‘Uttlesford United’ wants Local Plan Process Set back by Three Years

The latest move on the Uttlesford Local Plan is inevitable given the failure of their ruse to start a 15 year plan three years in the past, to avoid a new settlement at Elsenham, was ruled out of in a letter from PINS.

Herts and Essex Observer

UTTLESFORD residents have united to fight the district council’s latest proposals to build 10,460 new homes.

The Conservative administration’s latest U-turn is the final straw for protest groups across the authority’s area, who have now banded together and branded the blueprint ” a dismal failure”.

They want the politicians to start afresh and will make a show of strength this afternoon (Friday, November 1) when the Tory cabinet meets in Walden to discuss recommendations that: 2,100 homes should be built north of Elsenham; 400 properties on land west of Great Dunmow and south of Stortford Road; 100 dwellings on a site of the Helena Romanes School, also in Dunmow; and 167 houses at the Ashdon Road Commercial Centre.

The new sites have been earmarked because the Conservatives have finally admitted the Government will never ratify their figures unless they add an extra 2,600 properties to previous estimates and they have ditched their previous view that growth should be dispersed across the main towns and key villages, rather than concentrated in a single new settlement.

Spokesman for the new Uttlesford United Residents Group, Matt North, said: “It is evident to all that whilst Uttlesford needs to plan for significant housing growth the process to date has been dismal. The whole focus seems to be on where to dump houses with little or no thought to the infrastructure needs of current or future residents.

“Decisions are made which don’t appear to be supported by evidence; and most shameful of all is the complete absence of meaningful engagement with town and parish councils or individual residents. It is this latter point which has united groups from across the district who are demanding that Uttlesford begins a new local plan development process.”

The pressure group has already won the support of Walden’s WeAreResidents.org, Save Newport Village, the Joint Parish Councils Steering Group (Save Our Villages) Save Stansted Village and Takeley Parish Council and members are calling on other parish and town councils, groups and individuals from across the district to sign its petition at uttlesfordunitedresidents.org.

Uttlesford United’s main aim is that the local plan development process be stopped and the current draft plan discarded. It then wants a brand new local plan development process to be put in place which meets the following standards:

It is strategic: it works to an agreed set of objectives and reviews options against these objectives. It takes account of existing infrastructure capacity and needs as well as the infrastructure requirements that accompany new households before deciding where to put houses;

It is evidence-based: up-to-date evidence is gathered first before decisions are taken;

It is open and transparent – information is provided in a timely and accessible manner to stakeholders and that all decisions and discussions related to the local plan are open to public scrutiny;

It includes early and meaningful engagement with local organisations and parish/town councils and that concerns and ideas of individuals and organisations in Uttlesford are properly considered;

It is timely – that a robust time-frame for development of the plan is put in place and accountability for meeting the time-frame established. The group also believes a new plan can be done in less time than the current 2015 timescale.

Barminess is Back as Built in Clay Brent Seeks to Ban Fracking

I used to work for Brent and officers and some cllrs worked very hard to dispel the ‘barmy’ image,  This story therefore greatly saddens me.

LGC

Brent LBC could become the first local authority in the country to ban fracking.

The London borough has announced it is looking at whether powers under the Localism or Planning acts will allow it to ban the controversial technique to mine gas.

If successful, Brent LBC will be the first council in the country to ban the process.

Brent LBC leader, Cllr Muhammed Butt said he would ‘do everything legally within my power’ to ensure the borough was ‘a frack free zone’.

‘While there may be advantages to fracking in some parts of the country, it would be dangerous and reckless for companies to start drilling in Brent,’ said council leader, Cllr Muhammed Butt.

‘I will do everything legally within my power to address the concerns of residents and keep Brent a frack-free zone.

‘Councils have significant and widespread powers, which allow us to stand up for the rights of residents. I am determined to use these powers to help reassure people that fracking in Brent will always be a non-starter.’

 

That should be a short and to the point reply from the head of planning.  Ne we have no such powers and a blanket ban on anything without considering the evidence and material considerations particular to any individual case is contrary to planning law and the NPPF.

As an aside the BGS has no evidence that there is any fracking potential in the London basin.

This is the equivalent of Cleethorpes banning the Sex Pistols.  Why would they ever wanted to play there?

Bungalow Bob Should Not be Responsible for Evaluating The Success of New Homes Bonus

Yesterday the Public Accounts Committee drew headlines with its devastating critique of the New Homes Bonus.

It stated that it is

disappointing that after more than two years of the scheme being up and running, no evaluation is in place and no credible data is available to show whether the scheme is working or not.,,,

“The Department has yet to demonstrate whether the New Homes Bonus works. Is it helping to create more new homes than would have been built anyway? Is it the best way for Government to use its limited resources to create more homes where they are needed most?

“Its planned evaluation of the Bonus scheme is now urgent.”

Whilst minister are known for rubbishing select committee reports with flimsy replies we also had the highly unusual intervention of Bob Kerslake.

Sir Bob Kerslake, who is also the permanent secretary in the Department for Communities and Local Government, said he had “significant disagreements” with a public accounts committee report which alleges that the government has no idea whether the new homes bonus scheme is encouraging councils to invest in housing….

Kerslake said in response: “I am disappointed by today’s report and have some significant disagreements with its findings. We have made very clear that our review of the new homes bonus is under way and will be completed by Easter 2014 as we have always promised.

“The whole point of the new homes bonus – which the committee fails to recognise – is to recognise housing growth where it occurs, with money going where those homes are needed most.

But on this point Sir Bob clearly indicate why he is lacking an upstairs.

On the issue of evaluation Edward Page of the LSE have published a piece on a survey of how policy evaluation is often distorted by politicians and civil servants keen to ensure that their policies are judged a success.   He quotes on response

We met regularly with the Head of Research in the [Department] and also occasionally with their policymaking colleagues.  One difficulty with these meetings was that they insisted representatives of the [organisation running programme being evaluated] attended. This made it quite difficult to discuss the report openly because these peoples’ livelihoods depended on the scheme. My part of the report was critical of the [programme] and I thought it inappropriate for the [department] to invite these people along.  I felt it hindered honest and open discussion.

Ideally departments should not be evaluating the success of their own policies, rather this should be done by an independent  body (modelled after the ONS) responsible only to the PAC.  Sir Bobs intervention indicated precisely why ministers and civil servants cannot be trusted to evaluate the success of their own policies, they have an inbuilt research bias.

This is particularly true in this case as he was vaulting the success in terms of the original aim of the NHB – i.e. to channel spending in proportion of the number of homes built, rather than that of a neutral observer, does the policy operate effectively on the margin in ensuring that homes get built that otherwise would not.

Lets look back at the history of the NHB.  It arose following debates several years ago about whether local authorities were disincentivised over granting permission for new homes as the funding formula for local government took a number of years to compensate for additional population and much funding was needed for up front infrastructure.  The incoming conservative administration was influenced by several pamphlets from the policy exchange  which said there were no financial incentives for local planning authorities to housing.  We have come to something when the head of the civil service defends one the the many failed half baked ideas from that dumb tank.

Indeed there is no evidence at all that the NHB increased new housebuilding overall.  Indeed permissions since the introduction of the NHB fell to their lowest post-war level.  Permissions only rose following the punitive ‘build what you like where you like’ regime of the NPPF.

Certainly, in considering revisions or replacements for NHB, there is evidence that the NHB has inncetivised local authorities to bring empty homes into use.  There is much greater activity on this front now and LPAs consider it less politically painful than building new homes  There is also evidence that high growth midlands and northern cities like Birmingham and Leeds have been incentivised to plan positively for housing growth by large NHB windfalls, the policies intention.  But where demand for new homes is greates and supply is in the greatest shortfall there is no evidence at all that, for example, the NHB has had the slightest impact in places like Sevenoaks, Woking or Worthing.  Here housebuilding activity has been continuing throughout the recession but on a small scale whereas  it collapsed in many low value markets.  So even those these authorities may have been building far less than the level of household growth.  So ironically this has led to a crazy net redistribution of grant from pro-growth but deprived authorities to anti-growth authorities suppressing housing need.

Any replacement for the NHB should only apply to authorities with up to date local plans which by definition have a 15 year housing supply.  The money should then be frontloaded and be mainly paid up front on adoption of the plan.  Councils could also have extended prudential borrowing on anticipation of adoption.  A proportion of monies should be directly ringfenced into pools to pay for those items of social infrastructure most sensitive to large scale new housing growth, new schools and new GP surgeries, with a cross departmental fund replacing departmental funds able to be bid for by local partnerships and then distributed to local bidders who would build the facilities.  Funding for infrastructure for very large scale developments such as New Towns should be held by the HCA or a new national infrastructure body, with a presumption that this be devolved to local development corporation partnerships when set up involving local authorities, developers and local communities.    The NHB top slice for neighbourhoods should only apply where there is housing planned over a certain threhsold (such as new housing being more than 20% of a neighbourhoods size over 15 years) as again it is just subsidising housing that would be built anyway.

South Worcs Inspectors Letter – Must Read on Technical Calculation of Housing and Employment

You have to feel sorry for some LPAs.  Some plans you can see being unsound from a mile off.  Others seem to do everything right but stumble because of the technical assumptions made in areas where policy and guidance is not always clear.  most of the issues with the recent Inspector’s letter on the SWDP fall into the latter category.

The inspector found the methodology of the Feb 2012 SHMA sound but some of its data assumptions not.

Notwithstanding the demographic outputs the inspector also found certain supply elements of the final calculation of housing need flawed.

His interim report.

 I consider that there are three fundamental shortcomings in the approach taken in the SHMA. In combination they mean that its assessment of housing need is unreliable and does not provide a sound basis for the planning of housing provision in the Plan area.

First, the SHMA does not use household representative rates [HRR] drawn from the 2008-based DCLG household projections – the corresponding official projections to the 2008 SNPP – or any other  official population or household statistics. Instead, for the purposes  of the SHMA, HRR were recalibrated using the total number of occupied properties in the Plan area in 2011, drawn from Council Tax records. While the objective may have been to calibrate HRR to a fixed dataset, the adjustment introduces a degree of inconsistency
into the household projection process. This is because an individual occupied property, as considered for Council Tax purposes, may contain more than one household as defined in the Census and other official population and household statistics.

Comparison of the Council tax data for occupied properties with household numbers drawn from the 2011 Census – not available until after the SHMA was published – illustrates the point.

Secondly, the job growth figures underlying CS4 were based on employment forecasts for the three South Worcestershire districts produced by Cambridge Econometrics [CE] in 2009. The CE forecasts give annualised employment growth rates well below any of the more recent employment forecasts, by other independent and reputable analysts [Oxford and Experian] , that were provided to the examination. Moreover, the CE forecasts predict a modest decline in employment between 2010 and 2020, in contrast to all the other forecasts which predict reasonably strong growth in that decade.

Oh dear another blow to Cambridge.  Only a few months ago I recommended one group of authorities switch to teh Oxford method.

they were explicitly based on a public sector austerity scenario which attempted to anticipate cuts in government spending, but they have not been revisited subsequently in the light of actual spending plans. Secondly, and perhaps more significantly, they contain an unexplained anomaly in their treatment of agricultural employment

Of course because of continued high unemployment and automatic stabilisers over spending had not fallen despite cuts in front line services.

Thirdly, there is a lack of convincing evidence to support the  assumed increases in older people’s economic participation rates

The assumption that much less inmigration would be needed because of much higher older people participation rates was not accepted.

This is also the first inspectors report I know which accepts the argument made on this site many times that the fall in HH formation in the 2011 based projections does not reflect a fall in housing need because of supressed HH formation.

It seems very likely that the 2011-based projections are, at least in part, reflecting the fact that household formation, especially among the 25-44 age-groups, has been suppressed in the years since the global financial crisis of 2008 by a combination of reduced supply and lower effective demand. Some evidence for this can be found in the 2011 Census, which simultaneously demonstrated that there is a higher population and a lower number of households than had been expected from previous projections. At a national level, the Census
found about 375,000 fewer households in 2011 than had been predicted in the 2008-based household projections.

A recent Town and Country Planning Association paper argues persuasively that just under half that reduction is attributable to suppressed household formation due to the state of the economy and the housing market. The corollary of this is that, under the more favourable economic conditions expected in future years, there will almost certainly be a return to higher rates of household formation. Thus it would be unwise to rely on the household growth rates shown in the 2011-based projections persisting throughout the Plan period….

On the basis of current economic trends, I consider it less likely that, after 2021, household growth rates will accelerate beyond the rates experienced before 2008, as envisaged in NLP’s alternative “partial catch-up” scenarios.

This would be a matter wisely reflected in Beta guidance, as clearly HH growth must be based on ONS projections but also reflect how trends have been affected by suppressed (or indeed induced) household formation at times of unusal strength or weakness in the housing market.  A factor the inspector didnt consider is that in a large housing market such as this HH formation will also switch between the central and outer parts of the HMA is one is significantly more expensive than the other.  We see this for example in Cmabridgeshire where HH formation is not wholly suppressed but simply diverted.

 Nonetheless, the SHMA’s underlying methodology, which involves modelling a trend-based demographic growth scenario and then modifying it to take account of additional in-migration resulting from forecast employment growth, is essentially sound. The inclusion of an assessment of job-related in-migration is particularly necessary in South Worcestershire in view of the well-documented relative ageing of the population over the Plan period.

The inspector found a shortfall of 2,000 in affordable dwellings.  Objectors argued that overall numbers should be subject to a ‘boost’ to allow for this.  SW asked me about this and I replied that this would conflict with the viability tests of the NPPF.  The inspector agreed.

While this is regrettable, on current evidence I see no feasible means of overcoming it through further changes to the Plan. Increasing the proportion of affordable housing required from development beyond a viable level would be counter-productive, while simply increasing the overall housing requirement in proportion to the unmet affordable housing need would result in a substantial surplus of market houses and so would be economically unrealistic.

The long and short of this is that without some form of public subsidy on affordable housing the full need for housing will not be met.

The inspector did not accept the method used to calculate windfalls, bring empty homes back into use and for C£ housing released from people going into elderly care.  I will let readers read these conclusions for themselves.  He also felt a 5% assumed level of non-delivery was acceptable.

Every partnership calculating need should read this interim report.

Labour to Rebrand ‘Localism’ in Planning

Telegraph Isabel Hardman

The Government’s planning reforms provoke still more bitterness. Last week, Sir George Young, the Tory Chief Whip, sneaked into a Westminster Hall debate to watch colleague after colleague bemoan the effects of the current planning settlement, which they warned was not giving local people the power the Conservatives had promised and is instead seeing decisions forced through by the Planning Inspectorate. So great is Tory discontent over this that I hear Labour is developing its own model of localism for its 2015 manifesto, with a new name and a promise to give local people a “real say”. This might have sounded ridiculous from an instinctively centralising party a few years ago, but not any more. The row over planning also symbolises a historical split in the Tory party between free-market liberals who feel the green belt is arbitrary and more development essential, and those small “c” conservatives desperate to preserve views and institutions.

I can predict now that it will be just like the last election.  Whatever the DCLG shadow team promise no shadow chancellor/chancellor would ever permit a policy which would see a collapse in housing allocation/permissions/completions.