SELECTIVE REVIEW OF HOUSING NUMBERS AND OF CORE STRATEGY

You may be interested in the information below in respect of the current position with the Council’s Core Strategy and the potential review of housing numbers that is going to take place.

  • The Core Strategy Selective Review will also look at a number of other policy areas, these are: housing standards, aspects of housing policy, employment and green space.

Key Points

  • The review of the Core Strategy will focus on specific areas and will not therefore be a wholesale review of the document. It seems there is clear justification for the review within the National Planning Policy Framework, which states at paragraph 153 ‘each local planning authority should produce a local plan for its area. This can be reviewed in whole or in part to respond flexibly to changing circumstances.

 

The focus of the selective review is on the following:

 

  • Updating the housing requirement in policy SP6, this could also lead to other revisions to related areas of the plan.  This could impact on the length of the plan and the spatial strategy of the plan.
  • Incorporating the housing standards policy work into the Core Strategy.
  • Updating of wording relating to the Government withdrawal of the Code for Sustainable Homes in 2015.
  • An update to the affordable housing policy to take into account Government policy on starter homes.
  • The population projections have been in decline since the 2008 projection that was used to inform the core strategy. This issue was raised at the Core Strategy Inspection but the inspector chose to emphasise economic growth and the impact of the recession on growth, the thinking being that the downward trend in projections would only be short lived. However the 2014 projections continued the downward trend and it seems all now agree there is a need for a review of the numbers.

 

  • One consequence of the 70,000 target has been a failure to deliver the annual 3660 housing target which has now contributed to the Council not being able to demonstrate a 5 year land supply, which could mean that a number of key housing appeals are lost, Grove Road in Boston Spa being a recent example of this. Of course the housing industry play a part in this as ultimately they control supply of housing through build out rates and commencing building on sites with planning permission.

 

  • In Leeds the outstanding capacity on sites with planning permission is 18,330 units, with 2,170 units under construction and 16,160 yet to start.  There is also capacity for 7,547 units on allocated sites. This therefore contributes to a total outstanding capacity of 25,863 units.

 

  • Delivery rates are not taken into account when assessing housing need.

 

  • A report by Edge Analytics sets out a starting point for housing numbers at 2,600 homes per annum and 41,600 in total (the table below provides more detail). This is a benchmark figure and the report notes that the range for annual delivery is between 3,100 and 4,000 when taking into account factors such as internal migration, and household assumptions. It should be noted that this is still at least 700 fewer houses per year than is in the Core Strategy from 2017/18 to 2027/28 and at most 1600 fewer houses annually.

The new Strategic Housing Market Assessment (SHMA) will factor in the following issues:

 

  • the effects of economic growth (incorporating the Regional Econometric Model forecasts) including analysis of workforce and age of retirement etc.,
  • local demographic trends
  • migration/commuting flows with other areas
  • implications of Brexit on migration
  • backlog of housing current unmet need for affordable housing
  • the number of newly arising households likely to be in affordable housing
  • the relationship between the current housing stock and current and future needs
  • concealed needs
  • student housing needs
  • the specific needs of older people for different types of housing.

The report contains a key table on the demographic projections done by Edge analytics, which is set out below for reference.

  16-year plan horizon
Per year Total
Office for National Statistics (ONS)/Dept. for Communities and Local Government (DCLG) 2008-based benchmark

 

5,600 89,600
Leeds Core Strategy

 

4,375 70,000
ONS/DCLG 2014-based benchmark, with balanced internal migration*

 

4,000 64,000
Regional Econometric Model (REM) Spring 2016, with no change in age-specific economic activity rates, unemployment or commuting*

 

3,600 57,600
ONS/DCLG 2014-based benchmark, with 2008-based household assumptions*

 

3,100 49,600
ONS/DCLG 2014-based benchmark

 

2,600 41,600

*These are relatively crude estimates, provided as part of this pre-SHMA review as guidelines only.

    • So it is through the SHMA Area that the initial work on the review will commence and the emerging picture with that work will reveal the likely size of Leeds’ future housing requirement.
    • Another issue raised in the report refers to the possibility of extending the plan period by a further 5 years so up to 2033. This would enable the current year to run its course with a 3660 annual target and then move into a new period with a new annual housing target, presumably lower than the 4,700 that is currently the case. More detail introduces the possibility of the Site Allocations Plan (SAP) being retained but extended over a longer period so in effect 70,000 houses between 2012 and 2033, this would reduce the annual housing target as it would be over a 5 year longer period.
  • The Core Strategy Review may highlight that the SAP has identified sufficient homes to meet needs until 2033 (five years more than currently). This would be consistent with National Planning Policy expectation for plans to plan for housing delivery to a horizon of at least 15 years where possible (NPPF Para 47). In other words, in the event of lower overall housing requirements, the Council’s SAP will have a longer period to deliver the same level of housing; thus lowering annual targets but allowing for delivery issues to be addressed and monitored.’ Does this suggest a likely direction of travel?
  • Whilst the key area of interest is the housing projections, as noted above the review will touch on other areas of planning policy. A key issue highlighted in the report would be if the plan period were extended and the possible impact this would have on other Core Strategy policy areas. For example policy H7 sets the quantity of accommodation required for gypsy and travellers, would this then need to be reviewed? There are other similar policies such as EC2 and SP6 that deal with quantities of employment land and office space.
  • In terms of other planned revisions to the Core Strategy the housing standards work will be incorporated, meaning that housing developments will be made up of houses that have minimum internal space standards and a minimum proportion of dwellings will be designed to meet accessibility standards.
  • Affordable housing policy will be updated to take account of new national policy particularly around starter homes and an updated assessment of need. With regard to green space policy G4 will also be reviewed to set green space requirements for new developments and also to clarify where off site contributions will be sought through CIL.
  • A number of other more minor adjustments are proposed looking at protection for sites in both shortfall and non-shortfall areas and applying amenity protection to town centres to make it consistent with other policies in the strategy. There will also be a revision to maps particularly in relation to regeneration areas.
  • The report also sets out a likely timetable for the selective review, this is as follows:

 

 

    • Evidence gathering, scoping and early consultation: Spring 2017
    • Drafting the Plan for Publication: Summer 2017
    • Formal consultation (6 weeks) Autumn 2017
    • Consideration of responses: Winter 2017/18
    • Submission with any necessary modifications: Spring 2018
    • Examination: Summer 2018
    • Adoption Winter 2018/19

Commentary

 

News that the Core Strategy will undergo a selective review is clearly positive. If you want a copy of the Edge Analytics report please let me know.