Object

Representation ID: 60197

Received: 29/07/2013

Respondent: Gladman Developments

One of NPPF key changes relates to the need to "significantly boost the supply of housing" and this should be reflected in the plan making process.

What is clear from significant experience of involvement in the Local Plan process since introduction of NPPF is that many local authorities have not fully addressed its requirements when preparing their Local Plans and this has led to significant concerns being expressed by Inspector's on the soundness of their plans in their current format.

The main concerns centre upon the requirement in the NPPF to "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" (P47).

The process of undertaking an objective assessment is clearly set out in the Framework principally in P14, P47, P152 and P159 and should be undertaken in a systematic and transparent way to ensure that the plan is based on a robust evidence base.

The starting point for this assessment -to have a clear understanding of housing needs in their area -involves the preparation of a SHMA working with neighbouring authorities where housing market areas cross administrative areas.

The SHMA s[should] identify "the scale and mix of housing and the range of tenures that the local population is likely to need over the plan period which:
* Meets household and population projections taking account of migration and demographic change;

* Addresses the need for all types of housing including affordable housing and the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities, service families and people wishing to build their own homes); and

* Caters for housing demand and the scale of housing supply necessary to meet this demand."

Key points that are worth noting from the above is that the objective assessment should identify the full need for housing before the Council consider undertaking any process of assessing the ability to deliver this figure.

In addition,P159 specifically relates to catering for both housing need and housing demand within the authority area.

Any assessment of housing need and demand within a SHMA must also consider the following factors; falling household formation rates, net inward migration, the need to address the under provision of housing from the previous local plan period, the preliminary results of the Census 2011, housing vacancy rates including the need to factor in a 3% housing vacancy rate for churn in the housing market, economic factors to ensure that the economic forecasts for an area are supported by sufficient housing to deliver economic growth, off-setting a falling working age population by providing enough housing to ensure retiring workers can be replaced by incoming residents, addressing affordability and delivering the full need for affordable housing in an area.

A majority of the SHMAs that were prepared under the current guidance on SHMA preparation are not NPPF compliant and do not consider the full range of factors that are outlined in P159.

To avoid these issues at Examination, SHMAs should be updated to take account of the NPPF and ensure plans are based on robust and up-to-date evidence.

Indeed, the Government have noted the deficiency in SHMAs and are updating the guidance on SHMA preparation to fully reflect the guidance given in the Framework.

Following the exercise to identify the full, objectively assessed need for housing in an area, the local planning authority should then seek to undertake the assessment outlined in P152 of the Framework.

This statement clearly sets out that local planning authorities should seek to deliver the full, objectively assessed need and that this should be tested through the evidence base.

Only where the evidence shows that this is not achievable should they then test other options to see if any significant adverse impacts could be reduced or eliminated by pursuing these options.

If this is not possible then they should test if the significant adverse impacts could be mitigated and where this is not possible, where compensatory measures may be appropriate.

The final stage of the process is outlined in P14 and involves a planning judgement as to whether, following all of the stages of the process outlined above, "any adverse impacts of meeting the objectively assessed needs 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."

The final part of this sentence refers to footnote 9 which sets out the types of policies that the Government consider to be restrictive.

Although this list is not exhaustive it is clear that local landscape designations, intrinsic value of the countryside, the character of areas, green gaps etc are not specifically mentioned as constraints.