Ive been looking at a few of the first consultation from local authorities in the New Local Plans Era, where they set there own targets based on local evidence of need, assuming Regional Spatial Strategies (RSS) are eventually revoked.
Both are consulting on a range of housing figures. Low growth figures, growth figures in line with the RSS and higher growth figures.
Like all local planning authorities they are having to grapple with the 2008 based household projections – released in 2010. Though nationally these are slightly down on the projections on which most RSS was based, the reductions are mainly in on the north of England and in many parts of the Country such as the South East and East of England the numbers are pretty much the same, and in many growth spots considerably higher.
Of course these are projections not policy based forecasts and in translating them into policies many local planning authorities have to grapple with the effects of recession. In some cases estimates of firms such as Cambridge Econometrics suggest a slight fall in housing numbers from RSS figures because of lesser job growth and lesser household formation consequently in the early years of the plan. However it is dangerous to base a plan on the assumption of lower growth assumptions than past ones when national policy is going foresquare towards higher growth assumptions. It is difficult to see any such lowering being found sound by an examination inspector.
There is a great danger here of a statistical error called ‘regression to the mean‘ , this is complicated but basically means than basing a forecast on a small number of years projected forward can distort away from the long term trend as those years could form the outer limits of variation over a cycle rather than the intermediate long term trend. In my view then it is best to assume that the abnormally bad 2007-2012 years will be equally balanced by an equally abnormally good 5 year period sometime later in a 15 year plan span.
What I have found interesting is a number of Green Belt authorities finding that figures assuming the 2008 based HH projections +moderate growth imply significantly more loss of Green Belt than the Regional Spatial strategy. It certainly is the case for Warwick, and the South East with its higher growth forecasts it is a lot more.
Consider the case of Welwyn Hatfield. First two factors that complicate things. Firstly the RSS was successfully challenged because the allocation of additional housing to some towns was not SEAd for alternatives. Hence the increase for the district was deleted, but the Global RSS figure remained unchanged. There are a few towns in this position including Oxford Woking and several Herts Districts. The second complicating factor was the growth of Harlow with the RSS panel report concluding its should grow over the border into St Alban’s District.
Interesting the local MP and housing minister Grant Shapps has stated on 22nd Sept 2010 that if given incentives and without top down targets the District might choose to build more
I came up with a system that gives local people something they really want in return for building more homes. In our case in Hatfield, it’s a new town centre. I think it’s a bigger offer come election time for a politician to say to the public, ‘We’ve rebuilt the town centre,’ than the inconvenience of a few homes over there.”
However on seeing that this would mean building on the green belt he said in March 2011 ‘It’s important to protect the greenbelt and on the whole I don’t support plans to build on this land – and I don’t support those options…” Although he did say this was a generally local decision. However the consultation shows that the only option not involving building on the Green Belt is one which reduces housebuilding from 500 dwellings /annum, as the council was planning for previously, to only 146 homes per annum. So much for localism leading to a surge in house building compared to regional spatial strategies.
Of course the problem is Herts is that the Green Belt was drawn up in the 1980s and with a planning horizon of 20 years the strategic reserve sites are being eaten up. Once all brownfield site has been built on every single additional house will have to go on a green field site.
We can see what this means for Welwyn Hatfield here. I have circled in blue the submitted RSS figure and the higher 2008 based figure. Neither assume maxing out growth of jobs or the additional NPPF 20%. So a figure in full conformity with the RSS could be a lot higher. What is interesting is that by the District’s figure the landtake based on local growth alone is 2.3 times the RSS figure, and would of course be nearly three times larger with the NPPF.
Now doesnt National Policy protect the Green Belt? Doesnt mr Pickles call it ‘inviolable’ – well of course inational policy doesnt use the term ‘inviolable’ for development plans it uses the term ‘exceptional circumstances’ and Mr Pickles has by now approved a number of Green Belt schemes. At EiPs two arguments are likely to be made. Firstly that on the Woking Core Strategy first submission the inspector said as national policy was to increase housebuilding this could count as exceptional circumstances allowing Green Belt loss (im sorry the inspectors letter seems to be no longer online). Secondly because Green Belt boundaries are supposed to be permanent it could be argued that the inner boundaries can no longer fill that requirement as they are drawn too tightly. As a result a number of core strategies are now going on submission proposing green belt reviews on unspecified locations in the third 5 year phase. Green Belt boundaries have been reviewed in this manner for many years, and by doing so they maintain the integrity of the whole concept as a never changing approach to the Green Belt could build up such pressures that some future government might do away with it.
If after NPPF adoption and Localism Bill Royal Assent an LPA proposed a strict approach to the Green Belt this would imply a displacement of growth to outside the Green Belt. Of course the SEA directive will require that LPA to consult on and assess the affected areas, it is blind to local authorities boundaries. In this case where would it presume the displaced growth go, North Herts or Beds beyond the Green Belt? Of course the new d’uty to cooperate’ will require working with those authorities, or else you might not only have an unsound plan you would have an unlawful one.
Actually it does make a lot of sense to have more growth in North Herts/South Cambs than congested South Herts. I have suggested a new town between Ashwell and Morden Station and Royden, and I know David Lock also holds the view that this would be a good site for a third Herts Garden City, accessible by rail to Cambridge and London on largely unconstrained land. Of course such an approach requires some kind of regional or sub-regional plan. The irony is that the review of the East of England Plan was looking at the option of a smaller number of concentrations of growth rather than a scattered approach, but what goes around comes around. Those that argue that Green Belt should be inviolable – a easy political stance – need to put their necks out and say where instead it should go – where should it go Mr Shapps? If not the default position unde the NPPF would mean for your constituency and many other in the South East, East of England and West Midlands, a major increase in loss of Green Belt to Housing. An equally interesting case in Brentwood, Erick Pickles constituency, where the RSS implied significant Green Belt loss, Tonbridge Wells, Greg Clarks constituancy even more so as the last of the strategic reserve land will be used up by the core strategy, all extra growth will eat into it.