HARTLEY B 004(b)

SSDC LOCAL PLAN 2006-2028 – INDEPENDENT EXAMINATION

ISSUE 4 – DISTRICT WIDE HOUSING PROVISION, INCLUDING AFFORDABLE HOUSING AND ACCOMMODATION FOR GYPSIES AND TRAVELLERS

STATEMENT BY BARRIE HARTLEY – ID REFERENCE 4122433

4.1 Are the housing policies consistent with national guidance and supported by clear and robust evidence? Is the household size figure of 2.1 justified (as used for example in Table 3)?

4.1.1The housing policies are not consistent with national guidance in particular policies relating to rural communities. The evidence provided by SSDC regarding the employment distribution and economic profile of the district is not robust. Data from BRES appears to contradict the council’s indication of balance of employment between Yeovil and the rest of the district. The evidence at (Appendix A) for 2008 and 2009 is an example showing clearly that a greater proportion of the district employment is outside Yeovil.

4.1.2If housing distribution correctly related to the district employment profile (that reflects the higher levels of self-employed in communities outside Yeovil, HM Forces and Agricultural employment) the balance would be 42/43% in Yeovil rather than 49/50% detailed in the local plan.

4.1.3 The issue of the household size figure is one important element in assessing the overall housing requirement. SSDC indicated that it may be higher than 2.1 based on the 2011 census data which shows South Somerset average at 2.27. This was 0.02 above the 2.25 2006 baseline figure for projecting housing requirement and appears to be consistent with ONS UK national evidence[1] showing the average has remained consistent since 2002 rather than falling. The latest England household projections published 9th April 2013[2] confirms a slowing in the rate of decline indicating 2.35 (2016) and 2.33 (2021) while the 2008 data showed 2.25 by 2018 and 2.19 by 2028 from which SSDC took their evidence. The evidence clearly demonstrate the use of 2.1 household size for South Somerset by 2028 is significantly out of date and requires to be amended based on the most up to date data. It is clear a higher figure should be used.

4.1.4For the local plan to be sound a new household size figure in the region of 2.2 by 2028 should be used in economic and population projection calculations.

4.1.4The housing projection figures detailed in Tables 2 and 3 of the Local Plan specify a figure of 2% in communal facilities. This had been reduced from 2.2% in the draft version for consultation. SSDC uses the 2011 Census figure of 2.07% (rounded down to 2%) for persons in communal facilities and project that forward to 2028. This method is unsound and gives an inaccurate future private household population. Evidence indicates the percentage should be 2.4% or higher. SSDC failed to take into account an increase in military personnel residing in Barracks post the Army re-location and the projected increase in the over 65’s requiring residential care which comes from the Projecting Older People Population Information part of Oxford-Brookes University. Appendices B and C show the how the evidence is derived.

4.1.5For the Local Plan to become sound the council should change the percentage in communal facilities to 2.4% from 2% when calculating the future economic and population based housing requirements. The evidence shows the change is necessary and would reduce the housing requirement by 340 dwellings.

4.2 Is the information in the SHLAA soundly based? Have current economic conditions been satisfactorily taken into account?

4.2.1The guidance for preparation of the SLHAA advises land below the five dwelling (0.15 hectare) threshold should not be taken into account. In 2009 over 11 hectares of PDL under the threshold was given detailed or outlined planning permission. This significant amount of land aided the delivery of much needed housing across the district and in rural communities. The council’s rural settlement policy (SS2) actively seeks to restrict housing development and there is significant danger that suitable PDL and green field land below the threshold would come available and planning be refused. The flexibility of a balanced housing distribution policy would be to give genuine choice of location for families to settle and be consistent with the NPPF paragraphs 9 and 10.

4.2.2For the Local Plan to be sound SSDC would need to have policies that reflect the maximising of windfall including positive support for developments on land below the 0.15 hectare threshold indicating the support to communities in helping to deliver positive growth sensitive to location and embracing the holistic thrust of the NPPF.

4.3Is the overall housing provision based on sound assessment of supply and demand? In particular:

a.will the Local Plan meet the full objectively assessed needs for market and affordable housing in the District?

b.are the expectations for delivery of existing commitments reasonable?

c.is the proposed trajectory realistic and can it be delivered?

d.what assessment of PDL has been undertaken? Is the 40% target on such sites a realistic aspiration? and

e.is there sufficient flexibility to deal with changing circumstances affecting phasing and delivery – in particular with regard to the economy and financial constraints, land ownership and infrastructure provision?

4.3.1The proposed housing trajectory for Yeovil detailed at Annex 3 of the Local Plan[3] is of concern. There is nothing in the population or employment projections that indicate an increase in migration or increased reduction in household size over this period that would drive such an increase in housing requirement for Yeovil, particularly during the 2017-2022period. Rate of build projection/trajectory is surely an assessment of need over that period of time and the ability of developers to build at a rate commensurate with need.

4.3.2In the depressed housing market, evidence indicates slowness in bringing large scale key sites forward while the overall requirement is broadly on track. A pick-up in demand specifically for Yeovil will be dependent on the effectiveness of government funding, which is limited, and the drive to bring back empty dwellings and convert under used retail in town centres are potential inhibitors in a tight market.

4.3.2Trajectory in the “Rest of the District (rural settlements)” shows completions 2006 to 2012 averaging 135 per annum yet in 2015-16 it shows just 20 while 2017-2028 it only averages 80. This is not consistent with previous development levels and there is significant risk in a “putting all your eggs in one basket” approach.

4.6Has an assessment of empty homes been undertaken? Has vacant dwelling stock been taken into account in the housing calculations?

4.6.1Paragraph 4.96 of Annex 1 page 66 of 85 of the Local Plan indicates that no allowance would be made for empty homes and stated the information in the Baker Housing Requirement Report of January 2011 remained valid. I fundamentally disagree that this is the case. The evidence at (Appendices D and E) gives a different vacant dwelling scenario and is based on the CTB and from current HSSA guidance. The evidence indicates in excess of 2,600 dwellings were vacant in 2011 and formed approximately 3.6% of housing stock. SSDC recent AMR issued in February 2013 confirms the high level of vacant dwellings and shows the region average was approximately 2.7%. The Baker report appears to be based on outdated 2007 data extracted from HMA assessment Feb 2009. In the foreword of the South Somerset Empty Homes Policy 2010 it is recognised that there were in excess of 2,500 empty dwellings that needed to be reduced. It is clear that SSDC has a strong aspiration to reduce the number of empty dwellings. It is reasonable that SSDC should reduce their vacant dwelling stock to well below the regional average.

4.6.2For the Local Plan to become sound an allowance of up to 800 dwellings should be taken into account which effectively recognises the need for stretched targets and an aspiration to reduce the level of vacant dwellings from 3.6% to 2.5% of housing stock. This should equate to reduction in the new build requirement of 700-800 dwellings which should be an achievable aspiration of the Council and should be reflected in the Local Plan.

Appendix:

  1. ONS Employment distribution data 2008 and 2009 for South Somerset
  2. POPPI – Living in a care home South Somerset data
  3. Assessment of percentage in communal facilities by 2028
  4. Vacant dwellings – South Somerset
  5. GMB analysis of SW region vacant dwellings

1

[1] ONS Families Households tcm77-251353

[2] CLG - 2011 interim Household Projections 2011-2021 dated 9th April 2013

[3] Local Plan Annex 3 Housing Trajectory and Implementation Strategy pages 76 and 77 of 85