The ongoing Wrexham LDP inquiry has been suspended following a preliminary meeting because of concerns about lack of housing. A common event in England but I stand to be corrected a first in Wales.
The Inspector’s preliminary report found that
- A significant shortfall in the supply of housing which, if it were to be addressed, would undermine the strategy of the Plan of confining general housing to within settlement boundaries.
- A failure to take reasonable steps to secure an appropriate supply of affordable housing.
- A lack of suitable provision to meet the needs of the gypsy and traveller community.
- A failure in the Plan to respond to its own evidence base.
- An incoherent use of evidence e.g. short and long term trends used inconsistently to justify low housing figures.
- That cumulatively the changes that would be likely to be required would go beyond those which should be necessary to secure a sound Plan within a timely fashion, taking account of the potential need for an Appropriate Assessment and a Strategic Environmental Assessment/Sustainability Appraisal
The basis of the Council’s housing figures also provides a saluatory lesson for England
The Council’s Background Paper …explains that that the proposed level of housing to be provided by the Plan will provide sufficient homes to accommodate the projected demographic increase (births/deaths and household formation trends) set out in the latest (2008 based) WG projections, and to meet 60% of the projected increase arising from migration trends (both international and from within the UK).
In 2009 The Welsh Government proposed on the basis of the 2006 based HH projections an increase in housing targets from 6,300 set out in the preferred Wrexham County Borough Council Local Development Plan to a revised policy figure of 8,065, and an extra 300 based on 2008 based projections. The Inspector did not accept the maintenance of the lower figure despite all the evidence.
On migration was also an argument that is likely to be played out many times in England with similar conclusions.
The Council contends that a projection of immigration rates based on the past 5 years is unreliable given that the early part of the period saw unprecedented rates of immigration into Wrexham from Eastern Europe, particularly from Poland. The Council predicts that such rates will not occur in the future. However, it was accepted at the hearing that the annual rate of immigration assumed by Welsh Government projections is similar to that identified in ONS figures cited by the Council. The Council also accepted that whilst there was anecdotal evidence that some of the Polish community had moved back to their homeland in recent years there was little reliable information available to suggest that immigration patterns over the Plan period would be significantly different to that predicted in the Welsh Government Projections.
[Wrexham argued] Past rates of in-migration have been unduly influenced by the movement of people from Cheshire West and Chester Council
(CWAC) which is a trend that will not continue. A cornerstone of the Council’s case in seeking to reject the Welsh Government projections is its assumption that past trends of in-migration from within the UK would drop markedly. This contention was based on an anticipated change in planning policy which would see the presently restrictive approach to housing in the neighbouring CWAC being replaced with a strategy that would see, in broad terms, that county meeting its own housing needs. Again no analysis has been made of the proportion of inmigration generated from CWAC as distinct from other neighbouring authorities and further afield. It was accepted that, given Wrexham’s size and range of attractions and facilities, it is reasonable to expect that it would draw in-migrants from other parts of the region. The relatively cheap housing it provides when compared to CWAC could also mean that it may attract in-migrants even if house building rates increase in that County. In any event there are no figures available to suggest the likely effect on in-migration from the envisaged policy change.
This highlights one of the key risks of the NPPF, in areas such as the West Mids and Merseyside districts surrounding the cities were allocated much less than need in regional plans to reinforce policies of urban regeneration with some cities allocated more. The risk now is more pressure on Greenfield sites in counties like Cheshire and Warwickshire.
The Inspector also rejected an argument now being made by many English Authorities that the baseline period for making population projections should be an average of 10 years as opposed to the Welsh Government’s policy of 5 years. Again this is a point that sooner or later the English SoS will have to pass judgement on.
The inspector also rejected the linguistic swamping argument
However, there is no evidence to indicate the nature of any impact that would arise from greater build rates. Moreover, there seems to be no acknowledgement that in this respect the restrictive approach may have a harmful effect on the ability of local residents to find homes that would enable them to continue to reside in their community.
The preliminary report has prompted a political reaction.
CONTROVERSIAL proposals have been unveiled to build 10,000 new homes in Wrexham.
But they have been slammed by community leaders who say it could see the town’s population swell by thousands and put huge pressure on already overstretched services.
Wrexham Council intends to build 8,000 new homes in the county as part of the local development plan running until 2021, but the Cardiff-based Planning Inspectorate has advised the authority to increase that figure by another 2,000.
Marc Jones, Plaid group leader, said: “Wrexham is already over-developed and these plans would see the town’s population surge by as much as another 26,000.
“We need to put the needs of our communities before the demands of housing developers.”
Cllr Arfon Jones said: “We believe the current housing numbers in the LDP are already too high and an additional 2,000 homes will clearly have a hugely detrimental impact locally…
A petition against the proposal and asking for the plans to be recalled and redesigned based on genuine local need has now been lodged by Plaid Cymru with the Government’s petition committee.
Mark Pritchard, leading member for planning and housing, believes the advice given by the inspectorate was based on out of date figures and vowed the council would not be bullied into agreeing the inflated figure.
He said: “The inspectorate’s proposal is based on growth from 2003-08 and is not an accurate representation of the housing market and the economy at the moment.
“We would need to free up more land and the public has made it very clear it doesn’t want to lose any more green space.
“To bend to the inspectorate would be undemocratic and we certainly won’t be bullied into it by the inspectorate or the Government.”
Pol Wong, a member of Deffro’r Ddraig (Wake the Dragon), a movement which challenges housing developments the group believe threaten communities, said: “This proposal will damage the environment, the community and our heritage and identity….
But a spokesman for the Welsh Government claims the inspectorate’s recommendations were just guidelines, not demands.
“All local authorities have access to the methodology and data enabling them to formulate their own level of housing provision.
“The Welsh Government does not dictate to local authorities on housing provision – this is a matter for local authorities and communities to determine.
“All members of the community are able to express their views on the LDP and can make their views known to an independently appointed inspector who will consider any concerns.”…
The Planning Inspectorate for Wales cited concerns over an apparent under-provision of housing in the plan for why the proceedings were frozen until after a meeting with the council on February 23.
As you can see the argument has a decidedly nasty anti-English tone.
Unless Wrexham wants to install border checks and pass controls it needs to get on and allocate the housing its own population badly needs.