So What if RSS is Revoked if Inspectors Find the Targets are Too Low

Those local planning authorities hoping that revocation of regional strategies will see relief from high ‘imposed’ housing numbers, and allowing for ‘locally derived’ figures that do not presume pre-GFC levels of growth will get a sharp shock from the preliminary findings of the East Hampshire Local Plan: Joint Core Strategy as reported in Planning.

The strategy seeks to provide 8,500 new homes during the plan period to 2028,…But the inspector’s note said that while the figures conform to the South East regional strategy, evidence submitted to the examination suggests that there is a need for at least 11,308 to 11,770 new homes up to 2028.

He said the council has failed to produce an up to date strategic housing market assessment (SHMA) for the district, which makes it difficult to fully assess housing needs in line with the requirements of the National Planning Policy Framework (NPPF).

The note states

the South East Plan recognises that the number of dwellings allocated is below the forecast growth of households
and states that local planning authorities can test higher numbers through the development plan process (my emphasis)

Further the South East Plan is to be revoked and the National Planning Policy Framework (the Framework) requires local planning authorities 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, as far as is consistent with the policies set out in this Framework’’

The Council  produced SHMAs for South Hampshire in 2005 and 2006 and for Central Hampshire in 2007 and 2008. The last SHMA was produced in January 2008, over 4 years before the submission of the JCS for examination. Later assessments of need have been carried out but they do not provide an update on the full housing needs of the District. I consider this to be a serious shortcoming in the evidence base supporting the JCS and I do not see how I can properly consider whether the Plan meets objectively assessed need without an up to date SHMA.

The inspector continues

I am concerned that the level of housing proposed in the JCS [A low projected economic growth scenario] (added to an
aging population) would limit the supply of local workers, prejudicing existing businesses and making the District less attractive to new employers. It could also lead to increased levels of in commuting.

On affordable housing the inspector states that assuming that most of the backlog would be addressed over the lifetime of the plan would

 consign many in need to a long wait. This is not acceptable and, in my view, the undisputed and urgent need

The inspector did not consider that 60% of the districts being AONB was a reasonable excuse for not having an up to date SHMA.  Those lpas making the same excuse because of high Green Belt coverage (St Albans till last Weds) please take note.

Finally there was no SEA of options to deal with higher levels of growth.


One thought on “So What if RSS is Revoked if Inspectors Find the Targets are Too Low

  1. Hi Richard,

    Below is further to the draft consultation response and FYI.

    Inspectors are faced with a difficult decision on forecast figures – there are the RSS based figures, the adjusted LPA figures and the Mystic Meg figures. Inspectors now appear to be instructed from on high to regard even the RSS figures as too low. Methinks some high-up Government ministers are shareholders in building firms – short term gains versus long term losses.

    It is also evident that Inspectors are equating the high need for more affordable homes being directly linked to the number of non-affordable new homes to be built i.e. an artificially high number of new houses mostly on green fields is the only way to achieve the necessary number of affordable homes. What happened to good old-fashioned direct funding?


    Date: Wed, 5 Dec 2012 08:50:33 +0000 To:

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