Initial Strategic Housing Market Assessment for Central Bedfordshire & Luton

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Comment

Technical Reports

Representation ID: 573

Received: 03/08/2017

Respondent: Harlington Parish Council

Representation:

SHMA lacks clarity and thus diminishes the validity of the numbers of dwellings proposed. Lack of 'very special circumstances' to warrant release of GB land.
See attachment for detailed issues on the SHMA

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See attachment for comments from Harlington Parish Council

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Comment

Technical Reports

Representation ID: 3221

Received: 29/08/2017

Respondent: Mr Martin Walker

Representation:

All major housing developments must include the requirement to both allocate space for non-housing (such as shops, schools, medical centres, parks, etc) AND to mandate the provision of suitable buildings that deliver this capability. Allowing development of housing without the accompanying infrastructure (buildings and roads) is unacceptable

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All major housing developments must include the requirement to both allocate space for non-housing (such as shops, schools, medical centres, parks, etc) AND to mandate the provision of suitable buildings that deliver this capability. Allowing development of housing without the accompanying infrastructure (buildings and roads) is unacceptable

Object

Technical Reports

Representation ID: 3824

Received: 29/08/2017

Respondent: Legal & General Capital

Agent: Savills

Representation:

Please see attached

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Please see attached

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Object

Technical Reports

Representation ID: 3860

Received: 29/08/2017

Respondent: Hollins Strategic Land LLP (HSL)

Agent: Nexus Planning

Representation:

2.13 Overall HLS is firmly of the view that the Central Bedfordshire FOAN figure of 1,600 dpa as set out within the Interim SHMA 2017 fundamentally under assesses current and future housing needs over the period covered by the Local Plan. Consequentially the LP is currently unsound as it fails to be positively prepared, justified or consistent with national policy. To address these soundness issues, prior to the publication of the Regulation 19 Pre Submission Local Plan, a fundamental review of the Interim SHMA 2017 must be undertaken.

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2.1 Hollins Strategic Land (HSL) supports the Council's recognition that the draft Local Plan needs to be flexible at this stage, given it is still a considerable way off formal submission to the Secretary of State for Examination. In reviewing the overall spatial strategy proposed in the draft Local Plan, HSL are keen to raise the following comments and concerns.
Overall Housing Figure
2.2 The latest iteration of the Luton and Central Bedfordshire Strategic Housing Market Assessment, May 2017 (the Initial SHMA 2017) indicates that the full objectively assessed need (FOAN) for housing in Central Bedfordshire over the Local Plan period of 2015 to 2025 is 32,000 (1,600 dwellings per annum (dpa)).
2.3 However, we note that the 2014-based official household projections (the latest official projections), with the same vacancy and second home rate as applied within the Initial SHMA (4.1%), provides a Planning Practice Guidance (PPG) (ID: 2a-015) demographic starting point housing figure of 1,800 dpa over the period covered by the Local Plan. A housing figure 200 dpa higher than that concluded as FOAN within the Initial SHMA 2017.
2.4 Furthermore, we note having analysed market signal indicators that the Initial SHMA 2017 concludes that a 10% upward adjustment is justified and appropriate. Once applied, the PPG starting point figure of 1,800 dpa should increase to at least 1,980 dpa (if only a 10% markets signals adjustment is accepted). A housing figure 380 dpa higher than that concluded as FOAN within the Initial SHMA 2017.
2.5 The demographic starting point figure within the Initial SHMA 2017 appears to be based on the 2014-based sub-national population projections (2014-based SNPP) but adjusted to apply 10-year migration trends (between 2005 and 2015) as opposed to the shorter migration trend period applied within the 2014-based SNPP (5-year internal and 6-year international migration trends).
2.6 Whilst it is accepted that the current PPG does allow plan-makers to make adjustments to the official projections, the PPG is expressly clear (ID: 2a-015 and 2a-017) that any local changes would need to be clearly explained and justified on the basis of established sources of robust evidence.
2.7 Of fundamental concern is that for Central Bedfordshire, the Initial SHMA 2017 fails to provide any local evidence to support the migration adjustments made. The Initial SHMA 2017 only appears to state that "short-term migration trends are generally not appropriate for long-term planning, as they risk rolling-forward rates that are unduly high or unduly low. Projections based on long-term migration trends are likely to provide a more reliable estimate of future households". In accordance with criteria set out within paragraph 182 of the National Planning Policy Framework ('the Framework'), for the housing figure within the Local Plan to be sound, the SHMA must either:
(a) Clearly explain and justify using established sources of robust evidence the specific Central Bedfordshire circumstances that necessitate the use of 10-year migration trends over the shorter trends underpinning the 2014-based official projections; or
(b) Revert to the 2014-based official projections to provide the demographic starting point estimate of housing need (1,800 dpa).
2.8 In the absence of any local evidence, HSL is firmly of the view that the official 2014-based official projections provide the most appropriate PPG complaint demographic starting point housing figure (1,800 dpa).
2.9 We note that the Interim SHMA 2017 concludes that an adjustment to address suppressed household formation is required. Having reviewed Central Bedfordshire's household formation rates, particularly the for younger age groups, HLS agrees with this conclusion. However, we question the extent to which only a 15 dpa uplift (301 dwellings over the 2015 to 2035 period) would make any meaningful improvement to address suppressed household formation rates within Central Bedfordshire.
2.10 Having reviewed the market signals analysis within the Interim SHMA 2017, we question the extent to which only a 10% market signals upward adjustment is considered justified for Central Bedfordshire. Given the worsening affordability issues evidenced within the Interim SHMA 2017, HLS is of the view that the Council should consider, in accordance with the PPG (ID: 2a-020), a larger response in order to help make a more meaningful improvement.
2.11 Our concerns set out above in relation to the starting point estimate of housing need consequentially also infect the affordable housing assessment within the Interim SHMA 2017, as the affordable housing model is in part underpinned by the starting point estimate of housing need. Furthermore, the affordable housing assessment methodology applied within the Interim SHMA 2017 also appears to be inconsistent with the wider methodology prescribed within the PPG (namely ID: 2a-022 to 029). For example, a downward adjustment is made to newly arising need associated with those households who leave the area as they are 'unable to afford housing costs'. Surely, such households are those who should be captured within the affordable housing needs assessment.
2.12 HSL is therefore firmly of the view that the affordable housing assessment within the Interim SHMA 2017 under assesses the level of affordable housing need within Central Bedfordshire over the period 2015 to 2035.
2.13 Overall HLS is firmly of the view that the Central Bedfordshire FOAN figure of 1,600 dpa as set out within the Interim SHMA 2017 fundamentally under assesses current and future housing needs over the period covered by the Local Plan. Consequentially the LP is currently unsound as it fails to be positively prepared, justified or consistent with national policy. To address these soundness issues, prior to the publication of the Regulation 19 Pre Submission Local Plan, a fundamental review of the Interim SHMA 2017 must be undertaken.
2.14 Notwithstanding the above, we are also mindful that the Government will shortly be publishing a revised 'more standardised' methodology for assessing housing need. In light of this, any updated SHMA and therefore Local Plan housing figure will need to take account of any revised housing requirement methodology.

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Comment

Technical Reports

Representation ID: 4511

Received: 16/08/2017

Respondent: Historic England

Representation:

An Initial Strategic Housing Market Assessment for Luton and Central Bedfordshire 2015-2035 (July 2017) forms part of the evidence and is based on up-to-date CLG 2014 based household projections. The July 2017 edition is in effect a two page addendum which updates the May 2017 SHMA. The July 2017 SHMA states that migration assumptions which underpin the official household projections for Central Bedfordshire are incorrect.

See attachment for further text

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see attachment

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Object

Technical Reports

Representation ID: 5084

Received: 29/08/2017

Respondent: Legal & General Capital

Agent: Savills

Representation:

Please see attached document in regard to the Strategic Housing Market Assessment and its relation to Slip End,
Document includes information regarding:

Information on Slip End 'East' submission for circa 300 houses,
Migration - adopted 10 year trend is far lower than CLG based 2014 projections,
Conversion to Dwellings,
Household Formation,
Market Signals,
Adjusted OANH would increase to 2,164 dpa,
New Allocations figure of 32,000-48,000,
Information on Shortfall

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Please see attached

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Support

Technical Reports

Representation ID: 5984

Received: 29/08/2017

Respondent: Greater London Authority

Representation:

The approach to housing need set out in the Initial SHMA for CBC & Luton is welcomed by GLA, in particular the use of a 10-year historic migration trend.
The Council should not that our latest population and household projections are now available on the London Datastore (see attachment).
These projections will form the basis of the next London Plan and will include consistent outputs for all local authorities in England

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See attachment

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Comment

Technical Reports

Representation ID: 6130

Received: 29/08/2017

Respondent: North Hertfordshire District Council

Representation:

Our authorities have previously worked together to identify agreed housing markets in Bedfordshire and the surrounding areas. This has resulted in the production of the Housing Market Areas in Bedfordshire and surrounding areas (ORS, December 2015) study, which identifies the Luton Housing Market Area to cover the whole of Luton and a significant proportion of Central Bedfordshire, as well as smaller parts of Aylesbury Vale and North Hertfordshire Districts.
The study also identifies a Stevenage Housing Market covering the majority of North Hertfordshire and the south-east of Central Bedfordshire see attachment

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see attachment

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Comment

Technical Reports

Representation ID: 6163

Received: 29/08/2017

Respondent: House Builders Federation

Representation:

The Council's latest Strategic Housing Market Assessment published in May 2017 concludes that the Objectively Assessed Housing Needs (OAHN) for the Borough are 31,778 between 2015 and 2035 (1589 dwellings per annum). However, we are concerned that this is significantly below the CLG household projections of 34,587 and that the Council are constraining delivery through their assessment of housing needs. Our particular concerns with regard to the approach taken by the Council in assessing housing needs are: see attachment

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see attachment

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  • HBF (39.32 KB)

Comment

Technical Reports

Representation ID: 6265

Received: 24/08/2017

Respondent: Valuetype Ltd

Agent: Savills

Representation:

This document was prepared by Peter Brett Associates to support this consultation version of the Local Plan. This document states at Paragraph 7.31 that there are 8 sites which are suggested could be released from their employment use. This includes Hampden House at Arlesey and specifically states that:
"The building appears to be largely vacant although only a small amount of office space is being actively marketed. It is an isolated location for a large building and the building itself appears to be in poor condition. If vacancy levels persist, this situation is likely to worsen." see attachment

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see attachment

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Comment

Technical Reports

Representation ID: 6284

Received: 25/08/2017

Respondent: Bellcross Homes

Agent: Rapleys

Representation:

The SHMA identifies that the annual average OAN of 2,550 dwellings is notably higher than the recent rate of housing delivery in Luton and Central Bedfordshire over the 10 year period from 2001-11 which averaged bout 1,320 dwellings each year. Therefore, there is a required step change in the delivery of housing over he forthcoming plan period. Consequently, the strategy for delivering this growth has to be sound and deliverable - see further comment on this under the 'Strategy' section. see attachment

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see attachment

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Comment

Technical Reports

Representation ID: 6537

Received: 25/08/2017

Respondent: CPRE

Representation:

The SHMA prepared for CBC indicates that 32,000 new homes need to be built over the Plan period to 2035 - see SHMA page 85, Figure 66, Full Objectively Assessed Need (OAN) for Housing.
CPRE Bedfordshire has established from a Freedom of Information request that 60% of the 32,000 new homes are for people migrating into Central Bedfordshire from elsewhere.

The housing numbers have been calculated by assuming, amongst other things, the continuation of the very high levels of national and international immigration into Central Bedfordshire that has been experienced over recent years.
see attachment

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see attachment

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Comment

Technical Reports

Representation ID: 6562

Received: 29/08/2017

Respondent: Willis Dawson

Agent: HD Town Planning

Representation:

It is particularly important to assess the suitability of the Housing Background Papers (particularly including the Strategic Housing Market Assessment (SHMA) in the context of the National situation and advice set out in both the NPPF and the NPPG. It needs to be borne in mind that the White Paper sought to resolve the current housing crisis by devising methods to increase housing output and by shortening plan preparation periods. A part of both objectives was to standardize housing need projections and a guidance paper on how to do this is expected later this year. see attachment

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Comment

Technical Reports

Representation ID: 6603

Received: 29/08/2017

Respondent: Richborough Estates

Representation:

The Luton Local Plan included an OAN of 17,500, derived from the 2015 Strategic Housing Market Assessment (SHMA) coordinated with CBC. The newer 2017 SHMA which has been recently published includes an updated OAN of 18,810 for Luton which was not considered at the time of the Luton Local Plan Examination. Notwithstanding any reservations of the SHMA, the Councils own assessment of OAN for Luton over the plan period has increased by 1,310 dwellings and due to a shortage of housing land in the Borough, there is no plan to meet this shortfall. see attachment

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See attachment

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Comment

Technical Reports

Representation ID: 6626

Received: 29/08/2017

Respondent: Willis Dawson

Agent: Pegasus Group

Representation:

The SHMA identifies that the 2014 based household projections indicate that
there will be an additional 57,536 households across Luton and Central Bedfordshire between 2015 and 2035, of which 34,587 are within Central
Bedfordshire. The NPPG (2a-015) identifies that this should form the starting
point for the OAN.
2.8 The SHMA correctly acknowledges that these projections can be adjusted to
reflect factors affecting local demography as described in the NPPG (2a-015). The
NPPG provides some examples of where such adjustment may be required, and in
each instance, concludes that it is necessary to uplift from the household
projections. see attachment

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see attachment

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Comment

Technical Reports

Representation ID: 6676

Received: 29/08/2017

Respondent: O&H Properties

Agent: Turley

Representation:

The Council in introducing the Strategic Housing market Assessment (SHMA) is clear to confirm that this represents an "initial" assessment of housing needs, in anticipation of the Government's planned consultation on a standardised methodology for calculating housing needs later this year.
See attachment

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see attachment

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  • O&H (2.07 MB)

Comment

Technical Reports

Representation ID: 6778

Received: 29/08/2017

Respondent: Robinson & Hall

Representation:

We have studied both the Draft SHMA for Luton and Central Bedfordshire and the 'Luton HMA Growth Options Study' (July 2017) and its appendices. To ensure that locations are sustainable as part of the suite of evidence used to underpin the Local Plan's spatial strategy the latter study has correctly sought to identify strategic growth locations at which the majority of need can be met. The methodology clearly sets out a clear, objective assessment of the relevant environmental and infrastructure constraints applicable to each growth location.
see attachment

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Comment

Technical Reports

Representation ID: 6790

Received: 29/08/2017

Respondent: S Roberts & P Harris

Representation:

We have studied both the Draft SHMA for Luton and Central Bedfordshire and the Luton HMA Growth Options Study (July 2017) and its appendices. To ensure that locations are sustainable as part of the suite of evidence used to underpin the Local Plan's spatial strategy the latter study has sought to identify strategic growth locations at which the majority of need can be met. The methodology sets out an entirely objective assessment of the relevant environmental and infrastructure constraints applicable to each growth location. see attachment

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see attachment

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Comment

Technical Reports

Representation ID: 7150

Received: 29/08/2017

Respondent: Denison Investments

Agent: Arrow Planning

Representation:

The SHMA considers that long term 10 year migration trends are the most
reliable and robust basis for projecting the future population (para 2.105,
p.39). However, the evidence in the SHMA for deviating from the 2014
CLG Household Projections does not fully justify this deviation - the
criticisms levelled are not sufficiently robust to warrant the use of the 10
year migration trends, and do not take into account the counter argument
critiques of applying a 10 year migration trend. This approach is not
effectively justified in the SHMA and it is not consistent with the Planning
Practice Guidance requirements. see attachment

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