We have paid particular attention to Hertfordshire on this site as I believe it has the highest concentration of lagging local plans in the UK, as well as some of the highest housing needs and greatest Green Belt coverages. A toxic mix.
The Dacorum plan was submitted in June and in November the Inspector submitted a preliminary note - the findings of which will be very predictable to any reader of this blog – especially those in St Albans.
The Council confirmed that in its view 11,320 dwellings over the plan period would meet objectively assessed needs (as referred to in paragraph 14 of the NPPF). However, in my view that figure does not represent full objectively assessed need, rather it represents a level of development that in the Council’s opinion could be satisfactorily accommodated in the Borough without detriment to other policy constraints as set out in the NPPF.
I consider the starting point should be the identification of full‘objectively assessed needs’ (paragraph 47 of NPPF). The most recent CLG household projections 1indicate a need for 13,500 new households in the Borough (about 540 dwellings a year) over the plan period and there is also a significant need for affordable housing. The population projections also identify a significant growth
Whilst I understand the Council’s concerns regarding the robustness of the figures, I am mindful of the advice in paragraph 159 of the NPPF regarding meeting household and population projections.
Having identified the full need, the Council should then have undertaken the appropriate analysis to ascertain whether or not that full need for market and affordable housing could be met, remembering that the objective is to ‘boost significantly the supply of housing’. It may be that the Council would have reached similar conclusions as it has done in relation to the submitted Core Strategy but without a more thorough analysis I cannot be certain that this would have been the case.
I have two specific concerns: the lack of a robust and comprehensive green belt review and the limited emphasis that appears to have been given to the role that neighbouring local planning authorities could play in accommodating some of Dacorum’s housing needs….
With regard to neighbouring local planning authorities making a contribution to meeting the housing needs of Dacorum, this is clearly not a new concept, particularly in terms of St Albans City and District (which is immediately to the east of Hemel Hempstead)….
Whilst it is clear that Dacorum and St Albans have ‘co-operated’, particularly with regard to the joint Area Action Plan, it appears to me that the co-operation was directed more towards securing protection for the land in St Albans District between Hemel Hempstead and the M1, rather than investigating ways in which the area could contribute towards meeting the full housing needs of Dacorum.
The Council will wish to consider the options available to it but one of those options may be to commit to an early partial review of the CS (by way of an appropriate Main Modification), in order to investigate ways of assessing and meeting housing need more fully (taking into account updated household and population projections). Any such partial review would need to consider the identification of a housing target that closely reflects identified need; a thorough review of the green belt boundary (including the potential for safeguarded sites); and the role that effective co-operation with neighbouring local planning authorities could play in helping to meet the housing needs of Dacorum.
This is the point we repeatedly make in this blog, first you identify need, then constraints and come to a view as to whether need can be met in light of national policy. You dont prejudge this in your needs assessment.
Of course if Dacorum is saying that Green Belt constraints mean it cannot accommodate the need it should find out in cooperation with others alternative locations. However if you dont do a green belt review you have nothing to compare with no policy option which an inspector might assess and consider the impact of which unnacceptable.
The last para I quoted from the Inspectors report to my mind is contrary to the NPPF and would likely lead to successful legal challenge. Apart from not considering the +20% rule – If a plan is sound now but will not be in several years (such as having less than a 15 year supply) than an early review is appropriate (many examples of this – see West Berks) however is the annual rate of development so far falls short of need that the plan is unsound now then all an early review will do is allow an unsound plan to be adopted, of course there is dicreation and balance of judgement for marginal cases (again many examples of inspectors being prgamatic where authorities have made positive efforts) but allowing an unsound plan to be adopted is not the intention (indeed is completely the opposite) of the regulations and would in my mind be beyond the reasonablescope of the inspector’s discretion.
Dacorum have published a completely SHMA and trajectory less response.