1 What Are the Objectively Assessed Needs for Housing in Stroud District? Statement of Common Ground: Summary of Questionnaire Results Background The Stroud District Local Plan was submitted to the Planning Inspectorate in December 2013. Examination hearing sessions dealing with housing requirements were held in April 2014. The Inspector’s Stage 1 initial conclusions were published in June 2014. The Inspector concluded that further work was necessary to ensure that a soundly based objective assessment of housing requirements has been undertaken. The District Council commissioned Neil McDonald (NMSS) in July 2014 to undertake a study of the objectively assessed needs for housing in Stroud from first principles. In response to a query from a hearing participant, the Inspector asked the Council to consider holding a technical workshop with representors who challenged the objective assessment of housing need, in order to try to narrow the issues in dispute and prepare a Statement of Common Ground identifying areas of agreement and disagreement. This may assist in establishing the respective positions of the various parties before any further hearing sessions resume. On 14 October 2014, a technical workshop was held in the Council Chamber, Ebley Mill, Stroud. A draft Executive Summary and presentation slides were circulated in advance of the workshop on 10 October 2014. Participants asked questions and gave views during the workshop and were given until 24 October 2014 to write in with further comments and queries. Five responses were received. Following the workshop, Neil McDonald completed his final report taking into account views expressed during and after the workshop. The final report was sent to representors on 5 November 2014. Statement of Common Ground The District Council prepared a focused questionnaire which was sent to representors on 5 November 2014 for completion and return by 26 November 2014. The intention has been to compile a factual Statement of Common Ground between the Council and representors, identifying the areas of agreement and disagreement. The following sections set out the questions asked and a factual summary of the responses received. Appendix 1 sets out the responses received in their entirety. It will be for the Inspector to seek clarification of positions through the future hearing session on housing requirements scheduled for 29 January 2015. Stroud District Council, 12 December 2014
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What Are the Objectively Assessed Needs for Housing in Stroud District?
Statement of Common Ground: Summary of Questionnair e Results
Background
The Stroud District Local Plan was submitted to the Planning Inspectorate in December 2013. Examination hearing sessions dealing with housing requirements were held in April 2014. The Inspector’s Stage 1 initial conclusions were published in June 2014. The Inspector concluded that further work was necessary to ensure that a soundly based objective assessment of housing requirements has been undertaken.
The District Council commissioned Neil McDonald (NMSS) in July 2014 to undertake a study of the objectively assessed needs for housing in Stroud from first principles.
In response to a query from a hearing participant, the Inspector asked the Council to consider holding a technical workshop with representors who challenged the objective assessment of housing need, in order to try to narrow the issues in dispute and prepare a Statement of Common Ground identifying areas of agreement and disagreement. This may assist in establishing the respective positions of the various parties before any further hearing sessions resume.
On 14 October 2014, a technical workshop was held in the Council Chamber, Ebley Mill, Stroud. A draft Executive Summary and presentation slides were circulated in advance of the workshop on 10 October 2014. Participants asked questions and gave views during the workshop and were given until 24 October 2014 to write in with further comments and queries. Five responses were received.
Following the workshop, Neil McDonald completed his final report taking into account views expressed during and after the workshop. The final report was sent to representors on 5 November 2014.
Statement of Common Ground
The District Council prepared a focused questionnaire which was sent to representors on 5 November 2014 for completion and return by 26 November 2014.
The intention has been to compile a factual Statement of Common Ground between the Council and representors, identifying the areas of agreement and disagreement.
The following sections set out the questions asked and a factual summary of the responses received. Appendix 1 sets out the responses received in their entirety.
It will be for the Inspector to seek clarification of positions through the future hearing session on housing requirements scheduled for 29 January 2015.
Stroud District Council, 12 December 2014
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Summary of Questionnaire Responses
A. Population Forecasts:
The report takes as its starting point the populati on estimates from the interim 2011 based sub national population projections for England (2011 SNPP) and the 2012 sub national population projections for En gland (2012 SNPP). The report concludes that the 2012 SNPP, with due allow ances, should generally be adopted as the more reliable projection.
Do you agree with this approach? Yes/No
Yes Conditional Yes No No Comments Bruton Knowles on behalf of the Pullen Family - Rep 44
Aspect360 on behalf of the Hardwicke Court Estate - Rep 125
DLP Planning on behalf of Hallam Land Management (DLP) - Rep 75
Origin3 on behalf of Taylor Wimpey - Rep 59
Dursley Town Council (Dursley TC) - Rep 121
RPS on behalf of Redrow Homes Ltd – Rep 125
Don’t Strangle Stroud, Eastington Parish Council in association with Strategic Planning Alliance (DSS/EPC) - Rep110
Home Builders Federation (HBF) - Rep 50
Keep Eastington Rural (KER) - Rep 144
Pegasus Group on behalf of Robert Hitchins Ltd - Rep 109
Regeneris
Consulting on behalf of Gladman Developments - Rep 64
Reason for Conditional Agreement:
• Concern is expressed at the subjective wording of the statement for inclusion in a Statement of Common Ground but the 2012 SNPP are accepted as the starting point for determining the Objectively Assessed Need (OAN) for Stroud. [Aspect360, RPS]
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Reasons for disagreement:
• Agree the 2012 SNPP is the appropriate starting point, but disagree with the ‘due allowances’ and therefore the outcome. [DLP]
• The ‘due allowances’ are not valid. [DSS/EPC, KER]
B. Components of Change:
The report examines data relating to various compon ents of change - Births, Deaths, UK inflow, UK outflow, International migrat ion in and international migration out.
Births:
The report concludes that the 2012 based projectio ns are a better basis for forecasting future births than the 2011 based proje ctions.
• It is queried whether the population profile has been used directly, or whether the fertility rates have been used and applied to a base population profile? [Aspect360, RPS]
• It is suggested that age specific fertility rates are integral to establishing revised population projections, to that of the baseline 2012 SNPP. [Aspect360, RPS]
Deaths:
The report concludes that there is no reason to que stion this aspect of the 2012 based projections.
• It is queried whether actual projection data or age specific mortality rates have been used? [Aspect360, RPS]
UK Inflows and UK Outflows
The report adjusts UK inflows and outflows based on the ratio of the average annual flows over a 10 year period 2002 – 2012 to t he flows over the period 2007- 2012, rather than the 2012 based projections which reflect a 5 year trend 2007-2012.
Do you agree with this approach? Yes/No
Yes No No Comment Aspect360 DLP Origin3 Bruton Knowles DSS/EPC Dursley TC KER HBF Pegasus RPS Regeneris
Reasons for disagreement/ suggested alternative app roach:
• Suggested approach - Model the level of total net in migration as being 1,100 to 1,400 persons a year based on the outputs of the accepted Chelmer Model meeting the growth in labour force for the period 2014 – 2031 of between 2444 and 4403 persons (CE and OE projections page 76).[DLP]
• Returning to trend, a lower population projection should be used, deflating the housing requirement, and reducing the OAHN by 50 houses.[ DSS/EPC, KER]
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International Migration Flows
The report concludes that there is no reason to que stion this aspect of the 2012 based projections.
Do you agree with this approach? Yes/No
Yes No No Comment Bruton Knowles Aspect360 Origin3 DLP RPS DSS/EPC Dursley TC HBF KER Pegasus Regeneris
Reasons for disagreement/ suggested alternative app roach:
• The 2012 SNPP is considerably underestimating the level of international migration. [Aspect360, RPS]
• A sensitivity test of increasing international migration proportionally to reflect recent net migration should be incorporated. [Aspect360, RPS]
Unattributable Population Change (UPC)
The report includes the UPC for Stroud (for the per iod 2001-2011) in the calculation.
Do you agree with this approach? Yes/No
Yes No No Comment Aspect360 DLP Origin3 Bruton Knowles DSS/EPC Dursley TC KER HBF Pegasus RPS Regeneris
Reasons for disagreement/ suggested alternative app roach:
• The use of the 2012 SNPP does not require any adjustment for UPC. [DLP, DSS&E, KER]
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• Removing the UPC for Stroud from the calculation reduces the OAHN by 200 houses. [DSS/EPC, KER]
C. Estimate Population
The report estimates an increase of 14,100 people i n Stroud in the period 2011-2031 (or 16,700 people in Stroud in the period 2006 -2031).
Do you agree with these figures? Yes/No
Yes No No Comment Bruton Knowles Aspect360 Origin3 Dursley TC DLP HBF DSS/EPC Pegasus KER Regeneris RPS
Reasons for disagreement/ suggested alternative app roach:
• Unable to agree a figure without clarification of the above issues. [Aspect360, RPS]
• Based on the outputs of the Chelmer Model using the 2012 SNPP, the employment projections of an increase in jobs of between 2,444 and 4,403 jobs would require a population growth of between 19,338 and 22,452 persons. [DLP]
• There is no evidence for increasing the ONS projected figure of 13,600. [DSS/EPC, KER]
D. Household Formation Rates
The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are half way between the 2008 an d 2011 based rates. Thereafter household formation rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups. Do you agree with this approach? Yes/No
Yes No Bruton Knowles Aspect360 Dursley TC DLP DSS/EPC HBF KER Origin3
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Yes No Pegasus RPS Regeneris
Reasons for disagreement/ suggested alternative app roach:
• This is a significant issue and the approach requires further consideration and discussion amongst the interested parties and with the Inspector. [Aspect360, RPS]
• HFR for all age groups should be modelled to improve affordability and accessibility, and increase opportunities for home ownership. [DLP]
• The approach overestimates the OAHN by 250 houses. [DSS/EPC, KER] • Further sensitivity testing should be undertaken for assumptions on:-
i) A full return to trend, ii) A blended rather than mid-point approach. [HBF]
• A greater alignment with the 2008 headship rates should be used, until more reliable data becomes available which references a longer term trend. [Origin3]
• As a minimum, a consistent full return to trend (rebased to take account of the 2011 Census) should be used for all age groups in order that the negative trends experienced during the recession are not planned for. [Pegasus]
• As a minimum, the approach should assume full return to trends for those aged 25 to 34 in Stroud. Applying full return to trends for this age group would increase the OAN purely on a demographic basis by around 30 dpa to 460 dpa.[Regeneris]
E. Empty and Second Homes
The report includes an allowance of 3.96% for empty and second homes
Do you agree with this figure? Yes/No
Yes No Reasonable Aspect360 DSS/EPC Origin3 Bruton Knowles KER DLP Dursley TC HBF Pegasus RPS Regeneris
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Reason for disagreement/ suggested alternative appr oach:
• The 3.2% figure previously presented by Stroud District Council is informed by more up to date information.[DSS/EPC, KER]
F. Housing Needed from Demographic Calculations
The report states that 8,700 additional homes will be needed 2011-2031 (10,400 additional homes for 2006-2031) based on demographi c based calculations
Do you agree with this figure? Yes/No
Yes No Bruton Knowles Aspect360 Dursley TC DLP DSS/EPC HBF KER Origin3 Pegasus RPS Regeneris
Reasons for disagreement/ suggested alternative app roach:
• The assumptions that have been used in arriving at the demographic OAN are not fully agreed. In particular Headship Rates. [Aspect360, HBF, Origin3, Pegasus, RPS]
• The Chelmer Model based on the 2012 SNPP suggests a slightly lower requirement of 8,500 dwelling or 425 dwellings a year. This does not model the higher levels of migration over the 5 year period or the increase due to the unattributed population change. [DLP]
• The correct (ONS – advised) demographic based calculation would be -8,200 [DSS/EPC, KER]
• As a minimum, suggest that for those aged 25 to 34 there should be full return to trends by 2031, adding 20 to 30 dpa to the base demographic OAN. [Regeneris]
G. Market Signals
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
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Yes No Bruton Knowles Aspect360 DSS/EPC DLP Dursley TC HBF KER Origin3 Pegasus RPS Regeneris
Reasons for disagreement/ suggested alternative app roach:
• The 2014 Strategic Housing Market Assessment (SHMA) published by Stroud District, indicates that the scale of key housing market gaps in Stroud is significant, and that housing market signals justify uplift. [Aspect360, RPS]
• There has been persistent under provision against actual need since the 1990s.[DLP]
• The market signals on house prices and rents in Cotswolds and on affordability in Forest of Dean suggest that an upward adjustment to OAHN is required. [HBF]
• The evidence suggests that there should be some recognition of market signals within the OAN.[Origin3, Pegasus]
• Argue strongly for the use of “undiluted” 2008 long term trend household formation rates. [Regeneris]
H. Under Supply
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
Yes No No Comment DSS/EPC Aspect360 Origin3 Dursley TC Bruton Knowles KER DLP HBF Pegasus RPS Regeneris
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Reasons for disagreement/ suggested alternative app roach:
• The evidence available to the Inspector, reference appeal decision APP/C1625/A/11/2165671, demonstrates that the Council has persistently under-delivered against local housing need, and this component of market signals justifies uplift. [Aspect360, RPS]
• The housing figures need to be increased by at least 5% in the first five years. [Bruton Knowles]
• When considering future levels of provision, including those higher levels required to meet economic projections, historic undersupply adds considerable weight to the higher of these projections. [DLP]
• At least a further 400 homes should be provided to address the unmet need arising from previous under-supply in Stroud. [Pegasus]
I. Concealed Families
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
Yes No No Comment Bruton Knowles Aspect360 Origin3 DSS/EPC DLP Dursley TC HBF KER Pegasus Regeneris RPS
Reasons for disagreement/ suggested alternative app roach:
• Uplift is required to the base demographic scenario on the basis of all affordability components, including Concealed Families. [Aspect360, RPS, Pegasus]
• Draw attention to the need to address the considerable growth in the number of unrelated adults sharing accommodation as a consequence of the long term worsening affordability over the past two decades. [DLP]
J. Overcrowding
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
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Yes No No Comment Bruton Knowles Aspect360 Origin3 DSS/EPC DLP Dursley TC HBF KER RPS
Pegasus Regeneris
Reason for disagreement/ suggested alternative appr oach:
• Uplift is required to the base demographic scenario on the basis of all affordability components, including Overcrowding. [Aspect360, DLP, RPS,]
K. Affordable Housing
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
Yes No DSS/EPC Aspect360 Dursley TC Bruton Knowles KER DLP HBF Origin3 Pegasus RPS Regeneris
Reasons for disagreement/ suggested alternative app roach:
• Uplift is required to the base demographic scenario on the basis of all affordability components, including Affordable Housing. [Aspect360, RPS]
• The extent of the affordable housing requirement is so substantial that there is a case for extending the overall requirement to allow for new sources of supply to bring forward additional affordable homes.[Bruton Knowles, Regeneris]
• The latest SHMA suggests a requirement of 477 affordable dwellings a year (Table A5.1 Housing needs assessment model for Stroud) and has to be a consideration in determining the overall level of housing need in the District. [DLP]
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• The SHMA should make some allowance for structural change in the housing market, including increasing the supply of affordable housing and the effect this will have on the demographic based estimate.[Origin3]
• An up-to-date assessment of the objectively assessed need for affordable housing is required. However, the affordable need identified in the now out-of-date SHMA could be met by providing for a minimum of 10,700 homes (plus historic unmet needs of approximately 400 dwellings needs) assuming 30% of delivery is affordable. This will increase once the required assessment is undertaken, but provides a useful indication for now. [Pegasus]
L. Supporting Economic Growth
Economic Forecasts
The report uses the latest 2014 economic projection s from two forecasters – Cambridge Econometrics and Oxford Economics.
Do you agree with this approach? Yes/No
Yes Parti al Yes No Bruton Knowles Regeneris Aspect360 Dursley TC DLP Origin3 DSS/EPC HBF KER Pegasus RPS
Reason for partial agreement:
• Concerned with how the forecasts have been used and interpreted with regard to reviewing past trends and focusing on the downsides of the employment forecasts rather than providing a balanced assessment. [Regeneris]
Reasons for disagreement/ suggested alternative app roach:
• Economic scenarios should also use Nomis, for past evidence, and the Strategic Economic Plan (SEP) of the Gloucestershire Local Economic Partnership ( LEP). [Aspect360, RPS]
• Future employment growth should also utilise employment forecasts produced by Experian. [DLP]
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• Question how the South West regional data from CE has been ‘normalised’ for Stroud and why the more accurate, Stroud specific data from OE has not been used. [DSS/EPC, KER]
• Consideration should also be given to the inter-relationship between OAHN and the Gloucestershire LEP SEP. [HBF, Pegasus]
Economic Activity Rates
The report suggests that in estimating the labour f orce and hence housing implications of the econometric projections, econom ic activity rate assumptions consistent with the projections being i nterpreted should be used.
Do you agree with this approach? Yes/No
Yes No Bruton Knowles Aspect360 Dursley TC DLP Pegasus DSS/EPC HBF KER Origin3 RPS Regeneris
Reasons for disagreement/ suggested alternative app roach:
• The Council should set out what it considers are realistic economic activity rates across all age cohorts of its population projections and use those consistently in all sensitivity scenarios. [Aspect360, RPS)
• Include a table of proposed changes to activity rates, as a better reflection of the long term levels of activity as a result of pension age changes. [DLP]
• The approach ignores Stroud specific data. { DSS/EPC] • Inadequate explanation of the methodology behind this approach. [KER] • Request clarification of the economic activity rates used for the over 60’s.
[HBF] • Using the Gloucestershire figure of 6.1% - 6.2% appears a more reliable and
consistent approach. [Origin3] • A more robust approach is to apply plausible increases in economic activity
rates (based on national view of increases by age group) to the forecasts population in Stroud, to see what for a given population rise is the likely future workforce. This can then be compared to plausible employment forecasts to see what the implications for housing are. [Regeneris]
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Jobs Assessment Period
The report assesses how many homes will be needed t o support projected increases in jobs for the period 2014-2031.
Do you agree with this approach? Yes/No
Yes No No Comment Bruton Knowles Aspect360 Origin3 Dursley TC DLP DSS/EPC HBF KER Pegasus RPS Regeneris
Reasons for disagreement/ suggested alternative app roach:
• The period for job forecasts to inform local plan housing need should be based upon the Plan period from 2011. [Aspect360, RPS]
• The projections should also embrace the higher employment led forecasts for the period 2011 to 2031. [DLP]
• It is inappropriate to project economic growth over such a long timescale. A review date should be planned now, following the next census. [DSS/EPC, KER]
• Query why the jobs assessment period is different to the period for the assessment of OAHN? [HBF]
• Considering job growth from 2011 – 2014 may have demonstrated an additional need for housing. [Pegasus]
• Ignoring the jobs rise 2011 – 2014 would be a serious flaw: performance in 2011 to 2014 and subsequently is intimately linked. [Regeneris]
Interpreting the Economic Forecasts
The report suggests that a reasonable allowance for additional housing to support economic growth would be for Stroud, Cotswo ld and Forest of Dean to provide between them for half the additional hom es which the CE analysis suggests might be needed across Gloucestershire i.e . 2,700. If these are allocated in line with the relative housing numbers suggested by the CE analysis Stroud would provide 800 additional housin g (rounded).
Do you agree with this approach? Yes/No
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Yes No Bruton Knowles Aspect360 Dursley TC DLP DSS/EPC HBF KER Origin3 Pegasus RPS Regeneris
Reasons for disagreement/ suggested alternative app roach:
• The full CE evidence should be used from the year 2011 and a “policy off” position adopted in the assessment of OAHN: assumptions in respect of accommodating only half of the CE projection based upon the LEP position is a ‘policy on’ based assumption. [Aspect 360, RPS]
• The approach adopted by the report applies a policy decision not to meet the higher levels of housing growth required to meet the higher economic projections contrary to the Framework and OAN which requires the OAN to reflect the needs of the economy in terms of the policy off position. The level of dwellings that would actually be required to meet the projected level of employment growth is shown by the Chelmer Model. [DLP]
• The approach ignores the OE analysis for Stroud, fails to provide evidence for the number of jobs proposed and has not been endorsed through the Duty to Cooperate. The approach is also in direct conflict with the draft plan policy to reduce out commuting. [DSS/EPC, KER]
• The proposal to use only half the additional homes identified from the CE analysis is an arbitrary choice. [HBF]
• In the case of uncertainty, a precautionary approach should be taken to plan for the full objectively assessed level of growth. There is a realistic prospect that CE’s assessment of needing significantly more housing is correct and in the context of a growth agenda this should be taken as the starting point for planning purposes. [Origin3]
• The suggested revised distribution of OAN within the HMA to support economic growth would need explicit agreement from the JCS authorities that the JCS area would deliver an additional 2,700 homes to respond to the displaced economic needs of Stroud, Cotswold and the Forest of Dean.[Pegasus]
• Unclear how and why the authors have arrived at the 800 adjustment for Stroud: Based on the CE forecasts the adjustment should have been1,800 or increasing the 20 year OAN to 525 dpa - The Report needs to clarify: i) Exactly how the authors have calculated the extra housing need for “surplus” jobs over what the base labour requirement is for Stroud (Figure 40)
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ii) The assumed relationship between extra jobs and extra labour force, population and houses. [Regeneris]
M. Other Matters
Other factors which should be taken into account in identifying an OAHN for Stroud:-
• It would seem prudent to reflect the need to remedy poor past performance, affordable needs and windfall reductions by adding 20% to the first 5 years of the overall current projected requirement of 11,200 i.e. to increase to the total to 11,650, effectively adding one year’s requirement as flexibility. [Bruton Knowles]
• On the current evidence base we would suggest that the full objectively assessed need for housing taking into account improvements to the economy and changes to the pension age would require a dwelling provision of between 11,218 and 12,393 (2011 to 2031) or 561 to 620 dwellings a year. [DLP]
• The elderly population should be taken into account with respect to C2 housing: This amounts to 328 fewer houses, and 722 additional care home beds. [DSS/EPC, KER]
• The OAHN should also give consideration to the distribution of housing needs across the Gloucestershire HMA so that no unmet needs arise because an individual LPA is proposing a housing requirement in its plan below OAHN. [HBF]
• There is no objective assessment of need from 2006 to 2011 (the base date of the national household projections). [Pegasus]
• Setting an OAN from 2006, which is now 8 years ago, does not make sense: 2011 (as the JCS) is a more sensible starting point. [Regeneris]
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APPENDICES - Responses Received
Page Appendix 1: Aspect360 on behalf of the Hardwicke Court Estate
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Appendix 2: Bruton Knowles on behalf of the Pullen Family
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Appendix 3: DLP Planning on behalf of Hallam Land Management
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Appendix 4: Don’t Strangle Stroud and Eastington Parish Council in association with Strategic Planning Alliance
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Appendix 5: Dursley Town Council
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Appendix 6: Home Builders Federation
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Appendix 7: Keep Eastington Rural
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Appendix 8: Origin 3 on behalf of Taylor Wimpey
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Appendix 9: Pegasus Group on behalf of Robert Hitchins Ltd
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Appendix 10: RPS on behalf of Redrow Homes Ltd
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Appendix 11: Regeneris Consulting on behalf of Gladman Developments
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Appendix 1: Aspect360 on behalf of the Hardwicke Co urt Estate
What are the objectively assessed needs for housing in Stroud District?
Statement of Common Ground Questionnaire
Response by Aspect360 on behalf of the Hardwicke Court Estate
Background
The Stroud District Local Plan was submitted to the Planning Inspectorate in
December 2013. Examination hearing sessions dealing with housing requirements
were held in April 2014. The Inspector’s Stage 1 initial conclusions were published in
June 2014. The Inspector concluded that further work was necessary to ensure that
a soundly based objective assessment of housing requirements had been
undertaken.
The District Council commissioned Neil McDonald (NMSS) in July 2014 to undertake
a study of the objectively assessed needs for housing in Stroud from first principles.
In response to a query from a hearing participant, the Inspector asked the Council to
consider holding a technical workshop with representors who have challenged the
objective assessment of housing need in order to try to narrow the issues in dispute
and prepare a Statement of Common Ground identifying areas of agreement and
disagreement. This may assist in establishing the respective positions of the various
parties before any further hearing sessions resume.
On 14 October 2014 a technical workshop was held in the Council Chamber, Ebley
Mill, Stroud. A draft Executive Summary and presentation slides were circulated in
advance of the workshop. Participants asked questions and gave views during the
workshop and were given until 24 October 2014 to write in with further comments
and queries. Five responses were received by the District Council.
Following the workshop, Neil McDonald has now completed his final report taking
into account views expressed during and after the workshop. The full report has now
been published.
Statement of Common Ground
The District Council has prepared this focused questionnaire which will be used to
compile a factual Statement of Common Ground between the Council and
representors, identifying the areas of agreement and disagreement.
Representors are requested to fill in this questionnaire and to return it to Helen
clarification of positions through any future hearing session on housing requirements,
once the examination is reopened.
Stroud District Council 5 November 2014
QUESTIONNAIRE
Instructions for completing questionnaire.
Please respond to the questions by highlighting Yes/No and provide a brief text
response where asked summarising your position. Please do not attach further
supporting information at this stage as this will not be reported to the
Inspector.
Population Forecasts
The report takes as its starting point the population estimates from the interim 2011
based subnational population projections for England (2011 SNPP) and the 2012
subnational population projections for England (2012 SNPP). The report concludes
that the 2012 SNPP, with due allowances, should generally be adopted as the more
reliable projection.
Do you agree with this approach? Conditional Yes/No (please highlight as
appropriate)
Response: The Hardwicke Court Estate does not consider that this is an acceptable
statement to include within a Statement of Common Ground given the subjective
nature of the phraseology used. The Estate will, however, agree that the evidence
contained within the 2012 SNPP is the starting point for determining the Objectively
Assessed Need for Stroud District on the basis that it represents the latest available
information in the context of paragraph 016 of the Planning Practice Guidance
(PPG).
If No, what population estimates should be the starting point for the report?
Components of Change
The report examines data relating to various components of change - Births, Deaths,
UK inflow, UK outflow, International migration in and international migration out.
Births
The report concludes that the 2012 based projections are a better basis for
forecasting future births than the 2011 based projections.
Do you agree with this approach? Conditional Yes /No
If No, what should the forecast of future births be based upon?
Response: While the Estate agrees that the 2012 based projections birth evidence
is appropriate for projecting future births associated with population projections, it is
not clear from the report or statement above on the manner in which the evidence
has been used. The report sets out at paragraph 43 that the 2012 projections for
births appear to be plausible projections, however, it is not clear from the report
whether the population profile has been used directly, or whether the fertility rates
have been used and applied to a base population profile.
This distinction is important in appraising alternative scenarios such as economic
scenarios, as it is important that age specific fertility rates are integral to establishing
revised population projections, to that of the baseline 2012 SNPP.
Further clarity is therefore required and the Estate is happy to engage further to
reach agreement on this.
Deaths
The report concludes that there is no reason to question this aspect of the 2012
based projections.
Do you agree with this approach? Conditional Yes /No
If No, what should the forecast of future deaths be based upon?
Response: The Estate agrees that the 2012 based projections are a better basis for
forecasting future deaths, however, similarly to the birth statement above, it is not
clear whether actual projection data or age specific mortality rates have been used.
Further clarity is therefore required and the Estate is happy to engage further to
reach agreement on this.
UK inflows and UK outflows
The report adjusts UK inflows and outflows based on the ratio of the average annual
flows over a 10 year period 2002 – 2012 to the flows over the period 2007-12, rather
than the 2012 based projections which reflect a 5 year trend 2007-2012.
Do you agree with this approach? Yes/No
Response: The Estate concurs that the use of a ten year observation period is more
robust in respect of internal migration trends.
If No, what should UK inflows and outflows be based upon?
International migration flows
The report concludes that there is no reason to question this aspect of the 2012
based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of international migration be based upon?
Response: The 2012 SPPP International Migration trends are constrained at a UK
level as set out in paragraph 30 of the Council’s Report. This is currently 154,000
people per annum. However it is already observed that the national constraint has
been exceeded in 2012, 2013 and 2014, with net migration in those years
comprising 184,000, 212,000 and 243,000 respectively. This amounts to an
additional 177,000 people over the ONS constraint cap in just three years. This
accounts for more than a single year of the ONS cap in itself within the three year
period. It is therefore clear that the Governments ONS cap of 154,000 has already
been exceeded substantially.
The 2012 SNPP is therefore considerably underestimating the level of international
migration. The exceedance of the Government’s constraint is therefore a serious and
significant factor to be considered. It is also observed that the constraint of 154,000
has only been achieved once since 2004. The Council should therefore incorporate a
sensitivity test of increasing international migration proportionally as observed.
A self-imposed Government constraint is no mechanism for forward forecasts.
Unattributable population change (UPC)
The report includes the UPC for Stroud (for the period 2001-2011) in the calculation.
Do you agree with this approach? Yes/ No objection
If No, should the UPC be excluded or some other adjustment made?
Response: The Estate raises no objection to the approach used with respect to UPC
Estimate Population
The report estimates an increase of 14,100 people in Stroud in the period 2011-2031
(or 16,700 people in Stroud in the period 2006-2031).
Do you agree with these figures? Yes/No
Response: The Estate cannot at this time agree to this position as it seeks
clarification on a number of points above.
Household Formation Rates
The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are half way between the 2008 and 2011 based rates. Thereafter household formation rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups. Do you agree with this approach? Yes/No
If No, what assumptions regarding household formation rates should be used?
The Council’s Report contains a detailed review of recent changes in actual,
estimated and projected headship rates for Stroud (pp 29-35).
The most up to date official household projections are CLG’s 2011-based Interim
projections. The Council’s Report explains that the rates used in these projections
were derived from the 2011 Census. This identified household formation rates which
differed from those used in the previous (2008-based) CLG household projections.
The Council’s Report initially sets out (paragraph 46 refers) that the 2008-based
projections were based on trends which predated the economic downturn and which
could be taken as broadly indicative of previous longer term trends. However the
report subsequently suggests that as the 2008-projections failed to pick up some
trends which were apparent even before the downturn, the household formation
rates used in those projections are inappropriate as they stand and proposes a
partial return to these rates (paragraph 54 refers).
The difference between household formation rates in the two sets of projections
varies by age group. It is greatest for the 25-34 and over 60 age groups, but the
rates differ throughout the age spectrum.
For the 25-34 age group, the 2011-based projections suggest that the household
formation rates are lower than the 2008-based rates in 2011 and will continue to
diverge further over the 2011-2021 projection period.
The divergence for this age group from longer term trends is attributed in the
Council’s evidence to two factors. Firstly, significant international in-migration after
2001 reduced household representative rates because new in-migrants are more
likely to live in larger multi-person households than the rest of the population in this
age group, at least in the early years of residence. Research by Holmans1 attributes
around half of the reduction in household formation in the 25-34 age group nationally
to this cause. But as international migration levels in Stroud were less significant
than in many other areas, the report notes that the local impact might have been
less.
The second factor reducing the rate of household formation would have been an
increase in the tendency of people aged 25-34 to live together in shared houses/flats
or to remain living with parents.
ONS research2 using national data broadly supports this hypothesis. The Council’s
report sets out that this second element of change in household formation will mainly
1 Alan Holmans (2013) The Town & Country Planning Tomorrow Series Paper 16, New estimates of housing demand and need in England, 2011 to 2031, TCPA/CCHPR. 2 ONS (2012) Young Adults Living With Parents in the UK, 2011, available at http://www.ons.gov.uk/ons/dcp171776_266357.pdf and ONS (2013) Families and Households in England and Wales 2011, available at http://www.ons.gov.uk/ons/dcp171776_296986.pdf
Appendix 2: Bruton Knowles on behalf of the Pullen Family
What are the objectively assessed needs for housing in Stroud District?
Statement of Common Ground Questionnaire
Background
The Stroud District Local Plan was submitted to the Planning Inspectorate in December 2013. Examination hearing sessions dealing with housing requirements were held in April 2014. The Inspector’s Stage 1 initial conclusions were published in June 2014. The Inspector concluded that further work was necessary to ensure that a soundly based objective assessment of housing requirements had been undertaken.
The District Council commissioned Neil McDonald (NMSS) in July 2014 to undertake a study of the objectively assessed needs for housing in Stroud from first principles.
In response to a query from a hearing participant, the Inspector asked the Council to consider holding a technical workshop with representors who have challenged the objective assessment of housing need in order to try to narrow the issues in dispute and prepare a Statement of Common Ground identifying areas of agreement and disagreement. This may assist in establishing the respective positions of the various parties before any further hearing sessions resume.
On 14 October 2014 a technical workshop was held in the Council Chamber, Ebley Mill, Stroud. A draft Executive Summary and presentation slides were circulated in advance of the workshop. Participants asked questions and gave views during the workshop and were given until 24 October 2014 to write in with further comments and queries. Five responses were received by the District Council.
Following the workshop, Neil McDonald has now completed his final report taking into account views expressed during and after the workshop. The full report has now been published.
Statement of Common Ground
The District Council has prepared this focused questionnaire which will be used to compile a factual Statement of Common Ground between the Council and representors, identifying the areas of agreement and disagreement.
Representors are requested to fill in this questionnaire and to return it to Helen Johnstone [email protected] at the District Council by 26 November 2014.
Please answer the questions set out in the questionnaire and the questionnaire responses will be reported to the Inspector. It will be for the Inspector to seek clarification of positions through any future hearing session on housing requirements, once the examination is reopened.
Stroud District Council 5 November 2014
QUESTIONNAIRE
Instructions for completing questionnaire.
Please respond to the questions by highlighting Yes/No and provide a brief text response where asked summarising your position. Please do not attach further supporting information at this stage as this will n ot be reported to the Inspector.
Population Forecasts
The report takes as its starting point the population estimates from the interim 2011 based subnational population projections for England (2011 SNPP) and the 2012 subnational population projections for England (2012 SNPP). The report concludes that the 2012 SNPP, with due allowances, should generally be adopted as the more reliable projection.
Do you agree with this approach? Yes/No (please highlight as appropriate)
If No, what population estimates should be the starting point for the report?
Components of Change
The report examines data relating to various components of change - Births, Deaths, UK inflow, UK outflow, International migration in and international migration out.
Births
The report concludes that the 2012 based projections are a better basis for forecasting future births than the 2011 based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of future births be based upon?
Deaths
The report concludes that there is no reason to question this aspect of the 2012 based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of future deaths be based upon?
UK inflows and UK outflows
The report adjusts UK inflows and outflows based on the ratio of the average annual flows over a 10 year period 2002 – 2012 to the flows over the period 2007-12, rather than the 2012 based projections which reflect a 5 year trend 2007-2012.
Do you agree with this approach? Yes/No
If No, what should UK inflows and outflows be based upon?
International migration flows
The report concludes that there is no reason to question this aspect of the 2012 based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of international migration be based upon?
Unattributable population change (UPC)
The report includes the UPC for Stroud (for the period 2001-2011) in the calculation.
Do you agree with this approach? Yes/No
If No, should the UPC be excluded or some other adjustment made?
Estimate Population
The report estimates an increase of 14,100 people in Stroud in the period 2011-2031 (or 16,700 people in Stroud in the period 2006-2031).
Do you agree with these figures? Yes/No
If No, what should the figures be?
Household Formation Rates
The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are half way between the 2008 and 2011 based rates. Thereafter household formation
rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups.
Do you agree with this approach? Yes/No
If No, what assumptions regarding household formation rates should be used?
Empty and second homes
The report includes an allowance of 3.96% for empty and second homes
Do you agree with this figure? Yes/No
If No, what should the figure be?
Housing needed from demographic calculations
The report states that 8,700 additional homes will be needed 2011-2031 (10,400 additional homes for 2006-2031) based on demographic based calculations
Do you agree with this figure? Yes/No
If No, what should the figure be?
Market signals
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
Under supply
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
The housing figures need to be increased by at leas t 5% in the first five years in line with the Inspector’s preliminary conclusion s.
Concealed Families
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
Overcrowding
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
Affordable housing
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
The extent of the affordable housing requirement is so substantial that there is a case for extending the overall requirement to all ow for new sources of supply to bring forward additional affordable homes .
Supporting economic growth
Economic forecasts
The report uses the latest 2014 economic projections from two forecasters – Cambridge Econometrics and Oxford Economics.
Do you agree with this approach? Yes/No
If No, what alternative or additional economic forecasts / considerations should be used?
Economic activity rates
The report suggests that in estimating the labour force and hence housing implications of the econometric projections, economic activity rate assumptions consistent with the projections being interpreted should be used.
Do you agree with this approach? Yes/No
If No, what alternative approach should be used?
Jobs assessment period
The report assesses how many homes will be needed to support projected increases in jobs for the period 2014-2031.
Do you agree with this approach? Yes/No
If No, what period should the assessment cover?
Interpreting the economic forecasts
The report suggests that a reasonable allowance for additional housing to support economic growth would be for Stroud, Cotswold and Forest of Dean to provide between them for half the additional homes which the CE analysis suggests might be needed across Gloucestershire i.e. 2,700. If these are allocated in line with the relative housing numbers suggested by the CE analysis Stroud would provide 800 additional housing (rounded).
Do you agree with this approach? Yes/No
If No, what alternative approach should be used?
Other matters
Please provide brief details of any other factors which should be taken into account in identifying an OAHN for Stroud.
The Council has not published an updated 5 year hou sing land supply at the time of writing this response. There is therefore t he question of windfalls still to consider. An additional allowance may therefore be required to give some added flexibility on this matter.
Overall, it would seem prudent to reflect the need to remedy poor past performance, affordable needs and windfall reductio ns by adding 20% to the first 5 years of the overall current projected requ irement of 11200 dw. i.e. to increase to the total to 11650 dw., effectively add ing one years requirement as flexibility.
Contact Details
Please provide contact details so that we can ensure that your comments can be reflected in the Statement of Common Ground.
Name: W.W.Strachan
Organisation: Bruton Knowles (on behalf of the Pull en Family)
Contact phone / email: 01242236755 ( 07771966604)
strachan988@ btinternet.com
20
Appendix 3: DLP Planning on behalf of Hallam Land M anagement
What are the objectively assessed needs for housing in Stroud District?
Statement of Common Ground Questionnaire
Background
The Stroud District Local Plan was submitted to the Planning Inspectorate in December 2013. Examination hearing sessions dealing with housing requirements were held in April 2014. The Inspector’s Stage 1 initial conclusions were published in June 2014. The Inspector concluded that further work was necessary to ensure that a soundly based objective assessment of housing requirements had been undertaken.
The District Council commissioned Neil McDonald (NMSS) in July 2014 to undertake a study of the objectively assessed needs for housing in Stroud from first principles.
In response to a query from a hearing participant, the Inspector asked the Council to consider holding a technical workshop with representors who have challenged the objective assessment of housing need in order to try to narrow the issues in dispute and prepare a Statement of Common Ground identifying areas of agreement and disagreement. This may assist in establishing the respective positions of the various parties before any further hearing sessions resume.
On 14 October 2014 a technical workshop was held in the Council Chamber, Ebley Mill, Stroud. A draft Executive Summary and presentation slides were circulated in advance of the workshop. Participants asked questions and gave views during the workshop and were given until 24 October 2014 to write in with further comments and queries. Five responses were received by the District Council.
Following the workshop, Neil McDonald has now completed his final report taking into account views expressed during and after the workshop. The full report has now been published.
Statement of Common Ground
The District Council has prepared this focused questionnaire which will be used to compile a factual Statement of Common Ground between the Council and representors, identifying the areas of agreement and disagreement.
Representors are requested to fill in this questionnaire and to return it to Helen Johnstone [email protected] at the District Council by 26 November 2014.
Please answer the questions set out in the questionnaire and the questionnaire responses will be reported to the Inspector. It will be for the Inspector to seek clarification of positions through any future hearing session on housing requirements, once the examination is reopened.
Stroud District Council 5 November 2014
QUESTIONNAIRE
Instructions for completing questionnaire.
Please respond to the questions by highlighting Yes/No and provide a brief text response where asked summarising your position. Please do not attach further supporting information at this stage as this will n ot be reported to the Inspector.
Population Forecasts
The report takes as its starting point the population estimates from the interim 2011 based subnational population projections for England (2011 SNPP) and the 2012 subnational population projections for England (2012 SNPP). The report concludes that the 2012 SNPP, with due allowances, should generally be adopted as the more reliable projection.
Do you agree with this approach? Yes/No (please highlight as appropriate)
If No, what population estimates should be the starting point for the report?
The Planning Practice Guidance states that the popu lation projections are the starting point. It is therefore agreed that these p rovide the appropriate starting point but the final conclusions is dependants upon the due allowances”. These are not agreed and therefore the final outcom e is not agreed
Components of Change
The report examines data relating to various components of change - Births, Deaths, UK inflow, UK outflow, International migration in and international migration out.
Births
The report concludes that the 2012 based projections are a better basis for forecasting future births than the 2011 based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of future births be based upon?
Deaths
The report concludes that there is no reason to question this aspect of the 2012 based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of future deaths be based upon?
UK inflows and UK outflows
The report adjusts UK inflows and outflows based on the ratio of the average annual flows over a 10 year period 2002 – 2012 to the flows over the period 2007-12, rather than the 2012 based projections which reflect a 5 year trend 2007-2012.
Do you agree with this approach? Yes/No
If No, what should UK inflows and outflows be based upon?
The report is correct in that it is required in the context of the PPG the review of the past migration rates and question as to weht er they are likely to continue.
We would also agree that the impact of the recessio n is that the levels of internal migration as fallen.
We would however add that there are a number of oth er factors likely to impact on the future level of migration into the District. These are as follows:
• Impact of known under provision of housing in Londo n (a shortfall of at least 7,000 dwellings a year according to the FALP) .
• Impact of known under delivery in Birmingham • The impact of future level of employment growth and the requirement of
the NPG to integrate economic and housing strategie s
Considering the above we have modelled the level of total net in migration as being 1,100 to 1,400 persons a year. This is based on the outputs of the accepted Chelmer Model meeting the growth in labour force for the period 2014 – 2031 of between 2444 and 4403 persons (CE na d OE projections page 76).
International migration flows
The report concludes that there is no reason to question this aspect of the 2012 based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of international migration be based upon?
Unattributable population change (UPC)
The report includes the UPC for Stroud (for the period 2001-2011) in the calculation.
Do you agree with this approach? Yes/No
If No, should the UPC be excluded or some other adjustment made?
The use of the 2012 SNPP does not require any adjus tment for UPC
Estimate Population
The report estimates an increase of 14,100 people in Stroud in the period 2011-2031 (or 16,700 people in Stroud in the period 2006-2031).
Do you agree with these figures? Yes/No
If No, what should the figures be?
Using the employment projections of an increase in jobs of between 2,444 and 4,403 jobs would require a population growth of bet ween 19,338 and 22,452 persons (This is based on the outputs of the Chelme r Model using the 2012 SNPP).
Household Formation Rates
The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are half way between the 2008 and 2011 based rates. Thereafter household formation rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups.
Do you agree with this approach? Yes/No
If No, what assumptions regarding household formation rates should be used?
This approach is contrary to the PPG which requires a plan to increase opportunities for home ownership. It actually conti nues the implications of not only the recent recession but also the long term un dersupply of homes since the 1990’s.
The Household Formations rates for all should be mo delled to improve so as to reflect the aspirations of the government. Simpl y using recent past trends do nothing to increase opportunities for home owner ship or address affordability.
As a starting point we would suggest the use of the HRR on the following page. Although it is recognised that these in thems elves will not bring about the required changes to affordability and accessibi lity that is required by the Framework and the NPG.
The report includes an allowance of 3.96% for empty and second homes
Do you agree with this figure? Yes/No
If No, what should the figure be?
Housing needed from demographic calculations
The report states that 8,700 additional homes will be needed 2011-2031 (10,400 additional homes for 2006-2031) based on demographic based calculations
Do you agree with this figure? Yes/No
If No, what should the figure be?
Our Demographic projection from the Chelmer Model b ased on the 2012 SNPP suggests a slightly lower requirement of 8,500 dwel ling or 425 dwellings a year. This does not model the higher levels of migr ation over the 5 year period or the increase due to the unattributed population change.
Market signals
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
The approach of using indexed rates and only lookin g back to 2001 substantially underplays the issue of affordability . It presupposes that at 2001 the market was in equilibrium and that the levels o f affordability across the country and the districts were acceptable. This is not considered to be the case it is our view that the current housing crisis ’s has been building slowly since the 1990’s as our research illustrates that t here has been persistent under provision against actual need for these two d ecades.
Looking at the longer term as appendix 1 of DLP’s s ubmission on matter 2 in February 2 it is clear that by 2001 there were alre ady significant issues in affordability since 1993 Mean House prices have tri pled and affordability (lower Quartile prices v Lower Quartile Earning) ha s increased from 4 to over 6. If only the comparative changes are considered t hen future policy will just plan for a level of housing provision to maintain t he current market status and present levels of affordability rather than improve these. This we would argue is contrary to the Framework which requires to meet need and demand as well
as to increase the opportunities for home ownership this cannot be achieved by simply matching present levels of affordability on a regional or national scale.
Under supply
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
It is noted that the build rate in figure 24 is wel l below the DCLG projections of need for Stroud to meet the 2004 based projections would have required sufficient housing for 500 households a year.
It is considered that the district has undersupplie d against actual levels of demand and need. This is a common occurrence across the country and is a contributory factor of the worsening affordability nationally. Albeit small levels of under provision combine to especially over the l ong term to create a constrained market.
The question refers to the additional level of hou sing required, in our view these is no direct mathematical equation that can t ransfer the past level of under provision to additional dwellings just that w hen considering future levels of provision including those higher levels r equired to meet the economic projections such a finding adds considerab le weight to the higher of these projections.
Concealed Families
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
There has been a considerable growth in the number of unrelated adults sharing accommodation. This is a separate category and it is assumed that none of these persons are actually potential househ olds which are making a sub optimal choice of sharing accommodation rather than remaining in the parental home.
It is accepted that these are not what may be tradi tional referred to as hidden households but they are a consequence of the long t erms worsening affordability over the past two decades and does re quire to be addressed. It is noted that the Report does provide for a little rel ief in one of the age groups which are most likely to form this type of househol d however this is considered to be an inadequate response.
Overcrowding
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
It is accepted that the traditional measure of over crowding suggests that there is not a particular problem with the area although the more intensive use of the stock by adults sharing and HMO’s is oon our view i ndicators that the housing market is not currently operating in a way that is fully meeting all demand and need as required b the framework and the PPG.
Affordable housing
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
It is noted that in paragraph 88 the report argues that past levels of provision will have constrained household formation rates and that this is likely to continue.
The requirement for affordable housing is an indica tor as to the nature of the current market the fact that the latest SHMA sugges ts a requirement of 477 affordable dwellings a year (Table A5.1 Housing nee ds assessment model for
Stroud) has to be consideration in determining the overall level of housing need in the district.
Supporting economic growth
Economic forecasts
The report uses the latest 2014 economic projections from two forecasters – Cambridge Econometrics and Oxford Economics.
Do you agree with this approach? Yes/No
If No, what alternative or additional economic forecasts / considerations should be used?
It is noted that these two economic projections ten d to be the more pessimistic employment forecasts than those produce d by Experian. Other Authorities encouraged by inspectors have use all t hree to triangulate the likely level of future employment growth.
As these have already been presented in evidence to the examination it is both surprising and disappointing that the councils cons ultants have not sought to utilise this element of the evidence base.
This evidence also supports the fact that employmen t growth is likely to be towards the higher end of the tow projections in th e report.
Extract of Experian Projection (February 2014)
Stroud 2011 2031
Change 2011 to 2031
Total FTE employment (Thousands) 37660 41460 3,800
Workforce jobs (Thousands) 54550 60370 5,820
Working age population (Thousands) 64840 67160 2,320
Total population (Thousands) 112130 121840 9,710
LFS unemployment (Thousands) 3280 1910 -1,370
LFS employment (Thousands) 56460 68210 11,750
Economic activity rates
The report suggests that in estimating the labour force and hence housing implications of the econometric projections, economic activity rate assumptions consistent with the projections being interpreted should be used.
Do you agree with this approach? Yes/No
If No, what alternative approach should be used?
Economic activity rates are an output of economic m odels in that they are adjusted within the model in order to resolve the o utputs from the model with regard to population. The same is the case with com muting. Growth in jobs is also constrained to available labour after taking a ccount to modelled changes in activity rates and commuting. Hence using the ou tput activity rates from the model one must be conscious that these do not refle ct past patters or trends but have been generated internally by the model.
Our analysis of long term trends in economic activi ty rates highlight that these can be very flexible and therefore assumptions base d on short term changes should be treated with extreme caution.
These very modest long terms trends do not suggest that it would be wise to model in substantial long term changes in the econo mic activity rates. This position has been supported by the comments of insp ectors at South Worcestershire, Aylesbury Vale and Doncaster examin ations.
The approach adopted by SPRU in their modelling is an approach that has been favoured by Senior inspector Mr Clews at the S outh Worcestershire Examination which is to increase activity rates to reflect future changes of activity rates based upon the impact of the changes to the pension age.
These have been summarised in our previous submissi ons and for the sake of brevity are not repeated here.
The longer term trends and the volatility of activi ty rates are demonstrated in the two charts below:
It is suggested that the economic activity rates below be used as a better reflection of the long term levels of activity reflecting pension age changes
The report assesses how many homes will be needed to support projected increases in jobs for the period 2014-2031.
Do you agree with this approach? Yes/No
If No, what period should the assessment cover?
There is a mismatch in the approach as the largest element of the growth appears to have already occurred in the 2011 to 201 4 period. To achieve this will have required changes to commuting and activit y rates yet the approach taken by the report is that activity rates will imp rove on an average annual rate (i.e. smoothing out what are known to be highly vol atile rates in the short term.)
Our analysis of long term trends in (above) show th at short term fluctuations tend to average out over the longer period. In orde r to accommodate this it is considered that the projections should also embrace the higher employment led forecasts fo the period 2011 to 2031. These wil l be higher than the projections that have presently been run by SPRU in response to this paper.
Interpreting the economic forecasts
The report suggests that a reasonable allowance for additional housing to support economic growth would be for Stroud, Cotswold and Forest of Dean to provide between them for half the additional homes which the CE analysis suggests might be needed across Gloucestershire i.e. 2,700. If these are allocated in line with the relative housing numbers suggested by the CE analysis Stroud would provide 800 additional housing (rounded).
Do you agree with this approach? Yes/No
If No, what alternative approach should be used?
The approach adopted by the report is to apply a po licy decision not to meet the higher levels of housing growth required to mee t the higher economic projections (paragraph 134). It is clear that the d ecision not to meet these higher levels is the application of the LEP policy to redistribute economic growth. As such this is clearly a policy led decisi on and contrary to the Framework and OAN which requires the OAN to reflect the needs of the economy in terms of the policy off position.
Figure 42: OANs for 2011-31 for Stroud suggests tha t to meet this lower policy constrained level of employment growth would requir e 9,500 dwellings (475 dwellings a year).
There is no logic to this approach the forecast job growth is forecast to occur at the district level dependant on its own economic base to suggest that this can be redistributed is illogical.
The table on the next page demonstrates that the le vel of dwellings that would actually be required to meet the projected level of employment growth. The approach adopted by the report requires the continu ation of patterns of household formation and working that are deeply inf luenced by the long term undersupply of housing and demand during the past t wo decades. This mismatch has had a negative impact in the national economy nad has deepened the impact of the worldwide recession. Pla nning to perpetuate these conditions into the future is not considered to be a suitable response to the Framework or the PPG .
Please provide brief details of any other factors which should be taken into account in identifying an OAHN for Stroud.
Reference should be made both to our original submi ssion to the plan examination. Unfortunately the nature of this consu ltation does not facilitate the presentation of our full case which is based up on both the most up-to-date information regarding the demographic and economic scenarios but also recent decisions from other plan examination.
On the current evidence base we would suggest that the full objectively assessed need for housing taking into account impro vements to the economy and changes to the pension age would require a dwel ling provision of between 11,218 and 12,393 (2011 to 2031) or 561 to 620 dwe llings a year.
Contact Details
Please provide contact details so that we can ensure that your comments can be reflected in the Statement of Common Ground.
Name: Roland G Bolton
Organisation: Strategic Planning Research Unit at D LP Planning Ltd
Appendix 4: Don’t Strangle Stroud and Eastington Pa rish Council in association with Strategic Planning Alliance
1
What are the objectively assessed needs for housing in Stroud District?
Statement of Common Ground Questionnaire
Background
The Stroud District Local Plan was submitted to the Planning Inspectorate in December 2013. Examination hearing sessions dealing with housing requirements were held in April 2014. The Inspector’s Stage 1 initial conclusions were published in June 2014. The Inspector concluded that further work was necessary to ensure that a soundly based objective assessment of housing requirements had been undertaken.
The District Council commissioned Neil McDonald (NMSS) in July 2014 to undertake a study of the objectively assessed needs for housing in Stroud from first principles.
In response to a query from a hearing participant, the Inspector asked the Council to consider holding a technical workshop with representors who have challenged the objective assessment of housing need in order to try to narrow the issues in dispute and prepare a Statement of Common Ground identifying areas of agreement and disagreement. This may assist in establishing the respective positions of the various parties before any further hearing sessions resume.
On 14 October 2014 a technical workshop was held in the Council Chamber, Ebley Mill, Stroud. A draft Executive Summary and presentation slides were circulated in advance of the workshop. Participants asked questions and gave views during the workshop and were given until 24 October 2014 to write in with further comments and queries. Five responses were received by the District Council.
Following the workshop, Neil McDonald has now completed his final report taking into account views expressed during and after the workshop. The full report has now been published.
Statement of Common Ground
The District Council has prepared this focused questionnaire which will be used to compile a factual Statement of Common Ground between the Council and representors, identifying the areas of agreement and disagreement.
Representors are requested to fill in this questionnaire and to return it to Helen Johnstone [email protected] at the District Council by 26 November 2014.
Please answer the questions set out in the questionnaire and the questionnaire responses will be reported to the Inspector. It will be for the Inspector to seek clarification of positions through any future hearing session on housing requirements, once the examination is reopened.
Stroud District Council 5 November 2014
QUESTIONNAIRE
2
Instructions for completing questionnaire.
Please respond to the questions by highlighting Yes/No and provide a brief text response where asked summarising your position. Please do not attach further supporting information at this stage as this will n ot be reported to the Inspector.
Population Forecasts
The report takes as its starting point the population estimates from the interim 2011 based subnational population projections for England (2011 SNPP) and the 2012 subnational population projections for England (2012 SNPP). The report concludes that the 2012 SNPP, with due allowances, should generally be adopted as the more reliable projection.
Do you agree with this approach? Yes/No (please highlight as appropriate)
If No, what population estimates should be the starting point for the report?
The “Due allowances” used in this report are not va lid as described in the relevant sections below. The allowances appear to h ave been added to achieve a predetermined figure. We question whether the rep ort is Objective and as such is not sound in a number of areas.
Components of Change
The report examines data relating to various components of change - Births, Deaths, UK inflow, UK outflow, International migration in and international migration out.
Births
The report concludes that the 2012 based projections are a better basis for forecasting future births than the 2011 based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of future births be based upon?
Deaths
The report concludes that there is no reason to question this aspect of the 2012 based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of future deaths be based upon?
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UK inflows and UK outflows
The report adjusts UK inflows and outflows based on the ratio of the average annual flows over a 10 year period 2002 – 2012 to the flows over the period 2007-12, rather than the 2012 based projections which reflect a 5 year trend 2007-2012.
Do you agree with this approach? Yes/No
If No, what should UK inflows and outflows be based upon?
These “adjustments” are not valid for three reasons :-
1. They are attempting to fit a “UK wide” solution to Stroud. 2. The 2012 population projections already include an updated formula for
migratory flows in the UK (as confirmed by the ONS) 3. Neil Macdonald has assumed that the “post recess ionary” population
projections would be reduced by the effects of the recession. Referral to the ONS data confirms that his “assumption” is inco rrect. The trend from the last five years shows an increased population p rojection for Stroud (as confirmed by the ONS). If Neil McDonald and SDC wish to “return to trend” then a lower population projection must be used deflating the housing requirement. NMD’s approach is not objective (evidence based) an d is therefore UNSOUND Impact on OAHN ……… - 50 Houses
International migration flows
The report concludes that there is no reason to question this aspect of the 2012 based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of international migration be based upon?
Unattributable population change (UPC)
The report includes the UPC for Stroud (for the period 2001-2011) in the calculation.
Do you agree with this approach? Yes/No
If No, should the UPC be excluded or some other adjustment made?
UPC is a measure of a previous projection’s accurac y between two census points. Neil McDonald appears to be implying that a ll ONS population projections have to be corrected by a UPC. This ass umption is not credible and it is surprising that this has not been challenged at the proof reading stage.
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The 2012 projections have already been corrected to the 2011 census data. The ONS have confirmed the obvious - that UPC should no t be used in this way.
Additionally, the components of UPC show that the i nternal migration is the major contributor to the UPC. The ONS confirms that the 2012 projections have been updated to include this change in internal mig ration.
Neil Macdonald carries out a very eloquent descript ion of the UPC, however his use of UPC appears to suggest that he is again hunt ing for reasons to inflate the housing figure, or he does not understand the base subject. The use of UPC here is completely UNSOUND.
Impact on OAHN………………. - 200 houses
Estimate Population
The report estimates an increase of 14,100 people in Stroud in the period 2011-2031 (or 16,700 people in Stroud in the period 2006-2031).
Do you agree with these figures? Yes/No
If No, what should the figures be?
Neil Macdonald has not presented any valid evidence that backs up the increasing of the 13,600 number from the ONS projec tion in the period 2011-2031. In addition the Local Plan makes no argument for any action to increase the projected population. Indeed it emphasises the use of the ONS and DCLG projections.
His “adjustments” are not supported by the ONS or D CLG guidance – To achieve this higher figure the report does not “est imate an increase”. It creates an increase through invention – an erroneous correc tion value, UPC or “double counting”.
ONS and DCLG statements and guidance confirm this a ssertion.
These are very basic errors which do not inspire th e confidence of the reader in NMD as an “expert”. The 16,700 figure is therefore without any credible evidence and as such is UNSOUND.
The ONS projected figure of 13,600 has to be used a s it is the only one with a credible evidence base.
Household Formation Rates
The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are
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half way between the 2008 and 2011 based rates. Thereafter household formation rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups.
Do you agree with this approach? Yes/No
If No, what assumptions regarding household formation rates should be used?
Neil Macdonald doesn’t go into the detail of the co mponents of change included in the 2011-based DCLG household projections whatso ever . If he had, he would note that the household formation rates used are fr om the very optimistic 2008-based (pre-recessionary) DCLG projections. This inf ormation is present in the DCLG release notes – as we have already commented o n in previous submissions. So the household projections that come from this data set are therefore based on pre-recessionary data. We are su rprised that NMD did not appear to know this, or decided to gloss over this fact in his report and his presentations.
Neil Macdonald then carries out a “correction” to t his projection using previous (2008-based) data, without first correcting this da ta with the very UPC that he has explained in such great detail elsewhere. If he had, then there would be no correction to carry out. This essentially applies t he “return to trend” logic twice.
Impact on OAHN……… - 250 houses
So in this OAN, we have one example of the UPC bein g used when it shouldn’t, and one of NOT being used when it should. As commen ted earlier we are concerned that NMD does not appear to understand wh at the UPC Is, and when it should be used.
Empty and second homes
The report includes an allowance of 3.96% for empty and second homes
Do you agree with this figure? Yes/No
If No, what should the figure be?
The previous figure presented by SDC was 3.2% (from SDC’s own records). Why is this different? Neither Neil Macdonald nor Offic ers have checked the data SDC Officers have already presented for this EIP. H is data is based on 2011 information – the 3.2% number is informed by later information presented by Keith Woodhead. The use of this out-of-date number is contrary to NPPF guidance on using the latest data.
Housing needed from demographic calculations
The report states that 8,700 additional homes will be needed 2011-2031 (10,400 additional homes for 2006-2031) based on demographic based calculations
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Do you agree with this figure? Yes/No
If No, what should the figure be?
The “adjustments” made to the base number of houses are not valid – they rely on the inappropriate addition of UPC in the populat ion base, then fail to take UPC into account when applying older projection dat a. This error again appears to suggest a lack of knowledge or lack of research into the data used.
The correct (ONS – advised) demographic based calcu lation would be: - 8,200
Market signals
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
Under supply
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
Concealed Families
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
Overcrowding
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
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Affordable housing
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
Supporting economic growth
Economic forecasts
The report uses the latest 2014 economic projections from two forecasters – Cambridge Econometrics and Oxford Economics.
Do you agree with this approach? Yes/No
If No, what alternative or additional economic forecasts / considerations should be used?
This report suggests an economic boost for jobs tha t has no adequate evidence – and only based on the South West projection by CE (as per Neil McDonalds presentation given in the council chambers). At thi s presentation Neil McDonald stated that the CE data was for the South West regi on. Since that time the data we have now seen is presented as Stroud Data. No ex planation as to this change has been offered although we do understand f rom Keith Pearson that Neil McDonald has normalised the Data. No explanati on as to how this data has been “normalised” has been provided or offered. Cou ld we have an explanation that is supported by the working papers? Given that the SW has at least eight very large centres of population and employment, th e task of normalisation will be very complex and time consuming.
By Contrast Oxford has provided Stroud District spe cific data. Neil McDonald has not provided any explanation as to why this mor e accurate Stroud specific data has not been used. This again leaves the impre ssion that NMD is hunting for any data, however tenuous, that raises the Obje ctively Assessed housing need. This is UNSOUND.
Economic activity rates
The report suggests that in estimating the labour force and hence housing implications of the econometric projections, economic activity rate assumptions consistent with the projections being interpreted should be used.
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Do you agree with this approach? Yes/No
If No, what alternative approach should be used?
This approach suggests a boost based on a single da taset that covers the South West (that may have been normalised by undeclared m ethods). It ignores Stroud specific data (as described in Neil McDonald’s pres entation in the council chambers) – this is contrary to NPPG guidance to us e up-to-date and local data wherever possible. This methodology is unexplained and not objective and is therefore UNSOUND.
Jobs assessment period
The report assesses how many homes will be needed to support projected increases in jobs for the period 2014-2031.
Do you agree with this approach? Yes/No
If No, what period should the assessment cover?
It is inappropriate to project economic growth over such a long timescale. Government departments are struggling to do this a year or two into the future. To project such high and sustained levels of econom ic job creation over a twenty-year period is both unrealistic and UNSOUND.
The Euro area is almost back in recession. China’s growth rate is beginning to slow. Growth rates are slowing across Asia. So to c onfidently suggest these high and sustained levels of growth over the next t wenty years is completely unrealistic.
We have another census in seven year’s time a revie w date should be planned now. This is both common sense, and in line with th e NPPF.
Interpreting the economic forecasts
The report suggests that a reasonable allowance for additional housing to support economic growth would be for Stroud, Cotswold and Forest of Dean to provide between them for half the additional homes which the CE analysis suggests might be needed across Gloucestershire i.e. 2,700. If these are allocated in line with the relative housing numbers suggested by the CE analysis Stroud would provide 800 additional housing (rounded).
Do you agree with this approach? Yes/No
If No, what alternative approach should be used?
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The CE analysis is the ONLY ONE that supports this expansion level, and is not focussed on Stroud, but is based on the South West (as stated by Neil McDonald’s in his presentation in the council chamb ers). The OE analysis for Stroud, in contrast ,concludes that Stroud’s plan w ould include ample houses for job-related growth.
Further, Neil McDonald’s report makes an arbitrary decision concerning the number of jobs that Stroud itself would support. Th is is not based on any neighbouring local plan, or any other evidence (oth er than the CE report for the SW). This level of jobs increase is extremely unlik ely in Stroud. Also It represents a massive increase in out-commuting from Stroud, which is contrary to the policy stated in the local plan.
We also understand that the FoD have strong reserva tions about Neil McDonald’s report. There is therefore no agreement between the LPAs on the likely jobs growth. Further, there is no mention of the “duty to cooperate” which is an absolute requirement especially if Stroud is considering to take 50% of something that only two parties out of three have a greed. This means that SDC do not know the number from which they are agreeing to take 50%. Stroud’s population at 113,000 compares to the FoD and Cotsw old combined of around 165,000.
So Neil McDonald has taken a South West Regional fi gure from CE, normalised it in a way that is not revealed, Ignored Stroud-sp ecific data from OE without objective explanation. He has arrived at a random f igure for jobs growth for three LPAs and allocated 50% to Stroud with no decl ared logic or agreement.
This approach conflicts head-on with the SDC policy to reduce out-commuting.
The addition of these 800 houses is not logical, ob jective or SOUND.
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Other matters
Please provide brief details of any other factors which should be taken into account in identifying an OAHN for Stroud.
1. Neil Macdonald has failed to take the elderly po pulation into account with respect to C2 housing, as deemed necessary by the Sec. of State in his rulings (October 6 th Release). This omission is startling as it fails to take account of this specifically declared NPPF requirement. This makes the plan is UNSOUND. This amounts to 328 fewe r houses, and 722 additional care home beds, shown below.
Impact of these mathematical and mis-counting error s on the proposed OAN.
Proposed NM OAN = 11,200
Correction for UK flow change = - 50
Correction for UPC error = - 200
Correction for double counting (RTT) = - 250
Correction for un-evidenced jobs growth = - 800
GIVES A TOTAL = 9,900
Adjusting for secretary of state directive on C2 dw ellings
Correction for population in care = - 328
Plus previously omitted C2 care home beds = +722 beds
Final Total Houses plus C2 care home Beds = 10,29 4
The option remains to insert up to 800 county jobs growth boost (out-commuters)
Giving a Total Houses plus C2 care home Beds = 11,0 94
This would represent up to a 17% increase in units of accommodation and responds sympathetically to the elderly, which was absent from the Neil McDonald report.
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2. This OAN fails to answer the specific questions set by the inspector:-
• It does not match the process used by JCS to inform their housing need or attempt to explain the differences – see note be low.
• It does not seek to back up, or explain, the previo us work carried out by Keith Woodhead.
• It carries out an additional assessment that isn’t what the inspector asked for.
• It fails to explain why alternative data sources ar e not compared – “POPGROUP”, “HEaDROOM”, “What Homes Where”.
• It fails to answer the inspectors query on the affo rdable housing number. • The relationship between the Gloucestershire Strate gic Economic Plan
and the Local plan is not made clear.
Note –
1. The “objectively assessed” housing number for th e JCS area has been calculated by a very different method to the one us ed for Stroud. In his published “JCS method”, Neil Macdonald calculated h is average household size from the officer-supplied housing nu mber and ONS population projection. Then, it was no surprise thi s original number was the result when this average household size was use d in his calculations. This effectively chose a number first, and then mad e the calculations fit this number. Evidence of this is in a JCS report pr ovided to councillors and available.
2. Included in this very same document is the state ment:- “In absolute numbers, the change in the fertility rate is the largest factor, with the annual birth rate for 2012 falling from 733,000 in the 2011 based projections to 693,000 in the 2012 set, a reduction of 40,000 a year. A reduction had been anticipated as it had been acknowledged by ONS that the approach used in the 2011 based projections had led to an overestimation of births. However, as children do not form households this fall in births will not have a significant impact on the number of households in the next 20 years” This quite remarkable assertion was then paraphrase d by Neil Macdonald’s written responses to councillor’s quest ions in the report as: - “ Babies don’t buy houses” This strange methodology does not appear to have be en applied in the Stroud calculation.
3. Neil McDonald’s reports to the JCS have the CCHP R and Cambridge University logos displayed prominently on the front sheet, so claiming accreditation from these institutions.
4. At the presentation on the 14 th October (and in SDC notes to the inspector) Neil McDonald was presented as being par t of CCHPR.
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5. We have contacted Cambridge University and CCHPR and they confirmed that Neil MacDonald is a Client (Customer) of CCHPR . He has no employment connection directly to Cambridge Univers ity.
6. Neither Cambridge University nor CHHPR have any sponsorship, oversight or responsibility for any of the reports produced by Neil MacDonald, neither for the JCS nor Stroud areas.
7. The presence of the names and logos of Cambridge University and CCHPR on the cover sheet would appear to attribute accreditation that does not exist.
As a community group we are again very seriously co ncerned that data appears to have been manipulated to produce a particular an swer. For the JCS area, Neil Macdonald has acknowledged this in writing. As pre viously highlighted, Keith Woodhead’s original TOR’s instructed a particular n umber in the same way.
NMD has represented himself in various forums as ca rrying a degree of Cambridge University accreditation or CCHPR sponsor ship. In the Stroud reports, the Cambridge and CCHPR logos have now bee n removed from his presentation material since we wrote to Cambridge a nd CCHPR seeking to better understand his relationship with them.
NMD’s report is simply wrong in a number of areas. We have identified these and are concerned that a retired Director from the DCLG should make such basic errors. It is difficult for the public and in deed the Inspector to have confidence in a report littered with such basic mis takes. It is also very concerning that these were not identified when offi cers reviewed the report.
Mark Russell has confirmed in writing that the JCS and SDC OAN methodologies are the same. Perhaps this is correct , and Neil McDonald has been working toward a predetermined figure for his SDC report as KW was before him.
Contact Details
Please provide contact details so that we can ensure that your comments can be reflected in the Statement of Common Ground.
Name: Ian Stuart
Organisation: Don’t Strangle Stroud, Eastington Par ish Council in association with SPA, (Strategic Planning Alliance) group of pa rishes and community groups
What are the objectively assessed needs for housing in Stroud District?
Statement of Common Ground Questionnaire
Background
The Stroud District Local Plan was submitted to the Planning Inspectorate in December 2013. Examination hearing sessions dealing with housing requirements were held in April 2014. The Inspector’s Stage 1 initial conclusions were published in June 2014. The Inspector concluded that further work was necessary to ensure that a soundly based objective assessment of housing requirements had been undertaken.
The District Council commissioned Neil McDonald (NMSS) in July 2014 to undertake a study of the objectively assessed needs for housing in Stroud from first principles.
In response to a query from a hearing participant, the Inspector asked the Council to consider holding a technical workshop with representors who have challenged the objective assessment of housing need in order to try to narrow the issues in dispute and prepare a Statement of Common Ground identifying areas of agreement and disagreement. This may assist in establishing the respective positions of the various parties before any further hearing sessions resume.
On 14 October 2014 a technical workshop was held in the Council Chamber, Ebley Mill, Stroud. A draft Executive Summary and presentation slides were circulated in advance of the workshop. Participants asked questions and gave views during the workshop and were given until 24 October 2014 to write in with further comments and queries. Five responses were received by the District Council.
Following the workshop, Neil McDonald has now completed his final report taking into account views expressed during and after the workshop. The full report has now been published.
Statement of Common Ground
The District Council has prepared this focused questionnaire which will be used to compile a factual Statement of Common Ground between the Council and representors, identifying the areas of agreement and disagreement.
Representors are requested to fill in this questionnaire and to return it to Helen Johnstone [email protected] at the District Council by 26 November 2014.
Please answer the questions set out in the questionnaire and the questionnaire responses will be reported to the Inspector. It will be for the Inspector to seek clarification of positions through any future hearing session on housing requirements, once the examination is reopened.
Stroud District Council 5 November 2014
QUESTIONNAIRE
Instructions for completing questionnaire.
Please respond to the questions by highlighting Yes/No and provide a brief text response where asked summarising your position. Please do not attach further supporting information at this stage as this will n ot be reported to the Inspector.
Population Forecasts
The report takes as its starting point the population estimates from the interim 2011 based subnational population projections for England (2011 SNPP) and the 2012 subnational population projections for England (2012 SNPP). The report concludes that the 2012 SNPP, with due allowances, should generally be adopted as the more reliable projection.
Do you agree with this approach? YES (please highlight as appropriate)
If No, what population estimates should be the starting point for the report?
Components of Change
The report examines data relating to various components of change - Births, Deaths, UK inflow, UK outflow, International migration in and international migration out.
Births
The report concludes that the 2012 based projections are a better basis for forecasting future births than the 2011 based projections.
Do you agree with this approach? YES
If No, what should the forecast of future births be based upon?
Deaths
The report concludes that there is no reason to question this aspect of the 2012 based projections.
Do you agree with this approach? YES
If No, what should the forecast of future deaths be based upon?
UK inflows and UK outflows
The report adjusts UK inflows and outflows based on the ratio of the average annual flows over a 10 year period 2002 – 2012 to the flows over the period 2007-12, rather than the 2012 based projections which reflect a 5 year trend 2007-2012.
Do you agree with this approach? YES
If No, what should UK inflows and outflows be based upon?
International migration flows
The report concludes that there is no reason to question this aspect of the 2012 based projections.
Do you agree with this approach? YES
If No, what should the forecast of international migration be based upon?
Unattributable population change (UPC)
The report includes the UPC for Stroud (for the period 2001-2011) in the calculation.
Do you agree with this approach? YES
If No, should the UPC be excluded or some other adjustment made?
Estimate Population
The report estimates an increase of 14,100 people in Stroud in the period 2011-2031 (or 16,700 people in Stroud in the period 2006-2031).
Do you agree with these figures? YES
If No, what should the figures be?
Household Formation Rates
The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are half way between the 2008 and 2011 based rates. Thereafter household formation
rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups.
Do you agree with this approach? NO
If No, what assumptions regarding household formation rates should be used?
It is not understood what the report means in the s tatement that HFR associated with international migration will unwind .
The report is contradictory by stating that modelli ng a partial return to trend for all age groups reduces the number of households formed but Figure E2 shows that a partial return to trend for all age gr oups is higher than the partial return to trend for 25 – 34 age group only. Likewis e this result is also shown in the Tables in the Appendices on pages 75, 90, 105, 111 and 116. Therefore it is unclear why a partial return to trend for just the 25 – 34 age group is favoured other than as a means to reduce the OAHN.
This scepticism about the approach to HFR is also r einforced by the latest analysis by CCHPR dated March 2014 for the GCT JCS which modelled two further alternative scenarios. The report states “ CCHPR concluded in May 2013 that the “Partial return to trend” scenario wo uld be a reasonable central case (33,200 dwellings). They remain of that view. However, both “Partial return for 25-34s” (30,500 dwellings) and “Indexati on to 2008 rates from 2021” (30,900 dwellings) are credible alternative options ”.
There is no convincing argument that the mid-point between 2008-based and 2011-based projections is the most appropriate appr oach. There are examples of Inspector’s disagreeing if the mid-point project ion produces a lower figure than a blended approach (please refer to South Worc estershire, Derbyshire Dales and Amber Valley Inspector’s Reports).
The HFR assumption is critically important because no other upward adjustments are undertaken to account for past unde r-supply, existing unmet need or affordable housing needs.
Therefore further sensitivity testing should be und ertaken for assumptions on:-
• full return to trend ; • blended rather than mid-point approach.
Empty and second homes
The report includes an allowance of 3.96% for empty and second homes
Do you agree with this figure? YES
If No, what should the figure be?
Housing needed from demographic calculations
The report states that 8,700 additional homes will be needed 2011-2031 (10,400 additional homes for 2006-2031) based on demographic based calculations
Do you agree with this figure? NO
If No, what should the figure be?
A higher figure would result from different assumpt ions on HFR (see comment above).
Market signals
The report states that there is no strong case for additional housing on this ground
Do you agree? NO
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
The market signals on house prices and rents in Cot swolds and on affordability in Forest of Dean suggest that an upw ard adjustment to OAHN is required.
Under supply
The report states that there is no strong case for additional housing on this ground
Do you agree? NO
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
Concealed Families
The report states that there is no strong case for additional housing on this ground
Do you agree? NO
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
Overcrowding
The report states that there is no strong case for additional housing on this ground
Do you agree? NO
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
Affordable housing
The report states that there is no strong case for additional housing on this ground
Do you agree? NO
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
Supporting economic growth
Economic forecasts
The report uses the latest 2014 economic projections from two forecasters – Cambridge Econometrics and Oxford Economics.
Do you agree with this approach? NO
If No, what alternative or additional economic forecasts / considerations should be used?
In addition to using the above mentioned economic p rojections consideration should be given to the inter-relationship between O AHN and the Gloucestershire LEP SEP as indicated in the Inspect or’s Interim Report.
Economic activity rates
The report suggests that in estimating the labour force and hence housing implications of the econometric projections, economic activity rate assumptions consistent with the projections being interpreted should be used.
Do you agree with this approach? NO
If No, what alternative approach should be used?
It is not transparent what economic activity rates are used for the over 60’s. A clarification would be helpful.
Jobs assessment period
The report assesses how many homes will be needed to support projected increases in jobs for the period 2014-2031.
Do you agree with this approach? NO
If No, what period should the assessment cover?
It is confusing. Why is the projected increase in j obs for the period 2014 – 2031 when the period for the assessment of OAHN is 2011 – 2031? The economic projection with an earlier start date covering the period 2011 – 2031 shows a higher figure.
Interpreting the economic forecasts
The report suggests that a reasonable allowance for additional housing to support economic growth would be for Stroud, Cotswold and Forest of Dean to provide between them for half the additional homes which the CE analysis suggests might be needed across Gloucestershire i.e. 2,700. If these are allocated in line with the relative housing numbers suggested by the CE analysis Stroud would provide 800 additional housing (rounded).
Do you agree with this approach? NO
If No, what alternative approach should be used?
The proposal to use only half the additional homes identified from the CE analysis is an arbitrary choice. Why not more than half or even all?
Other matters
Please provide brief details of any other factors which should be taken into account in identifying an OAHN for Stroud.
The OAHN should also give consideration to the dist ribution of housing needs across the Gloucestershire HMA so that no unmet nee ds arise because an individual LPA is proposing a housing requirement i n its plan below OAHN.
Contact Details
Please provide contact details so that we can ensure that your comments can be reflected in the Statement of Common Ground.
What are the objectively assessed needs for housing in Stroud District?
Statement of Common Ground Questionnaire
Background
The Stroud District Local Plan was submitted to the Planning Inspectorate in December 2013. Examination hearing sessions dealing with housing requirements were held in April 2014. The Inspector’s Stage 1 initial conclusions were published in June 2014. The Inspector concluded that further work was necessary to ensure that a soundly based objective assessment of housing requirements had been undertaken.
The District Council commissioned Neil McDonald (NMSS) in July 2014 to undertake a study of the objectively assessed needs for housing in Stroud from first principles.
In response to a query from a hearing participant, the Inspector asked the Council to consider holding a technical workshop with representors who have challenged the objective assessment of housing need in order to try to narrow the issues in dispute and prepare a Statement of Common Ground identifying areas of agreement and disagreement. This may assist in establishing the respective positions of the various parties before any further hearing sessions resume.
On 14 October 2014 a technical workshop was held in the Council Chamber, Ebley Mill, Stroud. A draft Executive Summary and presentation slides were circulated in advance of the workshop. Participants asked questions and gave views during the workshop and were given until 24 October 2014 to write in with further comments and queries. Five responses were received by the District Council.
Following the workshop, Neil McDonald has now completed his final report taking into account views expressed during and after the workshop. The full report has now been published.
Statement of Common Ground
The District Council has prepared this focused questionnaire which will be used to compile a factual Statement of Common Ground between the Council and representors, identifying the areas of agreement and disagreement.
Representors are requested to fill in this questionnaire and to return it to Helen Johnstone [email protected] at the District Council by 26 November 2014.
Please answer the questions set out in the questionnaire and the questionnaire responses will be reported to the Inspector. It will be for the Inspector to seek clarification of positions through any future hearing session on housing requirements, once the examination is reopened.
Stroud District Council 5 November 2014
2
QUESTIONNAIRE
Instructions for completing questionnaire.
Please respond to the questions by highlighting Yes/No and provide a brief text response where asked summarising your position. Please do not attach further supporting information at this stage as this will n ot be reported to the Inspector.
Population Forecasts
The report takes as its starting point the population estimates from the interim 2011 based subnational population projections for England (2011 SNPP) and the 2012 subnational population projections for England (2012 SNPP). The report concludes that the 2012 SNPP, with due allowances, should generally be adopted as the more reliable projection.
Do you agree with this approach? Yes/No (please highlight as appropriate)
If No, what population estimates should be the starting point for the report?
The starting points are fine in themselves but the “Due allowances” used in this report are not valid as described in the relev ant sections below. The allowances appear to have been added to achieve a p redetermined figure. We question whether the report is Objective and as suc h is not sound in a number of areas.
Components of Change
The report examines data relating to various components of change - Births, Deaths, UK inflow, UK outflow, International migration in and international migration out.
Births
The report concludes that the 2012 based projections are a better basis for forecasting future births than the 2011 based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of future births be based upon?
Deaths
The report concludes that there is no reason to question this aspect of the 2012 based projections.
Do you agree with this approach? Yes/No
3
If No, what should the forecast of future deaths be based upon?
UK inflows and UK outflows
The report adjusts UK inflows and outflows based on the ratio of the average annual flows over a 10 year period 2002 – 2012 to the flows over the period 2007-12, rather than the 2012 based projections which reflect a 5 year trend 2007-2012.
Do you agree with this approach? Yes/No
If No, what should UK inflows and outflows be based upon?
These “adjustments” are not valid for three reasons :-
1. They are attempting to fit a “UK wide” solution to Stroud. 2. The 2012 population projections already include an updated formula for
migratory flows in the UK (as confirmed by the ONS) 3. Neil Macdonald has assumed that the “post recess ionary” population
projections would be reduced by the effects of the recession. Referral to the ONS data confirms that his “assumption” is inco rrect. The trend from the last five years shows an increased populat ion projection for Stroud (as confirmed by the ONS in writing to our D SS). If Neil McDonald and SDC wish to “return to trend” then a lower population projection must be used deflating the housing requirement. Impact on OAHN ………50 Houses
International migration flows
The report concludes that there is no reason to question this aspect of the 2012 based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of international migration be based upon?
4
Unattributable population change (UPC)
The report includes the UPC for Stroud (for the period 2001-2011) in the calculation.
Do you agree with this approach? Yes/No
If No, should the UPC be excluded or some other adjustment made?
UPC is a measure of a previous projection’s accurac y between two census points. Neil McDonald appears to be implying that a ll ONS population projections have to be corrected by a UPC. This ass umption is not credible
The 2012 projections have already been corrected to the 2011 census data. The ONS have confirmed in writing that UPC should n ot be used in this way.
Additionally, the components of UPC show that the i nternal migration is the major contributor to the UPC. The ONS confirms in w riting that the 2012 projections have been updated to include this chang e in internal migration.
The use of UPC here is completely UNSOUND.
Impact on OAHN……………….200 houses
Estimate Population
The report estimates an increase of 14,100 people in Stroud in the period 2011-2031 (or 16,700 people in Stroud in the period 2006-2031).
Do you agree with these figures? Yes/No
If No, what should the figures be?
Neil Macdonald has not presented any valid evidence that backs up the increasing of the 13,600 number from the ONS projec tion in the period 2011-2031. In addition the Local Plan makes no argument for any action to increase the projected population. Indeed it emphasises the use of the ONS and DCLG projections.
His “adjustments” are not supported by the ONS or D CLG guidance – To achieve this higher figure the report does not “est imate an increase”. It creates an increase through invention – an erroneous correc tion value, UPC or “double counting”.
ONS and DCLG statements and guidance confirm this a ssertion.
The 16,700 figure is therefore UNSOUND.
The ONS projected figure of 14,100 has to be used a s it is the only one with a credible evidence base.
5
Household Formation Rates
The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are half way between the 2008 and 2011 based rates. Thereafter household formation rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups. Do you agree with this approach? Yes/No
If No, what assumptions regarding household formation rates should be used?
Neil Macdonald doesn’t go into the detail of the co mponents of change included in the 2011-based DCLG household projectio ns properly. If he had, he would note that the household formation rates used are from the very optimistic 2008-based (pre-recessionary) DCLG proje ctions. This information is present in the DCLG release notes, so the househ old projections that come from this data set are therefore based on pre-reces sionary data
Neil Macdonald then carries out a “correction” to t his projection using previous (2008-based) data, without first correctin g this data with the very UPC that he has explained in such great detail else where. If he had, then there would be no correction to carry out.
This essentially applies the “return to trend” logi c twice. Impact on OAHN………250 houses
Empty and second homes
The report includes an allowance of 3.96% for empty and second homes
Do you agree with this figure? Yes/No If No, what should the figure be?
The previous figure presented by SDC was 3.2% (from SDC’s own records). Why is this different? His data is based on 2011 in formation – the 3.2% number is informed by later information presented by Keith Woodhead. The use of this out-of-date number is contrary to NPPF guidance on using the latest data.
Housing needed from demographic calculations
The report states that 8,700 additional homes will be needed 2011-2031 (10,400 additional homes for 2006-2031) based on demographic based calculations
Do you agree with this figure? Yes/No If No, what should the figure be?
The “adjustments” made to the base number of houses are not valid – they rely on the inappropriate addition of UPC in the po pulation base, then fail to take UPC into account when applying older projectio n data.
The correct (ONS – advised) demographic based calcu lation would be: - 8,200
6
Market signals
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
Under supply
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
Concealed Families
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
Overcrowding
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
Affordable housing
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?
7
Supporting economic growth
Economic forecasts
The report uses the latest 2014 economic projections from two forecasters – Cambridge Econometrics and Oxford Economics.
Do you agree with this approach? Yes/No
If No, what alternative or additional economic forecasts / considerations should be used?
At Neil McDonalds presentation given in the counci l chambers he stated that the CE data was for the South West region. Since th at time the data we have now seen is presented as Stroud Data. No explanatio n as to this change has been. Could we have an explanation that is supporte d by the working papers please?
Given that the SW has at least eight very large cen tres of population and employment, the differences are very significant.
By Contrast Oxford has provided Stroud District spe cific data. One would have expected that this survey would have been given mor e weight than the CE data based on the South West.
The decision of how to balance the two sets of data is unclear and should be laid out more logically to survive detailed scrutin y. Without that, this is segment of the report is potentially UNSOUND.
Economic activity rates
The report suggests that in estimating the labour force and hence housing implications of the econometric projections, economic activity rate assumptions consistent with the projections being interpreted should be used.
Do you agree with this approach? Yes/No
If No, what alternative approach should be used?
Please see previous question
This methodology is inadequately explained, not obj ective and is therefore potentially UNSOUND.
8
Jobs assessment period
The report assesses how many homes will be needed to support projected increases in jobs for the period 2014-2031.
Do you agree with this approach? Yes/No
If No, what period should the assessment cover?
It is inappropriate to project economic growth over such a long timescale. Government departments are struggling to do this a year or two into the future.
The Euro area is almost back in recession. China’s growth rate is beginning to slow. Growth rates are slowing across Asia.
No economy in the world has ever gone twenty years without at least one recession: usually two. To project such high and su stained levels of economic job creation over a twenty-year period is both unre alistic and UNSOUND.
We have another census in seven year’s time a revie w date should be planned now. This is both common sense, and in line with th e NPPF.
Interpreting the economic forecasts
The report suggests that a reasonable allowance for additional housing to support economic growth would be for Stroud, Cotswold and Forest of Dean to provide between them for half the additional homes which the CE analysis suggests might be needed across Gloucestershire i.e. 2,700. If these are allocated in line with the relative housing numbers suggested by the CE analysis Stroud would provide 800 additional housing (rounded).
Do you agree with this approach? Yes/No
If No, what alternative approach should be used?
The CE analysis is the ONLY ONE that supports this expansion level, and is not focussed on Stroud, but is based on the South W est (as stated by Neil McDonald’s in his presentation in the council chamb ers). The OE analysis for Stroud, in contrast ,concludes that Stroud’s plan w ould include ample houses for job-related growth.
Further, Neil McDonald’s report makes an arbitrary decision concerning the number of jobs that Stroud itself would support. Th is is not based on any neighbouring local plan, or any other evidence (oth er than the CE report for the SW). This level of jobs increase is extremely u nlikely in Stroud. Also It
9
represents a massive increase in out-commuting from Stroud, which is contrary to the policy stated in the local plan.
We also understand that the Forest of Dean have st rong reservations about Neil McDonald’s report. There is therefore no agree ment between the LPAs on the likely jobs growth.
Further, there is no mention of the “duty to cooper ate” which is an absolute requirement especially if Stroud is considering to take 50% of something that only two parties out of three have agreed. This mea ns that SDC do not know the number from which they are agreeing to take 50% . (Stroud’s population at 113,000 compares to the FoD and Cotswold combined o f around 165,000).
This approach conflicts head-on with the SDC policy to reduce out-commuting.
The addition of these 800 houses is not logical, ob jective or SOUND.
Other matters
Please provide brief details of any other factors which should be taken into account in identifying an OAHN for Stroud.
1. Neil Macdonald has failed to take the elderly po pulation into account with respect to C2 housing, as deemed mandatory by Para 037 of the National Planning Guidance, 6 th Match 2014 and 6 th October 2014. Whilst we understand that his ToRs did not include this analysis, we fee l a consultant statistician would have flagged the SINGLE largest demographic c hange : the number of over 75s in Stroud District is due to rise by over 60% (sixty percent) over the plan period.
There are currently 1204 Class C2 bed spaces in Str oud District, substantially occupied by over 75s. A first estimate of the impac t of the demographic shift would be to plan for 722 bed spaces (Class C2) in t he Plan Period AND to remove these 722 people from the General Housing re quirement.
In Neil McDonald’s report all 722 people are assume d to be wanting a house, in the formation ratio of 2.2 per household, thus over -counting the General Housing requirement by (722/2.2) 328 houses.
Impact on OAHN..…(deduct) 328 houses ADD 722 residential Class C2
Cumulative total impact on OAHN…
Deduct (328,200,50,250= 828)….10,372 houses
Add…residential Class C2..………..722 beds
= 11,094 units
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2. This OAN fails to answer the specific questions set by the inspector:-
• It does not match the process used by JCS to inform their housing need or attempt to explain the differences – see note be low.
• It does not seek to back up, or explain, the previo us work carried out by Keith Woodhead.
• It carries out an additional assessment that isn’t what the inspector asked for.
• It fails to explain why alternative data sources ar e not compared – “POPGROUP”, “HEaDROOM”, “What Homes Where”.
• It fails to answer the inspectors query on the affo rdable housing number.
• The relationship between the Gloucestershire Strate gic Economic Plan and the Local plan is not made clear.
Note –
1. The “objectively assessed” housing number for th e JCS area has been calculated by a very different method to the one us ed for Stroud. In his published “JCS method”, Neil Macdonald calculated h is average household size from the officer-supplied housing nu mber and ONS population projection. Then, it was no surprise thi s original number was the result when this average household size was use d in his calculations. This effectively chose a number first , and then made the calculations fit this number. Evidence of this is i n a JCS report provided to councillors and available.
2. Included in this very same document is the state ment:- “In absolute numbers, the change in the fertility rate is the largest factor, with the annual birth rate for 2012 falling from 733,000 in the 2011 based projections to 693,000 in the 2012 set, a reduction of 40,000 a year. A reduction had been anticipated as it had been acknowledged by ONS that the approach used in the 2011 based projections had led to an overestimation of births. However, as children do not form households this fall in births will not have a significant impact on the number of households in the next 20 years” This quite remarkable assertion was then paraphrase d by Neil Macdonald’s written responses to councillor’s quest ions in the report as: - “ Babies don’t buy houses” This strange methodology does not appear to have be en applied in the Stroud calculation.
3. Neil McDonald’s reports to the JCS have the CCHP R and Cambridge University logos displayed prominently on the front sheet, so claiming accreditation from these institutions.
4. At the presentation on the 14 th October (and in SDC notes to the inspector) Neil McDonald was presented as being par t of CCHPR.
11
5. We have contacted Cambridge University and CCHPR and they confirmed that Neil MacDonald is a Client (Customer ) of CCHPR. He has no employment connection directly to Cambridge Univ ersity.
6. Neither Cambridge University nor CHHPR have any sponsorship, oversight or responsibility for any of the reports produced by Neil MacDonald, neither for the JCS nor Stroud areas.
7. The presence of the names and logos of Cambridge University and CCHPR on the cover sheet would appear to attribute accreditation that does not exist.
As a community group we are again very seriously co ncerned that data appears to have been manipulated to produce a parti cular answer. For the JCS area, Neil Macdonald has acknowledged this in writi ng . Keith Woodhead’s original TOR’s instructed a particular number in th e same way. Has the same thing happened here?
Contact Details
Please provide contact details so that we can ensure that your comments can be reflected in the Statement of Common Ground.
Please respond to the questions by highlighting Yes/No and provide a brief text
response where asked summarising your position. Please do not attach further
supporting information at this stage as this will not be reported to the
Inspector.
Population Forecasts
The report takes as its starting point the population estimates from the interim 2011
based subnational population projections for England (2011 SNPP) and the 2012
subnational population projections for England (2012 SNPP). The report concludes
that the 2012 SNPP, with due allowances, should generally be adopted as the more
reliable projection.
Do you agree with this approach? Yes/No (please highlight as appropriate)
If No, what population estimates should be the starting point for the report?
Components of Change
The report examines data relating to various components of change - Births, Deaths,
UK inflow, UK outflow, International migration in and international migration out.
Births
The report concludes that the 2012 based projections are a better basis for
forecasting future births than the 2011 based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of future births be based upon?
Deaths
The report concludes that there is no reason to question this aspect of the 2012
based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of future deaths be based upon?
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UK inflows and UK outflows
The report adjusts UK inflows and outflows based on the ratio of the average annual
flows over a 10 year period 2002 – 2012 to the flows over the period 2007-12, rather
than the 2012 based projections which reflect a 5 year trend 2007-2012.
Do you agree with this approach? Yes/No
If No, what should UK inflows and outflows be based upon?
International migration flows
The report concludes that there is no reason to question this aspect of the 2012
based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of international migration be based upon?
Unattributable population change (UPC)
The report includes the UPC for Stroud (for the period 2001-2011) in the calculation.
Do you agree with this approach? Yes/No
If No, should the UPC be excluded or some other adjustment made?
Estimate Population
The report estimates an increase of 14,100 people in Stroud in the period 2011-2031
(or 16,700 people in Stroud in the period 2006-2031).
Do you agree with these figures? Yes/No
If No, what should the figures be?
Household Formation Rates
The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are half way between the 2008 and 2011 based rates. Thereafter household formation
4 | P a g e
rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups.
Do you agree with this approach? Yes/No
If No, what assumptions regarding household formation rates should be used?
Pegasus Group considers that as a minimum a consistent full return to trend (rebased to
take account of the 2011 Census) should be used for all age groups in order that the
negative trends experienced during the recession are not planned for (contrary to the third
core planning principle of the NPPF).
The projections include an arbitrary application of different headship rates during the plan
period, and so should not be used to support a phasing policy.
Furthermore, the way in which the partial return to trend is applied, such that a mid-point
between the 2011 and 2008 headship rates is adopted, effectively plans for a medium
economic growth scenario following a negative growth scenario, rather than being
aspirational (in conformity with paragraph 154). Pegasus Group consider that it is
appropriate to apply the negative headship rates of the 2011 projections during the short-
term i.e. to 2015, but then to apply the growth rates implied in the 2008 projections from
2016 onwards to provide for a balanced market.
The effect of a consistent return for all age groups results in an increased demographic led
need of 9,200 homes as identified in Figure E2. However, the application of a full return to
trend (rebased) as preferred by Pegasus Group will result in different figures.
Pegasus Group support the application of the 2011 rates over the short-term before
adjusting to longer term trends as this provides for a balanced projection over a plan period.
However, the arbitrary application has a very significant impact on the variability of
household growth during the period and cannot be robustly used to develop any phasing
policy. Paragraph 136 suggests some sort of phasing based upon this evidence, but the
arbitrary and unjustified application of household formation rates undermines the evidence
supporting this.
Empty and second homes
The report includes an allowance of 3.96% for empty and second homes
Do you agree with this figure? Yes/No
If No, what should the figure be?
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Housing needed from demographic calculations
The report states that 8,700 additional homes will be needed 2011-2031 (10,400
additional homes for 2006-2031) based on demographic based calculations
Do you agree with this figure? Yes/No
If No, what should the figure be?
Pegasus Group can only draw on the information contained in the report, which identifies a
consistent partial return to trend projection of 9,200 homes. However, if the headship rates
provided for more aspirational economic growth, it is likely that these would identify a
significantly increased demographic led housing need.
Market signals
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should
be added to the housing requirement to take into account this factor?
Pegasus Group note that the report now includes a section on market signals however it
concludes that there is no case for making adjustments. Pegasus Group considers that
adjustments need to be made to reflect some market signals including under supply and
affordable housing as identified in the following sections.
Under supply
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should
be added to the housing requirement to take into account this factor?
Pegasus Group consider that at least a further 400 homes should be provided to address the
unmet need arising from previous under-supply in Stroud. The 2011 Census identifies 376
concealed households, and in February 2014 Stroud Council was aware of 22 homeless
households. No information is available on the number of shared households. Nevertheless,
this demonstrates that as a minimum of the order of 400 additional homes need to be
provided to cater for this need. This is co-incidentally consistent with the level of under-
delivery relative to the Council’s proposed objectively assessed need from 2006 to 2014.
Furthermore, the report only assesses job growth from 2014-2031. This means that the job
growth from 2011-2014 is not considered which may have demonstrated an additional need
6 | P a g e
for housing. This further supports the application of an allowance to account for any under-
supply.
Concealed Families
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should
be added to the housing requirement to take into account this factor?
See previous comments on under-supply
Overcrowding
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should
be added to the housing requirement to take into account this factor?
Affordable housing
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes/No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should
be added to the housing requirement to take into account this factor?
An up-to-date assessment of the objectively assessed need for affordable housing is
required. However, the affordable need identified in the now out-of-date SHMA could be
met by providing for a minimum of 10,700 homes (plus historic unmet needs of
approximately 400 dwellings needs) assuming 30% of delivery is affordable. This will
increase once the required assessment is undertaken, but provides a useful indication for
now.
The PPG (2a-029) requires that the total number of affordable homes is considered. This is
consistent with paragraph 47 which requires that the full objectively assessed need for
market and affordable homes is provided for. The report, however, dismisses the affordable
need, on the basis that it would be undeliverable. Such an assertion cannot be justified
without the affordable need firstly being established.
7 | P a g e
Supporting economic growth
Economic forecasts
The report uses the latest 2014 economic projections from two forecasters –
Cambridge Econometrics and Oxford Economics.
Do you agree with this approach? Yes/No
If No, what alternative or additional economic forecasts / considerations should be
used?
The projections used are one source of appropriate information. However, no consideration
of the Gloucestershire SEP as identified in the Inspector’s Interim Report appears to have
been undertaken.
Economic activity rates
The report suggests that in estimating the labour force and hence housing
implications of the econometric projections, economic activity rate assumptions
consistent with the projections being interpreted should be used.
Do you agree with this approach? Yes/No
If No, what alternative approach should be used?
Jobs assessment period
The report assesses how many homes will be needed to support projected increases
in jobs for the period 2014-2031.
Do you agree with this approach? Yes/No
If No, what period should the assessment cover?
See previous comments on under supply.
Interpreting the economic forecasts
The report suggests that a reasonable allowance for additional housing to support
economic growth would be for Stroud, Cotswold and Forest of Dean to provide
between them for half the additional homes which the CE analysis suggests might be
needed across Gloucestershire i.e. 2,700. If these are allocated in line with the
relative housing numbers suggested by the CE analysis Stroud would provide 800
additional housing (rounded).
Do you agree with this approach? Yes/No
If No, what alternative approach should be used?
8 | P a g e
Pegasus Group considers that the objectively assessed need required to support economic
growth is identified in Figure 42 for each District (subject to the application of justifiable
household formation rates as previously raised). A revised distribution can be proposed
within the HMA but only if it was explicitly agreed with the JCS authorities that the JCS area
would deliver an additional 2,700 homes to respond to the displaced economic needs of
Stroud, Cotswold and the Forest of Dean. Given that the JCS has been submitted to the
Secretary of State on 20th November and does not include an allowance for 2,700 dwellings,
it is not clear how this issue can be addressed at this late stage in the planning process.
Other matters
Please provide brief details of any other factors which should be taken into account
in identifying an OAHN for Stroud.
The previous matters identify the objectively assessed need, subject to additional evidence
that would be required.
Based on the current evidence base, which has significant weaknesses as identified
throughout this response, the objectively assessed need for the period 2011 to 2031 for
Stroud District is at least 11,100 (10,700+400). However, once the headship rates have been
applied in a robust way that provides for economic growth, and once the affordable need
has been updated to reflect this, it is likely that the objectively assessed need will be
significantly greater.
Paragraph 153 of the report identifies a different time period for the Stroud Local Plan as
compared to all the preceding analysis. This presents a fundamental error in the
assessment. Housing completions from 2006 will have influenced the projections and so the
early part of the purported objective assessment of need simply reflects what has been built
rather than what is required. As a result, there is no objective assessment of need from
2006 to 2011 (the base date of the national household projections) and yet the report
purports to assess this need from 2006 to 2031.
Contact Details
Please provide contact details so that we can ensure that your comments can be
reflected in the Statement of Common Ground.
Name: Neil Tiley
Organisation: Pegasus Group on behalf of Robert Hitchins Ltd
Ms Helen Johnstone Planning Policy Stroud District Council Ebley Mill Ebley Wharf Stroud GL5 4UB
Dear Helen
Stroud District Local Plan Objectively Assessed Need – Statement of Common Ground
On behalf of my clients, Redrow Homes Limited, please find enclosed a completed questionnaire in respect of the Statement of Common Ground on the objectively assessed need for housing in Stroud District. I would be grateful if you could confirm receipt and also keep me informed of any future developments. In particular, could you please confirm whether the NMSS report has been considered by Members as yet? Kind regards Yours sincerely For RPS
Alistair Macdonald Director cc: Mr Keith Annis, Redrow Homes Ltd. Encs: Statement of Common Ground Questionnaire – response of Redrow Homes Limited
What are the objectively assessed needs for housing in Stroud District?
Statement of Common Ground Questionnaire
Background
The Stroud District Local Plan was submitted to the Planning Inspectorate in
December 2013. Examination hearing sessions dealing with housing requirements
were held in April 2014. The Inspector’s Stage 1 initial conclusions were published in
June 2014. The Inspector concluded that further work was necessary to ensure that
a soundly based objective assessment of housing requirements had been
undertaken.
The District Council commissioned Neil McDonald (NMSS) in July 2014 to undertake
a study of the objectively assessed needs for housing in Stroud from first principles.
In response to a query from a hearing participant, the Inspector asked the Council to
consider holding a technical workshop with representors who have challenged the
objective assessment of housing need in order to try to narrow the issues in dispute
and prepare a Statement of Common Ground identifying areas of agreement and
disagreement. This may assist in establishing the respective positions of the various
parties before any further hearing sessions resume.
On 14 October 2014 a technical workshop was held in the Council Chamber, Ebley
Mill, Stroud. A draft Executive Summary and presentation slides were circulated in
advance of the workshop. Participants asked questions and gave views during the
workshop and were given until 24 October 2014 to write in with further comments
and queries. Five responses were received by the District Council.
Following the workshop, Neil McDonald has now completed his final report taking
into account views expressed during and after the workshop. The full report has now
been published.
Statement of Common Ground
The District Council has prepared this focused questionnaire which will be used to
compile a factual Statement of Common Ground between the Council and
representors, identifying the areas of agreement and disagreement.
Representors are requested to fill in this questionnaire and to return it to Helen
Please respond to the questions by highlighting Yes/No and provide a brief text
response where asked summarising your position. Please do not attach further
supporting information at this stage as this will not be reported to the
Inspector.
Population Forecasts
The report takes as its starting point the population estimates from the interim 2011
based subnational population projections for England (2011 SNPP) and the 2012
subnational population projections for England (2012 SNPP). The report concludes
that the 2012 SNPP, with due allowances, should generally be adopted as the more
reliable projection.
Do you agree with this approach? Conditional Yes/No (please highlight as
appropriate)
Response: The above text being mooted for agreement between parties in respect
of population forecasts states that the report concludes that the 2012 SNPP, with
due allowances, should generally be adopted as the more reliable projection.
Redrow does not consider that this is an acceptable statement to include within a
Statement of Common Ground given the subjective nature of the phraseology used.
Redrow will, however, agree that the evidence contained within the 2012 SNPP is
the starting point for determining the Objectively Assessed Need for Stroud District
on the basis that it represent the latest available information in the context of
paragraph 016 of the Planning Practice Guidance (PPG)
If No, what population estimates should be the starting point for the report?
Components of Change
The report examines data relating to various components of change - Births, Deaths,
UK inflow, UK outflow, International migration in and international migration out.
Births
The report concludes that the 2012 based projections are a better basis for
forecasting future births than the 2011 based projections.
Do you agree with this approach? Conditional Yes/No
If No, what should the forecast of future births be based upon?
Response: While Redrow agrees that the 2012 based projections birth evidence is
appropriate for projecting future births associated with population projections,
however, it is not clear from the report or statement above on the manner in which
the evidence has been used. The report sets out at paragraph 43 that the 2012
projections for births appear to be plausible projections, however, it is not clear from
the report whether the population profile has been used directly, or whether the
fertility rates have been used and applied to a base population profile.
This distinction is important in appraising alternative scenarios such as economic
scenarios, as it is important that age specific fertility rates are integral to establishing
revised population projections, to that of the baseline 2012 SNPP.
Further clarity is therefore required and Redrow is happy to engage further to reach
agreement on this.
Deaths
The report concludes that there is no reason to question this aspect of the 2012
based projections.
Do you agree with this approach? Conditional Yes /No
If No, what should the forecast of future deaths be based upon?
Response: Redrow agrees that the 2012 based projections are a better basis for
forecasting future deaths, however, similarly to the birth statement above, it is not
clear whether actual projection data or age specific mortality rates have been used.
Further clarity is therefore required and Redrow is happy to engage further to reach
agreement on this.
UK inflows and UK outflows
The report adjusts UK inflows and outflows based on the ratio of the average annual
flows over a 10 year period 2002 – 2012 to the flows over the period 2007-12, rather
than the 2012 based projections which reflect a 5 year trend 2007-2012.
Do you agree with this approach? Yes/No
Response: Redrow concurs that the use of a ten year observation period is more
robust in respect of internal migration trends.
If No, what should UK inflows and outflows be based upon?
International migration flows
The report concludes that there is no reason to question this aspect of the 2012
based projections.
Do you agree with this approach? Yes/No
If No, what should the forecast of international migration be based upon?
Response: The 2012 SPPP International Migration trends are constrained at a UK
level as set out in paragraph 30 of the Council’s Report. This is currently 154,000
people per annum. However it is already observed that the national constraint has
been exceeded in 2012, 2013 and 2014, with net migration in those years
comprising 184,000, 212,000 and 243,000 respectively. This amounts to an
additional 177,000 people over the ONS constraint cap in just three years. This
accounts for more than a single year of the ONS cap in itself within the three year
period. It is therefore clear that the Governments ONS cap of 154,000 has already
been exceeded substantially.
The 2012 SNPP is therefore considerably underestimating the level of international
migration. The exceedance of the Government’s constraint is therefore a serious and
significant factor to be considered. It is also observed that the constraint of 154,000
has only been achieved once since 2004. The Council should therefore incorporate a
sensitivity test of increasing international migration proportionally as observed.
A self-imposed Government constraint is no mechanism for forward forecasts.
Unattributable population change (UPC)
The report includes the UPC for Stroud (for the period 2001-2011) in the calculation.
Do you agree with this approach? Yes/No No objection
Response: Redrow raises no objection to the approach used with respect to UPC
If No, should the UPC be excluded or some other adjustment made?
Estimate Population
The report estimates an increase of 14,100 people in Stroud in the period 2011-2031
(or 16,700 people in Stroud in the period 2006-2031).
Do you agree with these figures? Yes/No
If No, what should the figures be?
Response: Redrow cannot at this time agree to this position as it seeks clarification
on a number of points above.
Household Formation Rates
The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are half way between the 2008 and 2011 based rates. Thereafter household formation
rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups.
Do you agree with this approach? Yes/No
If No, what assumptions regarding household formation rates should be used?
The Council’s Report contains a detailed review of recent changes in actual,
estimated and projected headship rates for Stroud (pp 29-35).
The most up to date official household projections are CLG’s 2011-based Interim
projections. The Councils Report explains that the rates used in these projections
were derived from the 2011 Census. This identified household formation rates which
differed from those used in the previous (2008-based) CLG household projections.
The Councils Report initially sets out (paragraph 46 refers) that the 2008-based
projections were based on trends which predated the economic downturn and which
could be taken as broadly indicative of previous longer term trends. However the
reprt subsequently suggests that as the 2008-projections failed to pick up some
trends which were apparently even before the downturn, the household formation
rates used in those projections are inappropriate as they stand and proposes a
partial return to these rates (paragraph 54 refers).
The difference between household formation rates in the two sets of projections
varies by age group. It is greatest for the 25-34 and over 60 age groups, but the
rates differ throughout the age spectrum.
For the 25-34 age group, the 2011-based projections suggest that the household
formation rates are lower than the 2008-based rates in 2011 and will continue to
diverge further over the 2011-2021 projection period.
The divergence for this age group from longer term trends is attributed in the
Council’s evidence to two factors. Firstly, significant international in-migration after
2001 reduced household representative rates because new in-migrants are more
likely to live in larger multi-person households than the rest of the population in this
age group, at least in the early years of residence. Research by Holmans1 attributes
around half of the reduction in household formation in the 25-34 age group nationally
to this cause. But as international migration levels in Stroud were less significant
than in many other areas, the report notes that the local impact might have been
less.
The second factor reducing the rate of household formation would have been an
increase in the tendency of people aged 25-34 to live together in shared houses/flats
or to remain living with parents.
1 Alan Holmans (2013) The Town & Country Planning Tomorrow Series Paper 16, New estimates of housing
demand and need in England, 2011 to 2031, TCPA/CCHPR.
ONS research2 using national data broadly supports this hypothesis. The Council’s
report sets out that this second element of change in household formation will mainly
have been brought about by the worsening economic situation after 2007, the
collapse in housing supply, and the difficulty in obtaining mortgages. This suggests a
return towards previous trends if economic conditions improve, together with some
elimination of ‘suppressed’ household formation. However, it also argues that the
changes in household formation started before 2007 as a result of the deteriorating
affordability of housing arising from rapid increases in house prices and rents. These
causes may be more enduring, for example if mortgage finance remains more
difficult to obtain than in 2006-07. It is also suggested that welfare benefit reforms
will have a permanent impact. This would support an argument for not returning to
2008 formation rates as these may not have reflected the pre-2007 trends.
The report’s discussion of the potential causes of reduced household formation in
the 25-34 age group is interesting, but does not provide a definitive basis for
determining what might happen to household representative rates in the future. The
report itself accepts that this is a matter of ‘judgement, not science’ (paragraph 55
refers). It considers that a return to the 2008-based projection household formation
rates is unlikely to occur because of the continuing impact of international migration,
and because an improvement in the affordability of housing would be needed on top
of a general improvement in economic circumstances. It opts instead for rates
gradually moving back to the mid-point between those used in the 2008-based
projections and in the 2011-based projections over the period from 2015-2025, after
which the ‘gap’ would remain constant.
There are clear anomalies in this approach which the report itself illustrates
unintentionally through the example in the chart in para 64. This shows an assumed
increase in rates over the period 2015-2025, followed by a fall in rates thereafter. No
clear reasoning is offered either for the ten year timescale for the recovery in rates
(2015-25) or for the threshold point at which convergence with the 2008-based
projections ceases. Most strangely, the decline in rates which follows is not justified
by reference to any demographic factors and it is hard to conceive what factors
might justify this. The decline is merely brought about mechanically by the extended
linear projection of the 2011-based projection household representative rates.
Nowhere in these projections do CLG make any claim to suggest that these rates
can reasonably be projected onward beyond 2021 and the report provides no
explanation for how this has been carried out.
The Council’ evidence shows less interest in household formation amongst other age
groups because these are ‘less clear’ (paragraph 57 refers) and proposes no
amendments to the 2011-based projection headship rates. Redrow consider that the
2 ONS (2012) Young Adults Living With Parents in the UK, 2011, available at
http://www.ons.gov.uk/ons/dcp171776_266357.pdf and ONS (2013) Families and Households in England and Wales 2011, available at http://www.ons.gov.uk/ons/dcp171776_296986.pdf
Please respond to the questions by highlighting Yes/No and provide a brief text
response where asked summarising your position. Please do not attach further
supporting information at this stage as this will not be reported to the
Inspector.
Population Forecasts
The report takes as its starting point the population estimates from the interim 2011
based subnational population projections for England (2011 SNPP) and the 2012
subnational population projections for England (2012 SNPP). The report concludes
that the 2012 SNPP, with due allowances, should generally be adopted as the more
reliable projection.
Do you agree with this approach? Yes (please highlight as appropriate)
Components of Change
The report examines data relating to various components of change - Births, Deaths,
UK inflow, UK outflow, International migration in and international migration out.
Births
The report concludes that the 2012 based projections are a better basis for
forecasting future births than the 2011 based projections.
Do you agree with this approach? Yes
Deaths
The report concludes that there is no reason to question this aspect of the 2012
based projections.
Do you agree with this approach? Yes
UK inflows and UK outflows
The report adjusts UK inflows and outflows based on the ratio of the average annual
flows over a 10 year period 2002 – 2012 to the flows over the period 2007-12, rather
than the 2012 based projections which reflect a 5 year trend 2007-2012.
Do you agree with this approach? Yes (but)
If No, what should UK inflows and outflows be based upon?
Broadly we agree (although in practical terms for the base demographic projection it
makes little material difference for Stroud). However, the implications for the working
age population and labour force need to be considered under the scenario for an
increase in households to increase the workforce.
International migration flows
The report concludes that there is no reason to question this aspect of the 2012
based projections.
Do you agree with this approach? Yes
Unattributable population change (UPC)
The report includes the UPC for Stroud (for the period 2001-2011) in the calculation.
Do you agree with this approach? Yes
Estimate Population
The report estimates an increase of 14,100 people in Stroud in the period 2011-2031
(or 16,700 people in Stroud in the period 2006-2031).
Do you agree with these figures? Yes, as a base starting point for estimating an
OAN
Household Formation Rates
The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are half way between the 2008 and 2011 based rates. Thereafter household formation rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups.
Do you agree with this approach? No
If No, what assumptions regarding household formation rates should be used?
First of all we do not see the logic in the partial return to trends for 24 to 34 year olds.
A 50% return from the 2011-based to the 2008-based headship rates is described as
a “prudent planning assumption”. To us this choice seems arbitrary. Earlier the report
described the factors that it has properly set out as reasons for the dampened
household formation rates (para 54). The report also accepts that the international
migrant affect is likely to be lower in Stroud that the England average (we are
grateful that the authors have picked up this point made earlier by us).
However, the report seems to offer a council of despair in terms of affordability
issues for younger people (not likely to change in the “foreseeable future” see para
55(b)). By 2031 we see no reason why the structural issues the report identifies
could and indeed should have not been addressed. To assume only 50% “catch up”
seems to be arbitrary.
We suggests that “positively planning” would instead assume that the economic
affordability issues for young people can and should be surmounted. Therefore at
the very least the planning assumption should assume full return to trends for those
aged 25 to 34 in Stroud. We believe from the earlier presentation that applying full
return to trends for this age group would increase the OAN purely on a demographic
basis by around 30 dpa to 460 dpa.
The report makes stronger points about dealing with the use of 2011-based forecast
household formation rates for other age groups.
Empty and second homes
The report includes an allowance of 3.96% for empty and second homes
Do you agree with this figure? Yes
Housing needed from demographic calculations
The report states that 8,700 additional homes will be needed 2011-2031 (10,400
additional homes for 2006-2031) based on demographic based calculations
Do you agree with this figure? No
If No, what should the figure be?
See above. At the very least we suggest that for those aged 25 to 34 there should be
full return to trends by 2031, we believe this would add of the order of 20 to 30 dpa to
the base demographic OAN.
Market signals
The report states that there is no strong case for additional housing on this ground
Do you agree? No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should
be added to the housing requirement to take into account this factor?
The report is too dismissive of the evidence on affordability and the case for a
market signals adjustment. Taking a longer time period (pre-dating 2001) there is
some evidence of a worsening in relative affordability in Stroud (which would be
consistent with the evidence suggesting relative constraint since the mid 1990s).
If the case for some level of market signal adjustment is accepted, then:
At the very least this argues strongly for the use of “undiluted” 2008 long term
trend household formation rates;
Earlier work by Regeneris has suggested that a market signals uplift could be
considerable greater especially if the intention is to ensure that previously
identified affordable housing needs.
We also note that the report says “It certainly would not be appropriate to
increase the total volume of housing planned for until the amount of affordable
housing that can be delivered through S106 agreements equals the affordable
housing need” (para 88). This may be reasonable in the context of purely
considering the need for market housing, by NPPF requires LPAs to aim to
meet the full need for market and affordable housing.
Under supply
The report states that there is no strong case for additional housing on this ground
Do you agree? No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should
be added to the housing requirement to take into account this factor?
We are a little sceptical of the analysis in the report. The data presented for Stroud
could well be influenced by the fact that the period from 1994/5 onwards saw
housebuilding rates fall relative to the England average (due to policy constraint).
Concealed Families
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes
Overcrowding
The report states that there is no strong case for additional housing on this ground
Do you agree? Yes
Affordable housing
The report states that there is no strong case for additional housing on this ground
Do you agree? No
If No, what additional level of housing for the period 2011-2031 (2006-2031) should
be added to the housing requirement to take into account this factor?
The report acknowledges that assessing affordable housing need is out of scope of
the work. It quotes PPG “An increase in the total housing figures included in the local
plan should be considered where it could help deliver the required number of
affordable homes”. However, it seem to ignore the role of an increase in the volume
of market housing to help deliver against the assessed need for affordable housing
in Stroud.
Supporting economic growth
Economic forecasts
The report uses the latest 2014 economic projections from two forecasters –
Cambridge Econometrics and Oxford Economics.
Do you agree with this approach? Yes, in part but….
If No, what alternative or additional economic forecasts / considerations should be
used?
We consider it sensible if possible to use two sets of forecasts where these are both
reasonably up to date. CE and OE are well respected forecasting houses. We accept
that there is a considerable degree of uncertainty around forecasts at a local level.
However, we have some concerns with how the forecasts have been used and
interpreted:
1. The work should have reviewed in more detail the evidence from past
economic and employment growth in Stroud (and elsewhere). This
provides a useful sense check. Clearly past trends should not necessarily be
extrapolated forward; there may be good reasons why some sectors such as
public services will see slower growth than historically due to squeezes on
public spending (but note that the ageing of the population in Stroud will
increase demand for some caring/health service).
2. An analysis of past trends over at least one economic cycle in Stroud
suggests, we consider, that the current OE forecasts are particularly cautious
for Stroud.
3. The OE forecasts have, for some reason, been reduced for Stroud over the
last 9 months even though the UK level forecasts have been upgraded. For
instance trough to trough (1993 to 2011) total employment in Stroud grew by
around 11,000 jobs in Stroud. The effective flat-lining of the OE forecasts for
Stroud from 2020 onwards are simply implausible. It is also the case that this
assumption is not consistent with that assumed in earlier work on future
employment land needs in the Stroud area.
4. We note the report states in the context of past trends that “the projections for
Stroud might be argued to be a little low”. This strikes us as a serious
understatement. The extrapolation in Figure 35 is a little difficult to interpret,
but for Stroud the flat-lining of growth especially in the OE forecasts beyond
2020 looks most implausible
5. The second key point is that the report focusses almost entirely on the
potential downsides to the employment forecasts and does not provide a
balanced assessment. This is spite of the report stating that “there is
considerable uncertainty in the projections, not that they are necessarily too
high or too low” (para 111). The sensitivity analysis focussed on lower rates of
jobs growth in certain sectors rather than for instance a slower rate of decline
in manufacturing employment in Stroud.
6. We note the comments made about productivity and jobs growth. However,
we have no reason to consider that future productivity growth is understated
by either CE or OE. This is clearly a factor these economic forecasters have
to consider carefully in their modelling. It is dangerous to try and compare the
recovery from the recent recession from that of the 1990s as the shape and
nature of the recession is fundamentally different.
7. We do not consider that the approach of sensitivity testing one sectoral
growth factor from the CE forecasts (public services) is necessarily robust
either. By the same token it could be argued that both sets of forecasts are,
for Stroud, less positive for the prospects of manufacturing jobs than historic
experience would suggest.
Economic activity rates
The report suggests that in estimating the labour force and hence housing
implications of the econometric projections, economic activity rate assumptions
consistent with the projections being interpreted should be used.
Do you agree with this approach? No
If No, what alternative approach should be used?
We can understand why the authors have taken this approach as, at one level, it
appears logical. It does however assume that the models are robust in their
assessment of economic activity rates at a local level. We do not consider that this is
always the case.
These forecasts are sensitive to the actual starting point, in terms of economic
activity rates by age and gender in 2011, and the nature of future population change.
The approach adopted by OE is very broad brush as they do not at a local level
forecast economic activity rates by age and gender groups. This is our preferred
approach and is possible using POPGROUP. We are wary of using the OE forecast
economically active and the consequent population and households which are all
contained in a “black box”.
We have carried out some analysis of the OE forecasts of working age population
and residents in employment over the period 2011 to 2031. They imply, certainly for
Stroud, an implausibly large increase in economic activity rates for the whole
population compared to the numbers aged 16-64. In Stroud the ratio is forecast to
rise to 95 in work for every 100 aged 16-64 (much higher than the UK ratio and from
a ratio of 85 in 2012). This would imply, given what we know about the age structure
forecasts by SNPP 2012, economic activity rates for the over 65 year olds by 2031
which are dramatically higher in Stroud than any forecasts we have seen elsewhere
(eg from the OBR).
This does not strike us as a sound basis for planning. A more robust approach is to
apply plausible increases in economic activity rates (based on national view of
increases by age group) to the forecasts population in Stroud, to see what for a
given population rise is the likely future workforce. This can then be compared to
plausible employment forecasts to see what the implications for housing are.
.
Jobs assessment period
The report assesses how many homes will be needed to support projected increases
in jobs for the period 2014-2031.
Do you agree with this approach? No
If No, what period should the assessment cover?
It is not entirely clear what the authors have done. If they have ignored the jobs rise
2011 to 2014 then this is seriously flawed. By focussing on the period after 2014
the authors would be missing out on a particularly important period of jobs growth
since the middle of the recession (both CE and OE suggest that around 50% of all
jobs growth 2011 to 2031 is in the first three years 2011 to 2014 in the case of
Stroud). The effect has been that any spare labour has largely been mopped up in
Stroud during this three year period. The authors say “moreover, from a very
practical point of view, it is the period from now onwards that is most relevant” (para
125). This of course ignores the effect that the economic/jobs growth over the last
three years will have had on the labour market and spare capacity. The start date
and time period considered is therefore important.
Also the speed of the recovery in different places may have influenced the
subsequent degree of catch up post 2014, so the performance in 2011 to 2014 and
subsequently is intimately linked.
Interpreting the economic forecasts
The report suggests that a reasonable allowance for additional housing to support
economic growth would be for Stroud, Cotswold and Forest of Dean to provide
between them for half the additional homes which the CE analysis suggests might be
needed across Gloucestershire i.e. 2,700. If these are allocated in line with the
relative housing numbers suggested by the CE analysis Stroud would provide 800
additional housing (rounded).
Do you agree with this approach? No
If No, what alternative approach should be used?
Our first concern is that the work is not at all clear and transparent in:
1. Exactly how the authors have calculated the extra housing need for “surplus”
jobs over what the base labour requirement is for Stroud (in Figure 40)
2. The assumed relationship between extra jobs and extra labour force,
population and houses
It is difficult therefore to understand exactly how or indeed why the authors have
arrived at the 800 adjustment for Stroud. Based on the CE forecasts the adjustment
should have 1,800 or increasing the 20 year OAN to 525 dpa. This increase would
have been more in line with that proposed for Cotswold and Forest of Dean.
Other matters
Please provide brief details of any other factors which should be taken into account
in identifying an OAHN for Stroud.
We have consistently argued that setting an OAN from 2006, which is now 8 years
ago does not make sense. It also has the effect of reducing the average annual OAN
due to the particular changes that took place over that period. Other areas in
Gloucestershire (such as the JCS area) are using 2011 as the starting point. This
makes a lot more sense as we have a firm fix on a number of data points in 2011
due to the Census. We are not aware of other LPA (who have yet to derive an OAN)
who are trying to assess the OAN from a starting point as far back as 2006. We
understand that this is not the choice of the authors.
Contact Details
Please provide contact details so that we can ensure that your comments can be
reflected in the Statement of Common Ground.
Name: Stephen Nicol
Organisation: Regeneris Consulting (acting on behalf of Gladman