A couple of days ago we had a discussion about non-planning in St Albans to which several local cllrs chipped in.
They pointed me to the following document. I can honestly say I haven’t had such a laugh in a long time. No plan based on this has a cat in hells chance of being found sound.
You will search in vein for any justification here of any ‘objective’ identification of housing need, because new post RSS evidence is diddly squat. The joint HMA with other commuter belt authorities takes the RSS figure as its starting point. If any LPA wants to present a new different figure from RSS they will need new research based on the latest household projections. This report shows a lack of understanding of these through failing to appreciate you cant just read off from them a housing target. You need to make a number of other technical adjustments including taking into accounts fricational vacancy rates, level of demolitions and concealed household numbers indicated through housing needs surveys. None the less the household growth figures suggest at least 688 dwellings per annum – so not a hope in infinity for 250 dwellings a year being found sound.
Of course such a figure was not ‘objectively identified’. As locally elected cllrs have stated on here the figure of 100 affordable dwellings a year was plucked from thin air and 50 market dwellings being considered the minimum number to support these once affordable housing policy was adjusted. Therefore it is a classic example of unobjective policy based evidence.
The constrainst side does have some research backing it but it is a classic example of how to badly missaply the concept of ‘ecosystem services’ to planning, a subject I am part of an ESRC project on. The St Albans sponsored project makes the classic bungle, disabused by some University of Reading Research back in John Prescott’s day, of thinking its houses that drink water, houses that drive cars etc. No people do and those people will already be drinking water and already driving cars, so unless you can show that your patch is ecologically unsuited to building houses, compared to everywhere else, you will get nowhere with this line of argument.
The golden mistake however is making a mismash of evidence on need and evidence on capacity Para 15 of the NPPF on this point is quite clear first assess need and then weigh and balance this against evidence of constraints and capacity. The report therefore ends up with a capacity based target rather than showing how capacity might need to constrain the target because of conflicts with the NPPF. This should ideally be done through separate objective expert reports on both it then being a matter of professional and political judgement how to weigh and balence the two issues. As it stands it looks like St Albans has not even begun this exercise despite 28 years of a activity to little end.
Of course on RSS cllrs needed to be careful what they wished for. The RSS diverted growth on Harlow (challenge defeated) and Welwyn (challenge successful) now it needs to show either how it should accommodate the lot of a duty to cooperate mechanism to handle the overspill. Now if they cant voluntarily agree on this we have one of two alternatives, 1) bring back some form of binding sub-regional planning or 2) release so much Green Belt land in South Herts George Osborne might as well have been right as it would be equivalent to redefining the Green Belt out of existence.
St Albans simply to revert to the RSS figure and get on with submitting ASAP, the risk being that a low submission figure will open up a can of worms and potentially lead to far higher levels of Green Belt release. Inspectors will always be reluctant to go for figures far higher than RSS in case it leads to issues of non-conformity. If you leave it too late the RSS may be abolished and then the Green Belt would be in much more peril – so start campaigning to retain the East of England Plan now.