 2011-2016

2016-2021

2021-2026

2026-2031

2011 2031

Annual Average

2010 SNPP -328 1,214 1,116 1,257 16,298 815

2012 SNPP 492 876 926 759 15,273 764

Baseline 820 811 811 811 16,260 813

2012 SNPP Partial Return to Trend 492 876 926 759 15,273 764


Experian Jobs Partial Return to Trend PA 492 1,320 1,400 1,294 22,532 1,127

Experian Jobs with Uplift Partial Return to Trend PA 492 1,500 1,508 1,560 25,302 1,265

Commentary on output of modelled scenarios including comparison with the 2012 DCLG Sub National Household Projections

7.35 The starting point of the assessment is the dwelling requirement based upon the 2012 SNPP which is 562 dwellings a year for the period to 2031. This is just below the 572 dwellings required to meet the 2012 sub national household projections (utilising a 3.7 % Vacancy Rate). As both the Chelmer and the DCLG’s projection are based upon the 2012 SNPP this suggests that the assumptions used in these baseline projections are comparable, this provides confidence when considering the other projections that make up this set.

7.36 The “Partial Return to Trend” projections require some 614 dwellings per year (some 42 dwellings a year above the DCLG’s projection. This higher requirement is based upon making an allowance for improved access to housing to counter the negative effects of the recession and previous levels of under provision. This change effectively allows a further 52 households a year to form from the same population (compared to SPRU’s baseline projection). This is a modest increase and is considered to be in accordance to the approach of the Framework and Guidance in respect of increasing opportunity of home ownership.

7.37 In terms of the demographic based projections therefore the 2012 SNPP partial return to trend is preferred i.e. 614 dwellings a year, in that it better reflects the approach and guidance in the Framework and the Guidance.

7.38 The 2012 SNPP based projections, even when amended to take account of increased levels of activity as a result of the changes to the pension age, will only add some 140 persons to the workforce each year compared to the Experian projection of 435 jobs and the growth target of 522 jobs. Even taking into account the decrease in unemployment of 2,700 (135 additional workers) there would still be a substantial shortfall between labour force of 375 additional persons and projected job growth of 435 to 522 jobs (140 additional persons over 60 working + 135 presently unemployed re-entering work = 375).

7.39 In this case the assumptions regarding the changes to activity rates for those over 60 will add a further 2,911 persons to the labour force by 2031. This is the difference in labour force between the 2012 SNPP projection and the 2012 SNPP PA projection. This represents a substantial contribution to the increased labour force if it occurs.


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7.40 The levels of dwelling provision to meet the Experian projection of 8,700 jobs or the Growth aspiration of 10,440 jobs (435 to 522 jobs a year) are employment led housing requirement and higher than the trend based dwelling requirement from the 2012 SNPP. The table on the next page summarises the components of meeting the employment projections.

Table 13 Illustration of constituent elements contributing to meeting job projections

Experian Experian plus 20%

Projected level of job growth 8.700 10,400

Reduction in unemployment 2,700 2,700

Increase in activity rates for the over 60’s (approximate)

2,900 2,900

Increase from additional dwellings 3,100 4,4840

7.41 As the Objectively Assessed Housing Need has to take into account the needs of the

local economy, the employment led projection maybe regarded as the Objectively Assessed Housing Need for the District.

7.42 It is recognised that employment projections are subject to greater fluctuation than the demographic forecasts and can be influenced in part by the future availability and cost of labour. In this case the projections utilised are 2012 based, and as such are likely to be more modest than the later projections which will factor in more of the effects of the economic recovery. In these circumstances it may be appropriate to consider these employment led projections as representing the lower end of any range of Objectively Assessed Need.

7.43 The four charts on the next two pages illustrate the potential futures for the District. The first two charts show the current age/sex of the population the second chart illustrates how this changes with the population becoming much more elderly. This has an impact on the number of workers from the same population and also the number of dwellings required as people are living longer and being active for longer they remain in their homes longer and hence slow down the recycling of the existing housing stock to younger age groups.

7.44 The two charts on the following page illustrate firstly how with lower levels of net migration additional dwelling provision does not result in an increase in workers, even when allowance is made for an additional 2,900 persons to enter the workforce over the plan period from the over 60’s.

7.45 The last chart illustrates how additional dwelling provision to accommodate more migration will provide for the level of additional labour required to support the Experian plus uplift job requirement.

7.46 As stated earlier, all these projections retain the existing patterns of travel to work for all residents.


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Chart 11: Age/sex of South Kesteven population at 2011

Chart 12: Age/sex of South Kesteven population at 2031


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Chart 13: Results for 2012 SNPP based household projections

Chart 14: Results for the Experian jobs with uplift


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Chart 15: Summary of demographic change as a result of the 2012 SNPP based dwelling requirement

Chart 16: Summary of demographic change as a result of the migration to meet the 18,700 jobs (21.030 additional persons in Labour Force)


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Conclusion on Objectively Assessed Need for Housing from the Chelmer Model

7.47 That the starting point of deriving the Objectively Assessed Need for housing according to the NPPG (Paragraph: 030 Reference ID: 3-030-20140306) are the Government’s own Sub-National Population Projections (SNPP). These projections provide consistency across the Country and as such are a valuable tool in determining future housing needs. These projections are tested so that they are consistent with the national projections; they do not however take into account future policy decisions.

7.48 The most recent government projections (the DCLG 2012 Sub National Population Projections) suggest a dwelling requirement of 572 dwellings a year to 2031 or a lower 551 dwellings a year for the longer period 2012 to 2037). These projections are comparable to those undertaken by SPRU in this report the 2012 SNPP as both utilise the same population projections but the assumption SPRU have taken in the initial projection are a little less optimistic in terms of future household formation.

7.49 In particular recent decisions on development plans by Inspectors have emphasised the requirement for the Objectively Assessed Need to reflect the future needs of the local economy and that local planning authorities should ensure that their assessment of, and strategies for housing and employment are integrated, taking full account of relevant market and economic signals (Framework paragraph 158).

7.50 The dwelling requirement from the 2012 SNPP of 562 dwellings a year cannot be considered to meet the Objectively Assessed Need as it models in the negative impact of the previous undersupply and the recession, in terms of both migration and Household Representation Rates. It also performs poorly when compared to future projections of job growth. It only provides for an average growth in the labour force of 140 persons a year with all of this growth coming from the projected increased activity in the 60 plus age groups.

7.51 If the Experian projection of 435 jobs a year from the SHMA is to be planned for then allowing for the reduction in unemployment and present commuting patterns this would require over 343 persons each year to be added to the labour force. This would require 781 dwellings a year to support this population growth.

7.52 To reflect the Growth Point status of Grantham and the aspirations of the Greater Lincolnshire LEP, it is considered that the higher Experian plus 20% figure from the SHMA should be used so that policies for housing and the economy are aligned (Framework paragraph 158). This would require 839 dwellings a year to be provided.

7.53 What is clear from more recent work and Inspectors’ decisions at development plan examinations is that this simple “demographic” approach, which takes no account of the likely economic needs of the area, will not be found to be “soundly based”.

7.54 Taking account the need to deliver in full the affordable housing needs also indicate support for a higher dwelling provision than that contained in the consultation. This assessment based upon the SHMA work suggest that the level being promoted in this report is of the correct magnitude to deliver the level of affordable housing required.

7.55 For the purposes of future planning for the district, and in light of the approach required to consider other factors relating to the economy, market demand, the delivery of affordable housing and the overriding requirement to plan positively and prevent planning from being an impediment to economic growth then the figure of 839 dwellings a year should be regarded as the target to meet the economic aspirations


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of the District and as such should be used for the purposes of calculating the five year land supply for the District.

7.56 This level of dwelling provision will support employment growth of 10,440 jobs which is an increase of 20% from the Experian projection in order to reflect the Growth point aspirations of the Council.


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8.0 CONCLUSIONS

8.1 It is concluded that the range of dwelling requirements that are being consulted upon are based on out of date evidence and methodology. The approach does not conform to the requirements of the Framework as it is not based upon Objectively Assessed Need and relies upon out of date evidence. All recent evidence clearly points to a much higher level of Objectively Assessed Housing Need especially in the short term.

8.2 The most up-to-date evidence is the 2012 SNPP which takes account of the 2011 census. The housing requirement resulting from these projections has been calculated using the Chelmer Model and the results compare closely to those recently published by the government (2012 Sub National Housing Projections).

8.3 SPRU have suggested that the rate of household formation based on past trends is a too pessimistic response to a housing market which is emerging from recession and that a higher rate of household formation be utilised to provide a 614 dwellings a year for the period 2011 to 2031 from the same 2012 SNPP as this would allow for a moderate improvement in the ability of the population to form households slightly above the 2012 Household Representation Rates. This SPRU would suggest this should be the base projection from which to consider the appropriate level of housing requirement for the local plan in the context of the Framework, including the need to accommodate development to support the local economy and job growth.

8.4 In this context the Guidance is clear that the Council are required to consider increasing housing provision in light of evidence, which suggests an imbalance of job growth and changes to the working age population, as well as responding to other market indicators such as price and affordability. This approach has also been endorsed by the findings of Inspectors at various development plan examinations. It is clear that the demographic approach has to be integrated with the needs of the local economy.

8.5 The impact of increasing the level of dwelling provision to meet the recent Experian employment projections of 8,700 jobs would require some 781 dwellings a year in the period to 2031. This compares to the SHMA’s lower estimate of just 710 dwellings a year to meet the same level of employment growth to 2031. Our critique of the SHMA assumptions is that they are over estimating changes in future activity rates for the population and so our figure should be preferred.

8.6 This level of provision does nothing to address the earlier growth aspirations of the council reflected by the designation of Grantham in the Core Strategy and LEP as a Growth Point.

8.7 If this aspiration is to be met in the period to 2031 and the housing and economic policies are to be aligned as required by paragraph 158 of the Framework then the higher level of job growth in the SHMA is the appropriate target. Therefore to achieve full conformity with the Framework and Guidance our work suggests an average of 839 dwellings per year. Again this figure is higher than the SHMA figure for the same level of job growth which is 783 dwellings (SHMA table 37).

8.8 Turning to the plan period for the Core Strategy, for the period 2011 to 2026 the Framework compliant housing requirement is 825 dwellings a year according to our projections and 898 dwellings a year according to the SHMA.


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8.9 This report has also identified evidence of affordability as well as average house prices being higher than the regional average, and this would support setting the figure higher than that suggested by the recent 2012 Sub National Housing Projections.

8.10 In order to meet the full Objectively Assessed Need for affordable housing as identified in the SHMA but using the methodology suggested in the Warrington Judgement would also require the delivery of some 857 dwellings a year.

8.11 The suggested range in the SHMA of between 660 and 710 dwellings for the period 2011 to 2036 does not even on the SHMA’s own analysis meet the Frameworks requirement for the alignment of economic and housing strategies over the plan period. As such a consistent level of provision would substantially undersupply the level of housing required to support economic growth in the early years of the plan and fail to deal with the backlog since 2011.

8.12 In these circumstances the choice of time period is important as the employment led projection utilising the SHMA’s employment projections decrease substantially after 2026. In line with the assumptions in this report then most robust requirement would be 839 dwellings a year for the purpose of a new local plan to 2031, however given the evidence consideration should clearly be given to delivering a higher rate in the early part of the plan period.

8.13 For the purpose of calculating the five year requirement in the context of the appeal then the shorter time period would be more appropriate this either the immediate period preceding and post the assessment date (i.e. 2011 to 2021) or the period set by the extant plan. Our evidence suggests that this would result in a requirement of 783 to 825 dwellings (10 year and 15 year). The SHMA evidence suggests a Framework compliant requirement of between 994 to 898 dwellings (10 year and 15 year).


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APPENDIX 1: GLOSSARY

ave Average

DCLG Department of Communities and Local Government

HMA Housing Market Area

SKDC South Kesteven District Council

ONS Office for National Statistics

RSS Regional Spatial Strategy

SHMA Strategic Housing Market Assessment

SNPP Sub National Population Projections produced by the ONS


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APPENDIX 2: THE APPROACH TO BE TAKEN TO DEFINE A HOUSING

REQUIREMENT IN DETERMINING A PLANNING APPLICATION IN THE

ABSENCE OF AN UP TO DATE DEVELOPMENT PLAN

A2.1 This appendix summarises the Hunston case and the appeal decisions since that judgement in respect of the calculation of a five year land supply and secondly in terms of considering the Objectively Assessed Need in the development plan context.

Hunston Properties Ltd vs. Secretary Of State for Communities and Local Government & St Albans City and District Council

A2.2 The first decision in this case (High Court of Justice Queen's Bench Division 5th September 2013) concerned the refusal of planning permission for a housing development in the Green Belt the Judge is very clear on the approach that should be taken to the objective assessment of housing needs, which is of relevance in the interpretation of the Framework, both for development management decisions and development plans.

A2.3 In paragraph 20 of the decision the Judge finds that the reasoning of the Inspector in Planning Appeal X1165/A/11/2165846 to be entirely convincing. The Inspector in that appeal is quoted in paragraph 47 of the decision:

"… constraints do not bear upon the actual need for dwellings … the stage at which growth constraints should be taken into account is when assessing how the identified need can be addressed …they cannot reasonably be used … simply to reduce the number of dwellings calculated as necessary to meet housing need".

A2.4 In paragraph 30 the Judge states that the proper course in determining a housing requirement would be;

a. assessing need;

b. then identifying the unfulfilled need having regard to the supply of specific deliverable sites over the relevant period; and

c. then to decide on the policy implications of meeting this need.

A2.5 In the second decision in the Court Of Appeal (Civil Division) on Appeal from The Queen’s Bench Division Administrative Court his Honour Judge Pelling QC found that:

a. An Inspector is not required to undertake some sort of local plan process as part of determining the appeal, so as to arrive at a constrained housing requirement figure (paragraph 26).

b. The Inspector had been mistaken to use a figure for housing requirements below the full objectively assessed needs figure until such time as the Local Plan process came up with a constrained figure (paragraph 26).

c. Self-evidently, one of the considerations to be reflected in the decision on “very special circumstances” is likely to be the scale of the shortfall (paragraph 28).

d. There are other factors including planning policies such as Green Belt, Areas of outstanding Natural Beauty and National Parks that could provide a context for a shortfall and that these may well affect the weight to be attached to the shortfall.


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A2.6 There are of course no such constraints in relation to this appeal.

Post Hunston Appeal decisions

A2.7 In the decision on Land between Leasowes Road and Laurels Road, Offenham, Worcestershire, WR11 8RE (Appeal Ref: APP/H1840/A/13/2203924 the Inspector continued this trend of referencing the most up to date evidence of objectively assessed need.

A2.8 The Inspector highlights, in paragraph 24, that the former West Midlands RS targeted areas with significant amounts of previously developed land in need of regeneration, such as parts of Birmingham, and the other conurbations in the Region were no longer material to the appeal following the revocation of the RS.

A2.9 Paragraph 25 highlights that the Hunston Judgments, the Draft NPPG and the revocation of RS all change the strategic planning backdrop to this appeal and bring to the fore the need for local planning authorities to have a full understanding of housing needs in their area, as required in paragraph 159 of the Framework, and to meet it fully, as required in paragraph 47.

A2.10 In paragraph 32 of the decision letter the Inspector makes reference to the evidence that was also presented to the Inquiry, which used a combination of data appearing to follow the South Worcestershire Development Plan (SWDP) Inspector’s advice, including the use of the latest population and household projections, employment forecasts based on pre-recessions levels of growth, and building in 40% for affordable housing.

A2.11 The Inspector noted that the Council’s housing supply witness, Fred Davies, in cross examination, accepted that the Council had not sought to criticise any part of this analysis. The Inspector noted that whilst these conclusions are yet to be tested at the SWDP Examination, which clearly limits the weight he could give to them, they appeared to confirm the SWDP Inspector’s comment that, as a general guide, the objectively assessed housing need for the plan period is likely to be substantially higher than the 23,200 figure (for the entire South Worcestershire area) which was identified in the submitted plan.

A2.12 In paragraph 34 the Inspector considered the Appellant’s evidence which shows conclusively that the recent significant increase in Wychavon’s average house prices and relatively small proportion of rented properties and low delivery of affordable housing have resulted in an increasingly unaffordable local housing market. These market signals, which were not robustly challenged during the Inquiry, are in line with the Draft NPPG, which states: “The more significant constraints (as reflected in rising prices and rents, and worsening affordability ratio)…the larger the improvement in affordability needed and, therefore, the larger the additional supply response should be”.


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A2.13 The conclusion of the Inspector was:

36. Taking into account all the above considerations, it is my view that the Council’s case, that it has just over 5 years’ housing land, is unconvincing in the light of: (i) the revocation of the RS as a basis for assessing housing need; (ii) the likelihood of an increased housing requirement for Wychavon to emerge during the SWDP Examination; (iii) the over optimism of some of the Council’s assumptions of deliverable housing supply over the next 5 years; (iv) the Council’s ambitious housing targets in relation to its track record; and (v) the evidence of current market signals in relation to housing under provision and in affordability.

A2.14 In summary the Inspector appears to have accepted there may be a justification for a reduced level of housing requirement below the objectively assessed needs but that in a situation where the site itself doesn’t negatively impact upon those constraints that justify a lower requirement then the higher level of need can be given great weight.

A2.15 A further recent appeal decision (23 January 2014) relating to four appeals at Broom Hill, Swanley, Kent (Appeal Decisions APP/G2245/A/13/2195874, APP/G2245/A/13/2195875, APP/G2245/A/13/2197478 & APP/G2245/A/13/2197479 also reflect the weight to be attached to up to date evidence of the objectively assessed housing need even in areas of accepted constraint.

A2.16 In this decision the Inspector found in paragraph 13 that the Core Strategy was formulated prior to The Framework which indicates that local planning authorities should use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area. The Inspector highlighted that the emphasis in The Framework has changed from previous policy and, in their view, this was an important material consideration. In this case the Inspector highlights that there had been no objectively assessed need assessment since the CS.

A2.17 In paragraph 82 the Inspector acknowledged there is a recent current development plan that does not include allocation of this land for housing and which has identified an achievable 5 year housing supply. He noted however that the identification of that supply is not in accordance with the latest advice in The Framework, and in that any case, the limited supply of housing identified was for specific reasons, and development here would not conflict with those reasons, because it would be in the confines of the settlement (Swanley) and not Green Belt land. The Inspector considered that because of the great need for housing and affordable housing in the area, substantial weight should be proportionally attached to the provision of the housing and this justified a deviation from, and addition to, the housing identified in the adopted plan, for all four schemes.

A2.18 These two decisions confirm that substantial weight maybe placed upon the most recent evidence of the objectively assessed need for housing and the ability to address that need in the determination of planning applications.


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APPENDIX 3: THE APPROACH TO OBJECTIVELY ASSESSED NEED FOR

HOUSING BEING ADOPTED IN DEVELOPMENT PLAN EXAMINATIONS

A3.1 The importance of the matters highlighted above have been confirmed by Inspectors’ decisions in the following cases:

East Hampshire

A3.2 The requirement for local planning authorities is to ensure that their plans are based on adequate and up to date evidence and that they should have a clear understanding of the housing needs in their area and how this is to be met. However, the last SHMA was produced in January 2008 and later assessments of need do not provide an update on the full housing needs of the District (Inspector’s letter paragraph 6).

A3.3 As the plan period extended to 2028 the Inspector stated that it was to be hoped that pre-recession projected levels of economic growth would be achieved well before the end of the plan period. However, the Inspector was concerned that the level of housing proposed in the Joint Core Strategy (added to an aging population) would limit the supply of local workers, prejudicing existing businesses and making the District less attractive to new employers, which could also lead to increased levels of in commuting (Inspector’s letter paragraph 8).

A3.4 Again, this emphasises the need for the SHMA to be both up to date and to consider implications beyond the boundary of the district.

South Worcester Development Plan

A3.5 This provides a detailed explanation of the approach that was considered to be required in assessing the objectively assessed housing needs. This included, in Paragraph 44 of his letter, the suggestion that the analysis required in terms of the demographic stage be:

a. carried out using the latest available official population projections,

b. translated into future household numbers using HRR drawn from the 2011-based household projections for the period 2011-2021, the HRR drawn from the 2008-based household projections for the rest of the Plan period.

A3.6 In paragraph 37 the Inspector makes it clear that the demographic assessment of need is the first step in the process, commenting as follows:

However, each of these scenarios is essentially trend-based and does not include the necessary additional step of factoring in the effect of future employment growth on in-migration.


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A3.7 In paragraph 45 of his letter the Inspector states that:

As a first step in this stage, therefore, the Councils will need to satisfy themselves that they have up-to-date and realistic employment forecasts to inform the analysis. This is likely to mean examining and comparing forecasts from more than one source to ensure as far as possible that any they rely on are representative of the likely economic situation over the Plan period.

A3.8 The importance of the economic prospects of the area are highlighted in paragraph 46 of the Inspector’s letter:

Once representative employment forecasts have been obtained, the Councils will need to assess their implications in terms of in-migration. For the purposes of this assessment I would endorse, in principle, NLP’s assumptions about both future falls in local unemployment rates and increases in economic activity among older age-groups in the period to 2020. A similarly realistic assessment will need to be made of any further increases in older people’s economic activity in the following decade.

A3.9 In terms of the evidence that employment growth could be met by assumption including changing the pattern of commuting the Inspector stated in paragraph 49:

Clearly I cannot predict the outcome of this additional work. However, the 2009 CE employment forecasts on which SHMA CS4 was based show levels of employment growth well below any of the more recent employment forecasts provided to the examination. Added to this, the unsupported assumptions used to derive SS2 had the effect of substantially reducing the projected growth in households derived from CS4. As a general guide, therefore, it appears from the evidence before me so far that the objectively-assessed housing need figure for the Plan period is likely to be substantially higher than the 23,200 figure identified in the submitted Plan.

Vale of Aylesbury Plan

A3.10 The Inspector, in finding the duty to co-operate had not been discharged, noted the strong relationship with the neighbouring urban area of Milton Keynes which will continue to be a focus of housing and employment growth, and that the district formed part of the wider housing market Area (paragraph 9). The Inspector also highlighted that:

11. The duty to co-operate is not a duty to agree. … The lack of jointly produced evidence and the fact that a number of other local authorities continue to have concerns in respect of the level of housing provision set out in the Plan are not in themselves reasons to conclude that the Council has failed to comply with the duty. It is the actions of the Council in terms of co-operating to maximise the effectiveness of the preparation of the Plan which are critical to my consideration of the matter.


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A3.11 The Inspector highlighted the lack of consideration of other areas’ needs or consultation with other authorities in the preparation of the original evidence base that lead to the decision on the overall level of housing provision (paragraph 19) and concluded that the extent to which engagement, particularly of the limited form undertaken, could have genuinely influenced the overall level of housing provision appears to have been minimal. The Inspector suggested that the very brief responses of other authorities to the later work, undertaken to rectify the inadequacy of the evidence base, needed to be seen in the context of their understanding of their role in the process. The Inspector noted that there is no record of any substantive engagement with other authorities in relation to the preparation of the evidence base of the objectively assessed need for the district or indeed on the work that considered the wider Housing Market Area (paragraph 20).

A3.12 The Inspector raised the issue of concerns expressed by other councils and in particularly Milton Keynes, with regard to the balance of jobs and housing and the need to plan for the growth of the urban area as an issue that had not been adequately addressed (paragraph 21).

A3.13 In conclusion the Inspector stated:

27. As it stands there are significant issues in terms of potential unmet needs from other authorities and how they will be accommodated. There are particular issues concerning the relationship of Aylesbury Vale to Milton Keynes and its future growth. These issues have been left unresolved. The Council has been aware of these issues from early in the plan preparation process, if not before. There has been a substantial period of time since the duty to co-operate came into force and the NPPF was published. Whilst noting the lack of specific evidence on potential unmet needs from other authorities and accepting that collaboration and joint working is a two way process, it is the Council’s duty, as the authority submitting the Plan for examination, to have sought to address these issues through constructive, active and on-going engagement.

A3.14 Turning the Inspector’s comments regarding the soundness of the plan in terms of housing and jobs, the Inspector again emphasised the need for the strategy to be the most appropriate when considered against all reasonable alternatives and be based on effective cross boundary working (paragraph 30).

A3.15 The Inspector noted that the Council selected a level of housing provision close to the bottom of what had been identified as the range of “objectively assessed need” while the evidence base was still being prepared, and in the context of there being no fundamental environmental or infrastructure constraints to the higher levels of growth (paragraphs 32 and 33). This decision was taken at a time when there was no evidence regarding the potential needs of other authorities (paragraph 39).

A3.16 In terms of detail the Inspector considered that there was insufficient evidence to reduce migration based on the ONS revised Mid-Year Estimates. He also noted that recent migration figures suggested a return to pre-recession levels (paragraph 35).


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A3.17 The Inspector also considered the range of employment projections and assumptions regarding commuting and concluded:

Notwithstanding the difficulties associated with economic forecasting, it is clear that the Council is planning for a level of housing well below that indicated by its own evidence in terms of potential economic growth (paragraph 36)

A3.18 The Inspector highlighted that the Council’s own evidence indicated that significantly more housing than that planned would be required to support the level of jobs growth in the plan and that:

a. There was no substantive evidence that the jobs density are likely to change to the extent required to support the planned level of employment growth without the need for significantly more housing.

b. There was no substantive evidence that patterns of out-commuting are likely to change to the extent required to support the planned level of employment growth without the need for significantly more housing (paragraph 37)

A3.19 The Inspector concluded on the employment housing balance that:

In simple terms there is a clear and substantial mismatch between the level of housing and jobs planned (paragraph 37)

A3.20 In noting that a number of key strategic issues remained unresolved, the Inspector states (paragraph 40) that the:

The contingency approach included in the Plan is not an effective or appropriate way to deal with the issue of potential unmet housing needs from other authorities.

A3.21 The Inspector notes that on a practical level, the only effective response given that the issue would be the overall level of housing provision would be a plan review which would take some time.

A3.22 In paragraph 41 the Inspector states that putting off the resolution of the significant strategic housing issues which need to be effectively resolved as soon as possible through the plan making process, following genuine co-operation and collaboration with other authorities, would be inappropriate.

A3.23 The Inspector goes onto to state that, whilst there are clearly benefits in having an adopted plan as soon as possible, these would not in themselves outweigh the need for that plan to be effective in respect of housing issues.

A3.24 The Inspector concludes:

Taking all of the above into account, I consider that in relation to the overall provision for housing and jobs, the Plan has not been positively prepared, it is not justified or effective and it is not consistent with national policy. It is therefore not sound (paragraph 42).

Slaugham Parish Neighbourhood Plan 2013 - 2031

A3.25 The Independent Examiner’s Report of the Slaugham Parish Neighbourhood Plan states clearly in paragraph 9.10:

Given the rural nature of the Parish and in particular its location within the AON Band the lack of an up-to-date district level local plan and the stage the emerging local plan


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is at, it would be useful for the Parish to make an objective assessment of the level of residential development it needs as part of the neighbourhood planning process.

A3.26 In paragraph 9.11 the Inspector’s claims that the justification as to the level of housing provision selected is unclear to her. In paragraph 9.18 the Inspector stated that she was not in a position to provide alternative wording for this policy as the evidence required (on the local level of housing required was lacking).

A3.27 In respect of the level of housing, the Inspector concluded at paragraph 10.2 that the target set for housing was not based on sufficiently robust evidence, resulting in the “allocation” of potential undeliverable sites. The Inspector concluded that the plan should not proceed to a referendum.

High Court decision: Gallagher Homes Limited - And - Solihull Metropolitan Borough Council

A3.28 This decision confirms the importance of undertaking an up to date assessment of housing need. This high court decision of the Solihull Local Plan (SLP) upheld the challenge that the plan was not supported by an Objectively Assessed Need figure for housing needs for the district as it relied primarily upon the housing target and policy context of the Draft West Midlands Regional Spatial Strategy to justify the requirement.

A3.29 Hickinbottom (Judge) identified the “substantive error” in the Inspector’s decision as “a failure to grapple with the issue of full objectively assessed housing need, with which the Framework required him, in some way, to deal.” He concluded that the plan was not sound because it is not based on a strategy which sought to meet objectively assessed development requirements and was not consistent with the Framework.

A3.30 It is also noted that the requirement to meet objectively assessed need and to integrate employment and housing strategies is not limited to Core Strategies but applies to all development plans.

Conclusion from development plan examinations

A3.31 It is clear that post Hunston appeal Inspectors need to take into account of objectively assessed need for housing. It is also clear that this assessment has to take into account and give weight to up to date information in terms of the needs of both the population and the economy, and to consider the wider evidence of need in the housing market area in terms of other market indicators.