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14th February 2016

Joint Core Strategy Examination in Public (EiP) with Inspector Elizabeth Ord –

Cheltenham Alliance (CA) Objectively Assessed Need (OAN) and Analysis

Dear Inspector Ord,

The Cheltenham Alliance would like to thank the Bristol Inspectorate for allowing us to take a full part in this EiP of the Gloucester, Cheltenham and Tewkesbury Joint Core Strategy, it been a steep learning curve and the support provided by the Council Officers and Inspectorate has been much appreciated.

This letter is to formally put on the record the CA final submission on the OAN and Jobs EiP sessions in January 2016, and we have made every effort to keep this brief (please note Appendix 1 and 2 are previous submissions and included for reference only). We had a final email from the DCLG (Mr Bob Garland, the Responsible Statistician for the DCLG Housing Projections - Bob.Garland@communities.gsi.gov.uk tel. 030344 42273) who has been very helpful in answering technical questions on the latest 2012 DCLG housing projections now being used to inform the JCS, please see below.

The CA were disappointed not to be able to cross examine the G-First/LEP on their aspirational economic growth and job projections over the JCS plan period, they were unable to attend any of the EiP sessions leaving many questions unanswered, we fall back on reporting unresolved issues and make inferences from other sources of data, we also request the Inspector to downgrade their evidence in their absence.

The CA agree with the JCS council position outlined by Messer’s Jamison and McDonald that no uplift to the OAN is required based on the aspirational LEP jobs growth evidence, this was also supported by Peter Brett Associates at the OAN session. There is contingency in the plan coupled with regular reviews and generous provision of employment land puts the JCS councils in a good position to react quickly to business growth opportunities. This position is also consistent with the advice provided by Cristina Howick (Peter Brett Associates) at the first OAN session on the caution to be exercised when using the econometric models being employed by NPL in their latest economic projections.

Swindon Village Society

Leckhampton Green

Land Action Group

Prestbury Group

Don’t Choke Cheltenham

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DISCUSSION and COMMENTS AT THE EiP OAN SESSION – January 2016 1. Mr McDonald again made a compelling case for exercising caution on applying economic models

and the high degree of variability of the outputs reported in EXAM 138 (NLP Report). What is clear is that these econometric models are not on par with the ONS and DCLG projections used in the main demographic/housing growth projections, nor are they peer reviewed or reviewed for long term accuracy.

2. The resent County Devolution Report [ref attached], signatories are all six councils, the LEP, Gloucestershire NHS Trust and Gloucestershire Constabulary, this report pitches for an aspirational GVA uplift of 4.7% year on year throughout the duration of the JCS plan to 2031, however looking at the detail this level of growth is not predicated on job growth, this is projected at 1% annual growth in working age population, this is important when considering any OAN uplift against economic growth.

3. This job growth projection agrees with the SW Observatory Module final report[ref attached], Prof Shane Vallance and Nigel Jump, extract below. We can conclude that the growth in GVA is driven by increases in productively not jobs, there is no linear relationship between economic growth and jobs, it's more to do with profit and productivity, of keeping a healthy order book and investment in training and product development.

4. Point 15 from below on the NLP Employers Consultation. 5. Refer back to the Peter Brett evidence from the first OAN session, Cristina Howick, Peter Brett

consultant this time was talking about the job creation being aspirational and therefore should not be directly linked to the OAN Employment need.

6. G first/LEP not providing sufficient clear evidence to explain where the new jobs are being generated, again reference to the NLP Employers Consultation, point 15 below is relevant.

7. Transport the ridiculous delay in the info being made available and the fact that its coming in last These are the Cheltenham Alliance Notes pre-prepared for the JCS OAN open sessions Our concerns and initial questions relate to:

8. The starting point for the OAN, following PPG guidance, is the DCLG Household Projections. The DCLG 2012 housing projection for Cheltenham is 9,206[1], this is the PAS recommended household projection baseline for Cheltenham which includes provision for economic growth[ref. Garland email], the DCLG use a longer period for household projections to avoid short term economic downturns unduly affecting the projections. Since this is the stated PPG baseline we would expect the DCLG projection to be provided in this JCS OAN document, could we request the DCLG figures be provided for all JCS districts so the starting point for OAN is correctly established. [1] Household

projections for England and local authority districts, Release 2012-based, 27th February 2015, Table 406: Household projections by district,

England, 1991- 2037 9. The continued use of Unattributable Population Change (UPC) against the recommendation of the

ONS Population Projection Unit, there is no evidence that these adjustments are statically valid. The ONS population projections are peer reviewed, to make adjustments would require a great deal more statistical work to demonstrate a systemic or method error in the way the ONS projections are calculated, to our knowledge no professional statistician has been employed by the JCS Councils to substantiate this UPC juggling with the district OAN's. This is a basic misunderstanding of the statistical methods employed by the ONS, there is no evidence of systemic error in the projections, small positive or negative errors will always be present in population projections, it does not mean these can be relied upon to 'adjust' future projections. The DCLG in making their Household Projections do not use UPC[ref. Garland email], it is not mathematically sound, there are few other councils who uses UPC in this way to adjust the OAN, it would be disapointing to impact on the soundness of the plan for small UPC OAN uplifts, it may have been justified in the past but not with the latest ONS population Unit Methodologies and Models . We have provided

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the official guidance from the ONS Population Projection Unit in previous JCS submissions and the DCLG view is provided below[ref. Garland email].

10. The handling of Empty and Second Homes in EXAM119 is confusing, the source of this data seems to be the DCLG live table 615. However, the report states the use of Council Data, the CA have previously provided a spreadsheet of empty homes in Cheltenham, there is a large discrepancy with EXAM 119 Table 8 which needs explanation, for Cheltenham table 8 gives figures of 1,665 and 790 for vacant and second homes respectively. It the detail on empty and second homes is available for any of the three JCS districts then this should be used in preference to national tables; this data is available.

11. There is a great deal of discussion on the important job projections, we would like the job and JCS economic projections to be correlated with the SW Observation Module reports which have been referenced in our evidence. These reports are comprehensive, making full use of all available data across the South West and provide an insight into the job growth and economic outlook based on real data, these should be referenced in the JCS as do many other councils in the preparation of local plans.

With reference to the two NLP documents, EXAM138 and EXAM139, we have raised the following anomalies in the evidence provided, can these please be put on the record and considered in the final OAN review.

12. The NPPF and the PPG gives clear guidance that past trends should be a major input on employment growth projections, be 'aspirational but realistic'. Table 4.1 of EXAM138 provides a JCS Employment Projection based on three economic projections, the actual past trend on jobs is not being used to anchor the estimates to bring a realism to these projections, this is a requirement of the NPPF. The Job growth trends are given in section 3.6 but not used to balance the more aspirational employment projections across the JCS area, the employment projections should also importantly be broken into the three districts to aid transparency.

13. The housing need is primarily based on the ONS Population Projection and the DCLG Household Projection, both pulled together by professional statisticians, the latter from Bob Garland's group at the DCLG using the new model for England with improved accuracy on household formation/sizes and the former from the ONS Population Projection Unit (Titchfield) Suzanne Dunsmith and Pete Large. These projections are peer reviewed and subject to consultation, the PPG requires these projections to be the 'starting point' for housing needs. Economic growth is built into the DCLG housing need projections based on past trends, to avoid undue influence from short term recessions or fluctuations in the economy the projections use data over three decades within the England Model. The Employment growth set out in EXAM138 and EXAM139 are not peer reviewed nor are they transparent in how these various computer economic models are being used and the assumptions being input into these models, if we are to use these models please can we have more information on operation, inputs and the performance of these models.

14. The source of the employment growth graphs (2000 - 2013) in section EXAM138 figure 3.1 are given as the ONS Job Density, these do not agree with the Housing Trend Analysis & Population and Household Projections, Gloucestershire County and Districts Planning Authorities, Gloucestershire Housing Evidence Review, Final Report, May 2011, The Research Team, these graphs and the report are attached as evidence.

15. The consultation with employers was restricted to interview and meetings, no surveys are mentioned, this is not the transparency expected of these important economic and job projections.

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There is no opportunity to access the responses from local employers, section 2.6 on Expansion Needs briefly states that nearly all of the respondents indicated that their current premises met their business needs, however one identified a flood risk and two others stated new premises would be required. This is at odds with the general conclusions being driven by the economic projections of table 4.1 projecting very large economic growth over the plan period.

16. Another source of evidenced based economic projection for the South West is the SWO Economy Module Prospects for Private Sector Job Growth SW - Shane Vallance & Nigel Jump, October 2011, used by many councils to inform local plans, see attached, please can this document be submitted to the JCS evidence base, an extract is below for ease of reference. This analysis is against the NPPF and PPG Guidance:

NPPF [154] requires local plans to be 'aspirational but realistic' PPG 2a-004 assessment of development need should be objective, based on fact and unbiased

evidence Economic projections should not be restricted to one approach, requires the approach to be

transparent and through but proportionate PPG2a-018 likely change in numbers to be based on past trends and/or economic forecasts as

appropriate PPG 2a-031 important to consider projections based on past trends and forecasts plan makers should liaise closely with business community

Finally the CA would like to share insight provided by Mr Bob Garland (Responsible Statistician for the DCLG Housing Projections - Bob.Garland@communities.gsi.gov.uk tel. 030344 42273) on the DCLG Housing Projections, dated 15th Feb 2016: Dear Ian, Thanks for this and also for sending me the Turley Economics Report.I apologise for the delay in replying. I’ve answered your questions as noted below. Best regards, Bob 030344 42273 ------------------- From: Ian Bickerton (Bristol University - Chemistry) [mailto:Ian.Bickerton@bristol.ac.uk] Sent: 25 January 2016 15:55 To: Bob Garland Subject: Re: 2012 Housing Projections Dear Bob, Tried to call this afternoon and thought an email would be better than a voice message. Have been looking through the projection methodology again to prepare for a series of meetings here in Cheltenham on OAN assessment, three questions came up and you are the only person who gives straight answers !

Is stage 1 of the DCLG household projection is any interim census data still being used, is the 2011 census data requested by the DCLG all now in the England Model ? As much as possible of the 2011 Census was incorporated – see the Stage 1 and Stage 2 methodology documents]

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The projections use a two point methodology, 2001 and 2011 census data, am I right in thinking the level of economic growth is built into the DCLG projection in that there is no way to separate the projection from the economic conditions that prevailed at the time ? The Stage 1 projection is based on 5 points back to the 1971 Census. So the long term household growth is picked up, but you’re correct that the effect of the housing market recession in 2008 will be reflected to an extent in the projections.

Did you reach any conclusions on the use of Unattributed Population Change (UPC), we are still getting hounded on this, what is the DCLG policy, I know this is not used in your sub-national projections following the clear ONS recommendation and that Peter Brett Associates have changed their advice, in that UPC 'should not be needed in future, because ONS has now improved its processes to better distribute international immigrants to their first true area of settlement' and the fact that the ONS population unit do correct the MYE's, anchored to the census, before doing their own population projections ?

We agree with the ONS approach of not including the UPC in projections. Thanks in advance for any guidance.

---------------------- Yours Sincerely Cllr Ian Bickerton Feb. 2016, Tel 01242 250473 cheltenham.alliance@gmail.com For the CHELTENHAM ALLIANCE http://www.cheltenhamalliance.org.uk

Helen Wells Chair Save the Countryside www.savethecountryside.org.uk 07770986078 Bridget Farrer Chair HaShTAG www.facebook.com/pages/Hashtag-Chargrove/381779971947674 07847711468 Janet Thomas Chair Save Brockworth’s Greenbelt 01452 863713 Barry Simon Chair Swindon Village Society www.swindonparish.org.uk 01242 521723 Mathew Parker Chair Protecting the Environment http://www.peps-net.co.uk/ 07967953754

of Prestbury and Southam (Pepsnet) Peter Edis-Bates Don't Choke Cheltenham www.dontchokecheltenham.info 01453 791235 Patrick Durkan Chair Prestbury Group 01242 576794 Ian Bickerton Chair LEGLAG www.Leglag.org.uk 01242 250473

EXTRACT SWO Economy Module Prospects for Private Sector Job Growth SW - FINAL VERSION Forecasting & forecasts In “The Economics Story”, we explain the approach to forecasting in terms of a performance framework, growth scenarios and influencing trends. That is the analytical approach adopted here. First, then, we take as given the performance framework revealed by the long and deep understanding, gained over many years of our analysis, of the historical trends and structures in the different parts of the SW economy. Second, we consider the four aspects of setting growth scenarios: the current capacity of an economy to develop; historical performance and projection of that performance forward; forecasts based on some idea of the theoretical or econometrically established relationships between key variables through time; and target deviations, from both history, projection and forecast, on the basis of foreseeable change, investment plans and aspiration.

Page 6 of 35 Third, we consider other “less economic” influences that may affect private sector job creation going forward: demographics, environment, technological change and the process of rebalancing itself. We reproduce the latest projections and forecasts for the region and its parts in the following tables and charts. Table 1: SW real growth forecasts Annual Average % change Projection Forecast Target 2010-2015 +2.0% +2.2% +2.3% 2015-2020 +2.3% +2.6% +2.7% 2020-2030 +2.4% +2.4% +2.9% Source: SW RDA Economics – Economy Module Table 2: SW sub-regional employment projections ( Full-time equivalent FTEs) Annual Average % change 2011-2016 2016-2030 1995-2005 Cornwall & Scillies 1.6% 1.4% 2.6% Dorset 1.5% 0.4% 2.0% Gloucestershire 1.8% 0.8% 1.1% Heart of SW 1.7% 1.1% 1.9% Swindon & Wiltshire 1.9% 1.2% 0.9% West of England 1.9% 1.4% 1.9% Source: SW Economic Projections for SWRDA, autumn 2011

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APPENDIX 1 PREVIOUS CHELTENHAM ALLIANCE

SUBMISSION – APRIL 2015 (for reference) This Cheltenham Alliance OAN report examines the current lack of soundness of the Joint Core Strategy (JCS) Pre-

Submission document on the assessment of housing numbers, the Objectively Assessed Need (OAN) which forms a

critical element of the whole JCS process. Our original analysis has been updated to respond to the November 2014

NMSS Report [12] and to take guidance from the OAN technical note[13] published by the Planning Advisory Service

(PAS). The NMSS OAN Report[13] has only recently been brought to our attention, this report was not part of the pre-

submission evidence provided in the final JCS public consultation and therefore only a partial scrutiny has been

possible.

There follows an executive summary highlighting the key issues raised by this report, the body of the report provides

the best practise methodology as used by the majority of councils to derive the OAN for Gloucester, Cheltenham and

Tewkesbury, also provided are the sources of data and supporting evidence from government departments to allow

verification.

Executive Summary

The PAS in their OAN Technical Note[13] advocate to start housing need assessment with the ONS Population

Projections and the DCLG household projections, making full use of local/ sub-national data and informed by

robust and proportionate evidence, the CA OAN follows this best practice guidance

The National Planning Policy Framework emphasises that data used in setting housing targets should up-to-

date, this is NOT the case for the JCS which casts aside both the ONS 2012 sub-national population

projection and the 2013 DCLG district Household Formation Rates

The 2011 ONS interim population projection is being used inappropriately by the JCS

Household Formation Rates have been arbitrarily adjusted by the JCS consultants (CCHPR) with no rigorous

basis for the derivation nor any evidence presented in some obscure backwards process working from the

housing numbers

The district variations for international migration, internal migration and natural population changes have

not been taken into account adequately

The impact of inappropriate methods and out-of-date data in JCS leads to an inflated housing requirement of

30,500, whereas use of referenced up-to-date data and DCLG modelling demonstrate a requirement of

23,500

The methods and data employed to derive this improved OAN is compliant with NPPF [159] , fully supported

by ONS, DCLG and Bristol Inspectorate, and defensible at the JCS Examination in Public (EiP)

Over provisioning of housing, with early phasing onto the greenbelt and open countryside is unsound and

non-compliant with the NPPF, it will lead to development on less sustainable sites without the correct level

of infrastructure investment, a misuse of resources and unnecessary destruction of green belt and green

field sites

It is critical that the latest population and household formation projections be updated before proceeding to

the Examination in Public, leaving an uncorrected error of 23% in the JCS housing targets endangers the

whole plan and will make the JCS pre-submission document unsound

An analysis has been provided of the JCS OAN using the latest ONS Population Projection and DCLG

Household Projection, this includes a sensitivity appraisal and reports the incomplete status of the DCLG

2012 based projection.

Introduction

Page 8 of 35 The failure of the JCS Councils to use up-to-date data has significantly inflated the JCS housing provision, this reduces

our five year land supply and cannot be relied upon as the NPPF ‘exceptional circumstances’ to allow early phasing

onto the much loved open countryside and greenbelt around Cheltenham.

The lack of references and sources of data makes the (JCS) Pre-Submission document very difficult to verify, for

example the table of section 3.1.10, this illustrates that the level of house building proposed is little different to the

numbers in the previous plan. In the period from 2001 to 2011 the actual house build is given as 1450 with no

source or reference. The fact that these are census years provide a clue, for verification purposes the table below

provides the actual number of households in all three JCS districts in the two census years, the reader is invited to

use the links to verify the correct use of the DCLG or ONS data.

Table 1 Historical House Building in the JCS Districts measured by the 2001 and 2011 Censuses,

actual build rate 1025pa, JCS historical build rate stated in the pre-submission at 1450pa

JCS District 2001 Households 2011 Households Difference/House Building

Gloucester 45,760 [1] 50,456 [1] 4696

Cheltenham 48,181 [1] 50,902 [1] 2721

Tewkesbury 32,427 [1] 35,264 [1] 2837

Total 10,254 annual build 1025

[1] Data Source: DCLG Household Projections or go directly to the table DCLG Table 406 table 406 on the TAB, line 415

[2] Housing Numbers can also be verified directly from the ONS 2001 Census Gloucester Cheltenham Tewkesbury

Increasing the level of house building from 1450pa to 1525pa as presented in the pre-submission document seems

reasonable, however the analysis above shows the 2001 to 2011 annual build rate to be 1025, and this is how errors

in the statistics can be very misleading to councillors and the public and should now be corrected. Moving from a

previous JCS build rate of 1025pa to 1525pa, an increase of 49% paints a completely different picture. This agrees

with our local MP’s, Martin Horwood and Laurence Robertson who both dispute the level of housing growth

promoted by the JCS. Together they question the ‘appalling sustainability analysis’ and the ‘accuracy of the models’

which make up much of the evidence base behind the JCS.

The Alliance agrees with the important objections raised by the CPRE in their JCS Response, the plan is found to be

unsound and non compliant to the NPPF, in particular with reference to NPPF[Para 50] ‘local planning authorities

should: identify the size, type, tenure and range of housing that is required in particular locations, reflecting local

demand’. The JCS fails to meet this critical NPPF requirement and before any strategic sites are finalised, prior to

EiP, time should be used to allow this work to be completed.

Cheltenham Alliance is not against house building, we absolutely recognise the need for more affordable and social

housing in Cheltenham. However, the Alliance cannot support the JCS plan for a 20% increase in the town’s

population with the strain that puts on jobs, health, education and transport made all the worst by an infrastructure

funding gap of greater than £750M identified by the C5 Cheltenham Parish Councils and now reported in the ARUP

JCS Infrastructure Report.

Initial Response to NMSS OAN Report[13] The introduction states this report is a summary of the Cambridge Centre for Housing and Planning Research advice

to the Joint Core Strategy. However, it is not clear if this NMSS report had been peer reviewed by CCHPR and has

their agreement on the use of out-of-date population projections, out-of-date 2008 DCLG household projections and

Page 9 of 35 housing provision adjustments being made on the evidence of Unattributable Population Change (UPC) against the

advice and material evidence provided by the ONS Population Projection Unit.

Section 1 & 2 cover population and household formation, the fundamental flaw is not updating to the ONS 2012 sub-

national population projection and the 2013 DCLG district Household Formation Rates, both of which were available

at the time of report preparation. We would be more accepting if the population and household formation analysis

made use of local data sources, this is not the case. The main issue here is that official population and household

projections are not being used as the starting point for housing provision, these projections are compiled by

professional statisticians with methodologies which are peer reviewed. There is no rationale as to why up-to-date

data and projections, as required by the NPPF, are not being employed to provide the most objectively assessed

need which would be based on the 2011 census.

The ‘return to trend’ or ‘partial return to trend’ rationale is being used throughout the report; no trend has been

established for the JCS districts. Household Formation Rates (HFR) or the reciprocal Average Household Sizes (AHS)

need to be examined individually for Gloucester, Cheltenham and Tewkesbury to establish the trends. The starting

point should be the DCLG Household projections, the NPPF Planning Guidance (PG) puts forward this ‘standard

methodology’ which is ‘strongly recommended’, and any authority that chooses to depart from this best practise

should provide some rational and explanation. There is scope for adjustment to cover local circumstances and

certainly in Gloucester this would need to be applied, it is one of the few districts in England with a rising household

size. The latest CLG (Feb. 2015) sub-national household projection do provide the detail of housing need from

population and increasing household formation so these adjustments are readily accomplished.

The report includes an analysis of a ‘return to trend’ for younger adults (25 to 34 age group), this analysis needs to be

more objective and include a quantitative assessment using that local demographic information that is readily

available from the 2011 census. Prof. Ann Berrington has provided all the data[9] on how this age group has been

affected in recent years with the economic downturn. Local demographics need to be taken into account for a

quantitative assessment, for example the Gloucestershire Housing Evidence Review 2011 (DRD Research) showed

that 90% of the population increase for Cheltenham to 2031 was due to the increase in people of retirement age.

On the Unattributable Population Change (UPC) adjustment made to the ONS 2012 population projections in the

NMSS report, this adjustment is not justified given the strong evidence based recommendation from the ONS. In

discussion with the ONS Population Unit, they confirmed the mid-year population estimates are corrected to the

UPC or re-baselined to the 2011 census, it is these UPC corrected mid-year estimates that have been used for the

2012 population projection.

The ONS have stated the position on Unattributable Population Change on the Q&A 2012 PP webpage

‘At consultation, we proposed that no adjustment was to be made to the 2012-based sub-national population

projections for Unattributable Population Change (UPC). This is because our research concluded that an adjustment

would only be made if it could be demonstrated that UPC measures a bias in the trend data that will continue in the

future. In addition, it is also unclear what proportion of the UPC is due to sampling error in the 2001 Census,

adjustments made to the population estimates after the 2001 Census, sampling error in the 2011 Census or error in

the intercensal components - so methodologically, this would be difficult to adjust for.

The UPC is unlikely to be seen in continuing sub-national trends because:

if it is due to either the 2001 Census or 2011 Census, then the components of population change will be

unaffected, and

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if it is due to international migration, it is likely that the biggest impacts will be seen earlier in the decade and

will have less of an impact in the later years, because of improvements introduced to migration estimates in

the majority of these years.

Therefore, ONS has concluded that no adjustment should be made’.

The analysis on vacant properties and second homes would be much improved by the use of local data, this is

available from the council tax office. This data has been provided through a FOI request in 2013, provided by Emily

Adams (CR & Research Officer), the supplied spreadsheet identifies 46 exempt and 40 Long Term Empty properties

in Cheltenham, considerably less than the percentages being used in the NMSS report, this needs work and

correction.

JCS Objectively Assessed Need following the PAS[13] & PG Guidance

The starting point for this JCS assessment of housing need is to access the latest ONS sub-national population

projections and corresponding CLG sub-national household projections, links are provided for reader verification.

Table 2 Latest ONS & DCLG Population & Household Projections

ONS Population 2031 ONS 2012 Population Projection Table 2 Published 24th May 2014

CLG Households 2031 CLG Household Projection Table 406 Published 27th Feb. 2015

2011 2031 Delta

Gloucester 143,900 50,440 62,315 11,875

Cheltenham 131,200 50,910 60,116 9,206

Tewkesbury 97,300 35,269 43,110 7,841

This would suggest a JCS housing provision requirement in excess of over 29k, considerably more than the previous

DCLG projections in appendix 1. For an explanation we need to look at the DCLG 2012 Household Projection Report

and Methodology, the household projection is almost the same as the 2011 Interim Projection, 220k against 221k to

2021, the report states, ‘some data on household formation rates at a national level’. Some local household

formations probabilities where exchanged for national figures, this would impact on household numbers in areas

where household sizes where flat or increasing as in Cheltenham and Gloucester.

The Methodology Report adds clarity to the projection, it describes a two stage process, only partial information was

available for stage 1 and therefore household representative rates for 2011 have been derived at England level not

the local level. Stage 1 is incomplete and stage 2, detailed household type breakdown by age will follow later in the

year.

The report provides some valuable sensitivity tests which can be used to judge the precision of the household

projections, table 3 provides the data and illustrates the sensitivity to average household size in the projections and

the likely corrections required for the JCS OAN.

Table 3 Sensitivity Tests on the DCLG Household Projections

ONS Population 2031 ONS 2012 Population Projection Table 2 Published 24th May 2014

CLG Projected Average Household Size CLG Household Projection Table 406 Published 27th Feb. 2015

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2011 CLG 2011 Actual[**] 2031 CLG

Gloucester 143,900 2.367 2.382 2.335

Cheltenham 131,200 2.288 2.202 2.242

Tewkesbury 97,300 2.309 2.307 2.272

[**] Data Source ONS – Table H01UK 2011 Census: Households with at least one usual resident, household size

and average household size, local authorities in the United Kingdom (Excel sheet 237Kb)

The current difference between the projected average household size and actual for Gloucester in 2011 is 0.015, this

sounds small, however housing provision is very sensitive to small changes in AHS and when projected over twenty

years very large errors can result. Even at the start of the projection in 2011 this error would result in an over

estimate of housing provision of 319 houses. (119955/2.367 – 119955/2.382)

The CLG Projection is extremely sensitive to any errors in household formation rates and it is no surprise that an

incomplete stage 1 projection founded on England data throws up a large projection error in Gloucester where

household sizes are rising. The DCLG Projection will be greatly improved once local 2011 census data gets adopted to

give reliable household formation rates across all age groups and status.

The CA recommendation at this stage is to fall back to the best practice recommended to us by the Bristol

Inspectorate Local Plan Team, to use the latest ONS Population Projections in conjunction with a Average Household

Size projection anchored to the 2001 and 2011 Censuses, this is our previous work set out in the housing provision

charts for each JCS local authority in Appendix 1 to this report. A small adjustment to these housing provisions

needs to be made for vacant and second homes, accurate local data is available to inform this work.

We will continue to study the 2012 based DCLG Household Projections and refine our housing provision charts in

preparation for the EiP. This report replaces our original JCS pre-submission OAN response.

We request the opportunity to participate in the EiP on the Housing Provision of matter 3, to present evidence as

required and allow the Inspector to question any part of our analysis.

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JCS Housing Provision – Analysis and Data

The National Planning Policy Framework (NPPF) specifies the use of up-to-date data, and the integration of housing and employment in the formulation of local plans:

NPPF Para 158: “Each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area.

Local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals”.

The Cheltenham Alliance is disappointed with Cheltenham Borough Council, having given the public assurances at full council on the 9th April in the JCS amendment, with the failure of the Council to update the assessed housing

need in line with the May 2014 ONS longterm sub-national population projection and the DCLG household formation rates from April 2013. These are basic NPPF requirements; failure to meet this requirement makes the strategic

plan unsound. Hired consultants might be saying these new projections make little difference to the housing numbers, the Alliance would strongly disagree with this analysis, the Council need to recognise the expertise of

professional statisticians at the ONS and the DCLG using sophisticated peer reviewed models who together put the JCS housing requirement at 23,500.

This brief attempts to add some clarity on the impact of the new ONS/DCLG projections and provide objective sources of data, both national and local have been used in the compilation of this JCS housing analysis. The recently

published ONS sub-national population projections[1] is recommended by the ONS for the purposes of local planning and used by the vast majority of councils in the formulation of local plans, the use of these datasets will stand up

to formal Examination in Public (EiP) with the Bristol Inspectorate. For illustrative purposes the various Cheltenham population projections are shown in Figure 1, Gloucester and Tewkesbury projections are included in the

Appendix, the JCS line is based on the ONS 2011 interim 2011 projection and has been superseded to correct the known errors in the birth rate estimates, please see the ONS correspondence and advice in Appendix 1.

Figure 1 Cheltenham Population Projections, Office for National Statistics, 2001 & 2011 Census, mid-year corrected estimates to 2013 and the JCS Projection currently used for the OAN

Gloucester and Tewkesbury projections are included in the Appendix (note the additional MY 2013 data point published by the ONS, 10th July 2014

Page 13 of 35

F

Figure 2 Average Household Size, 1911 – 2011, England and Wales, source Office of

National Statistics [2] – there is no evidence for a continued drop in household size

Table 7 Cheltenham Local Council Tax

Data, Single Occupier Discount,

percentage of total households[8]

YEAR Single Occupier Discount

2007 36.0%

2008 36.4%

2009 36.6%

2010 37.0%

2011 37.2%

2012 36.8%

Table 3 is a strong local indicator of

no change in single household

occupancy in Cheltenham since 2007

(no data available before 2007)

Table 6 District Average Household Size, source Office of National Statistics

District Population (2011 Census [1])

Households (2011 Census [2])

Average District Household Size

Tewkesbury 81,900 35,100 2.33

Gloucester 121,700 50,400 2.41

Cheltenham 115,700 50,900 2.27

[1] Table P07 2011 Census: Number of usual residents living in households and communal establishments, local authorities in England and Wales [2] Table H01 2011 Census: Number of households with at least one usual resident, local authorities in England and Wales

Table 4 Three Step Process to calculate the JCS Objectively Assessed Need

1. Population in 2031, three JCS Districts, source ONS long-term sub-national population projections [1].

Gloucester[1] 143,900 in 2031 Cheltenham[1] 131,200 in 2031 Tewkesbury[1] 97,300 in 2031

2. Access Average Household Size projected for the three districts to 2021, reference DCLG Housing Projection[2] and County SHMA[4]. Awaiting the DCLG to provide data to 2031 later this year, household formation is stable across the JCS area from 2001 to 2011, measured by census and Labour Force Survey.

Gloucester 2.407 (DCLG Model, 2011 trend small rise) Cheltenham 2.255 (DCLG Model, 2011 trend flat) Tewkesbury 2.309 (DCLG Model, 2011 trend small drop) To access charts and previous trends in AHS, please see appendix 1

3. Final calculation of JCS Housing Requirement, using the new ONS population projection, the DCLG England Model on Household Formation providing Average Household Size and subtracting the current housing stock as of 2011.

Gloucester 143900 divided 2.407, subtract 50363 = 9421 Cheltenham 131200 divided by 2.255, subtract 50929 = 7253 Tewkesbury 97300 divided by 2.309, subtract 35126 = 7013

TOTAL 23,687

Table 5 Census 2011: Population and Housing Growth, published by the ONS, 24 September 2012

District MYE 1991

MYE 2001

CENSUS 2011

Population % Change

2001 to 2011

Households 2001

Households 2011

Census

Growth in Housing 2001 to 2011 (%)

Cheltenham 107,000 110,000 115,732 5.2% 48,000 50,929 6.1%

Cotswold 74,800 80,400 82,881 3.1% 34,000 36,236 6.6%

Forest of Dean 75,800 80,100 81,961 2.3% 33,000 34,167 3.5%

Gloucester 103,500 109,900 121,688 10.7% 46,000 50,363 9.5%

Stroud 104,100 108,100 112,779 4.3% 45,000 47,794 6.2%

Tewkesbury 70,700 76,500 81,943 7.1% 32,000 35,126 9.8%

NOTES, BACKGROUND & ANALYSIS

The Cambridge Centre for Housing & Planning Research (CCHPR) predicts a ‘return to trend’ on household formation rates in Cheltenham, this is without a rigorous analysis of past trend, the

absence of any modelling work and against the DCLG evidence presented in their April 2013 report. The JCS is unsound in the reliance in this arbitrary judgement on future Cheltenham

household formation to substantiate a greenfield first policy or an ‘early phasing to ensure delivery in the plan period’. It is vital that the JCS updates the housing targets prior to EiP inline with

the May 2014 longterm ONS Population Projection and the latest April 2013 DCLG Household Formation Rates (HFR), the NPPF stresses the importance of using up-to-date data, some fifteen

times in this national planning document.

In the same consultancy, the November 2013 report on the Potential Implications of New Population and Household Projections for the JCS presents a backwards process to derive the average

household size or household formation rates – Annex B – 15, they present no household formation model. This mysterious JCS ‘return to trend’ or ‘partial return to trend’ parameter is

calculated from the housing targets, as Cllr Massey stated at the April 9th JCS Council, ‘hardly the required Objectively Assessed Need but rather more Subjective’.

The CCHPR November 2013 report [10] also states in Annex B -14, the OAN of 31,900 and then adds an allowance for empty and second homes producing a total requirement of 33,200, so this

assumed the number of empty houses will increase over the period of the plan ?

Page 14 of 35 The NPPF requires that the level of Housing must be linked to jobs, this element of the strategic plan is again

unsound, future employment opportunities need to be demonstrated by business survey in a proactive local

economic policy backed by a detailed analysis of the labour market and trends for each of the three JCS districts.

Evidence based and realistic levels of economic growth for Gloucestershire are given in references [4] & [5], extracts

are provided in Appendix 1.

In the previous round of the JCS consultation, one identified problem was the late switch to an interim 2011 ONS

population projection and extending that to 2031 without any observation of the warning of potential over

estimates of the birth rate. The ONS have now stated, see appendix 1, that this interim population projection was

never intended to be used beyond 2021 and more importantly the demographics should be verified for each district

before use. The recently published Strategic Housing Market Assessment (SHMA) JCS evidence document

highlights the stark differences between the three districts, with the population growth in Gloucester (of 10.7%)

being over twice that of Cheltenham’s at 5.2% from 2001 to 2011; and where in Cheltenham 'net international

migration' was the largest component of population growth, in Gloucester it was 'net natural change', whilst in

Tewkesbury it was 'net internal migration'. Given the degree of uncertainty on international migration and the

findings of the SHMA for Cheltenham it would be reckless to promote early phasing of green field sites before new

government policy has been given a chance to impact on population growth. With the differences reported in the

SHMA, each district requires a separate OAN based on projected district population and household formation rates.

The problems of over-provision of housing in housing supply include the danger of development coming forward too

rapidly in less sustainable places (e.g. dispersed, more rural / dormitory settlement locations which all have local

requirements) and, through competition effects, diverting development resources (e.g. infrastructure investment)

from more sustainable but more difficult to develop places (e.g. inner urban brownfield land, continued policy of

regeneration of Gloucester & Cheltenham). This would result in what were largely intended to meet local growth

needs being taken up by a higher proportion of inward migrants and commuters, and resulting in a perpetuation of

the dispersed, car dependent settlement growth patterns. Over-provision in general would also place additional

strain on existing infrastructure and could lead to investment in new capacity before it is required, representing a

waste of scarce resources.

It is interesting to note the first JCS public consultation, Developing the Preferred Option (DPO) identified strategic

allocations for approximately 29,500 houses, mostly on greenbelt, adjacent to Cheltenham, Gloucester and

Tewkesbury, how little has changed.

In summary, the housing numbers can be simply calculated in a three step process shown in the table 4, it follows

the best practice given by three government departments, the DCLG, ONS and Bristol Inspectorate and uses

referenced up-to-date population projections and household formation rates.

Cllr Ian Bickerton April 2015, Tel 01242 250473 cheltenham.alliance@gmail.com For the CHELTENHAM ALLIANCE http://www.cheltenhamalliance.org.uk

Helen Wells Chair Save the Countryside www.savethecountryside.org.uk 07770986078 Bridget Farrer Chair HaShTAG www.facebook.com/pages/Hashtag-Chargrove/381779971947674 07847711468 Janet Thomas Chair Save Brockworth’s Greenbelt 01452 863713 Barry Simon Chair Swindon Village Society www.swindonparish.org.uk 01242 521723 Mathew Parker Chair Protecting the Environment http://www.peps-net.co.uk/ 07967953754

of Prestbury and Southam (Pepsnet) Peter Edis-Bates Don't Choke Cheltenham www.dontchokecheltenham.info 01453 791235 Patrick Durkan Chair Prestbury Group 01242 576794 Ian Bickerton Chair LEGLAG www.Leglag.org.uk 01242 250473

Page 15 of 35

REFERENCES

[1] Sub-National Population Projections, 2012-based projections, Table 2, 2012-based sub-national

population projections by sex and five year age groups for Local Authorities in Regions - SE, SW and

London - Office for National Statistics, May 2014

http://www.ons.gov.uk/ons/publications/re-reference-tables.html?edition=tcm%3A77-335242

[2] Household Projections by district, England, 1991- 2021 England Counties, London boroughs, unitary

authorities and districts in England, DCLG Table 406 and the Report

https://www.gov.uk/government/statistical-data-sets/live-tables-on-household-projections

[3] ONS Statistical Bulletin, 2011 Census - Population and Household Estimates for England & Wales, 2001 to

2011, Office for National Statistics - 16 July 2012

‘Average household size in 2011 is unchanged from 2001, meaning that only population growth drove an

increase in the number of households in that period. The long-term decrease in household size reflects

the decline in the total fertility rate5and the ageing of the population over the century. It also reflects

changes in the structure of society... This information is critical for local authorities for assessing and

planning for housing needs. Future 2011 Census releases will include further detail about numbers and

types of households.’

[4] a) Local Authorities of Gloucestershire - Strategic Housing Market Assessment Update Final Draft

October 2013, HDH Planning and Development Ltd

b) Local Authorities of Gloucestershire - Strategic Housing Market Assessment Update Final March

2014, HDH Planning and Development Ltd

[5] Prospects for Private Sector Jobs Growth in SW England, Oct 2011, South West Observatory - Economy

Module http://economy.swo.org.uk/

[6] Oxford Economics “South West Growth Scenarios: Final Report” June 2010

[7] Letter to the DSS, Parliamentary Under Secretary of State, Bob Neill, Department of Communities and

Local, March 2012

[8] Cheltenham Borough Council, Tax Office, total number of Properties and Single Occupier Discounts

from 2007 to 2012, by email 20th Aug. 2012

[9] Changing Living Arrangements and Household Formation: A Review, Prof. Ann Berrington, University of

Southampton, UK - BSPS Meeting on Estimating Future Household Formation, London School of

Economics, 16th December 2013

Ann Berrington is currently a Professor in Demography and Social Statistics at the University of

Southampton and jointly co-ordinates the fertility strand of the ESRC Centre for Population Change. She

has worked on the following projects for the CPC

Page 16 of 35

[10] The Potential Implications of New Population and Household Projections for the Cheltenham,

Gloucester and Tewkesbury Joint Core Strategy, Preliminary Report – November 2013 Cambridge

Centre for Housing & Planning Research CONFIDENTIAL FOR MEMBERS ONLY

[11] Evidence provided to the Parliamentary Select Committee - Review on the effectiveness of National

Planning Policy Framework, Cheltenham Alliance Evidence, 7th July 2014 [1] [2]

[12] The Objectively Assessed Housing Needs of the Cheltenham, Gloucester and Tewkesbury Joint Core

Strategy Area, Neil McDonald with Christine Whitehead, Nov 2014

[13] Objectively Assessed Need and Housing Targets - Technical Advice Note, published by the Planning

Advisory Service, June 2014

Page 17 of 35

APPENDIX 2 – USEFUL SOURCES OF DATA & EVIDENCE

Population Projections for Gloucester, Tewkesbury & Stroud

Page 18 of 35

Page 19 of 35 Household Formation Rates / Average Household Size in the JCS Districts

Data provided by the ONS Please note how sensitive the housing targets are to the projected average household

size, see the house building scale on the right hand side, one tenth change can result in thousands of houses onto

the greenbelt. It is vital we use the most up-to-date data available and the best modelling available from the

Department of Communities & Local Government (DCLG), this is best practice as provided by the Bristol

Inspectorate.

These charts were produced in May and December of 2013 and require updating to the new ONS longterm

population projections[1], the county SHMA tables, p17/18 of this appendix, provide more accurate and up-to-date

average household sizes for Gloucester, Cheltenham & Tewkesbury.

Page 20 of 35

Page 21 of 35

Page 22 of 35

Extract from the County SHMA[4] – JCS Evidence Base

Extract from the CCHPR Report[10], please note how similar are the projected future migration inflow and

outflow to Cheltenham, given that this is the major component of population change for Cheltenham the

question as to who we build houses for needs to be examined.

Page 23 of 35

Extract from reference [5], Prospects for Private Sector Jobs Growth in SW England, Oct 2011, South

West Observatory - Economy Module http://economy.swo.org.uk/based on in-depth analysis of SW

labour market and projected economic recovery.

Page 24 of 35

Extract the ONS publication – Results, 2010-Based National Population Projections, 26 October 2011, fao

Cllr Simon Wheeler, as discussed at the JCS Working Group meeting, UK population has not always been

following the same growth path and will likely change again given the declared government policy change

on migration.

Page 25 of 35

Extract ONS Publication - Fertility Assumptions, 2012-based National Population Projections

Figure 3-1 shows the average completed family size (CFS) and the total fertility rate (TFR), which is defined

as the average number of children that would be born per woman if all women lived to the end of their

child bearing years and experienced the exact current age-specific fertility rates throughout their lifetime,

for the UK between 1973 and 2037.

Page 26 of 35 Best Practice given by the ONS Projections Unit on the correct use of the Interim 2011 Population Projection

On 11/03/2014 15:08, Projections@ons.gsi.gov.uk wrote:

Dear Ian, Thank you for your email.

The 2012-based subnational projections, which will extend to 2037, are due to be published in May/June 2014 (the

exact date has not been confirmed yet). You can keep track of future releases by checking the publications hub:

http://www.statistics.gov.uk/hub/index.html

We would not recommend extending the interim 2011 projection to 2031 because they were produced specifically for

a shorter time span.

More detail on how births are projected for local authorities can be found here: http://www.ons.gov.uk/ons/rel/snpp/sub-national-population-projections/Interim-2011-based/rpt-snpp-2011-based-

methodology-report.html#tab-Births

The subnational projections use specific local authority fertility rates to calculate births for each LA so local trends are

reflected. It should be noted that the total number of births is controlled to the national total to ensure consistency

between the subnational and national projections.

You are correct that the birth rate warning for the interim projections was due to unrevised pre-Census fertility rates

being applied to the revised Census-based population, which was higher than expected. The 2012-based subnational

projections will include fully updated rates and trends based on the 2011 Census results.

Please don't hesitate to contact us if you have any further queries.

Regards, Fern

___________________________________________________________________________________________________________________________________ Population Projections Unit | Office for National Statistics | Titchfield | PO15 5RR | Phone +44 (0)1329 444652 | email: projections@ons.gov.uk | www.ons.gov.uk

National Population Projections web page: www.ons.gov.uk/ons/taxonomy/index.html?nscl=National+Population+Projections Interactive population pyramids: www.ons.gov.uk/ons/guide-method/understanding-ons-statistics/interactive-content/dvc3-twin-national-projections-pyramid-link.html

Subnational Population Projections web page: www.ons.gov.uk/ons/taxonomy/index.html?nscl=Sub-national+Population+Projections

Interactive population pyramids: www.ons.gov.uk/ons/guide-method/understanding-ons-statistics/interactive-content/dvc4-twin-subnational-pyramid-link.html

Page 27 of 35 Whatever happened to our input in the early days of the JCS ...

15/3/2012 17:48, Ian (Bitworks - Cheltenham) wrote:

Hi Tracey,

Just a few points to throw into the JCS mix ...

The JCS should have a formal input from CBH on assessment of housing need & affordability across wards. Has the findings of the Fordham Gloucestershire Housing need Assessment 2009 report been included as

part of the evidence base? Use of previous consultations, the two large forum events held in Gloucester or Cheltenham on the 31st

January and the 4th of February 2005, Summary report on responses in relation to the Sub Regional Spatial Strategy for Gloucester and Cheltenham Prepared for Gloucestershire County Council and the Joint Steering Group by Land Use Consultants, February 2005, this is still very relevant if officers are going to be putting forward sustainable sites & numbers.

The Site Delivery Breakdown is premature and in my opinion should be removed until JCS Scenarios have been tested and agreed which members of all three Councils.

The 'new settlement' approach was raised by Steve Jordan as an alternative to unpopular urban extensions in a recent member briefing. Martin Horwood had a similar message recently when quoting from a government report, describing how vital those urban fringe green spaces were to people, bringing so much enjoyment, beneficial to health and are so important in peoples lives. This new settlement was discussed at one of the members briefings, potentially supported by JCS councils to enable collective investment in services, this has potential and should be investigated more fully in JCS phase 2. In my opinion, the whole question of urban extensions to save money on infrastructure & services needs detailed study on both the economics, environmental and public support point of views. Capacity on roads & local services are not always available in these 'sustainable' sites being put forward in development plans across the County. From an environmental view a new eco town, receiving the available government grants, collocated with employment, good transport links to Cheltenham Gloucester & Tewkesbury might be the environmental development scenario which is missing in the JCS report and would bring warm support from the public. The impact on affordability of homes in the JCS area could be tested on the JCS model, a strong eco theme, good services, designed for living with plenty of green space.

The new population demographic projections for Cheltenham needs to be reflected in any JCS recommendations for development to match housing need to delivery.

On the natural population, births & deaths across the three regions, how is this information obtained, are the registers available in electronic form to enable us to check our modelling in JCS phase 1 ?

The new home affordability model, any chance of having the mathematical formulas being used to connect the various parts used in the model, there was a diagram as part of the handout showing the interconnect but did not have the exact relationships.

Best Regards

Ian

Dear Councillors,

The Budget published yesterday made important announcements in regard to Planning, I have extracted the relevant section for you below. A full version of the budget report can be downloaded via the following link http://cdn.hm-treasury.gov.uk/budget2012_complete.pdf

Key issues for Cheltenham

National Planning Policy Framework (NPPF) will be published next Tuesday. As of this date the NPPF will be effective. We need to look ...

Page 28 of 35

An Ageing Population, Household Formation and Housing – Prof. John Ermisch Housing Studies, 1991 Vol. 6, pp.230-239 (one of a series of papers)

Prof Ermisch correctly predicted the changes to household formation rates in the UK in his peer

reviewed paper of 1991, this paper highlights the academic discipline required to validate any JCS

‘return to trend’ theory prior to use in assessing the objective housing need.

Abstract

One aspect of an ageing population is an increasing percentage of elderly people in the population, but the rest of the

age distribution of the population is also affected. That this is the case is clearer when it is recognised that the

primary cause of population ageing is a decline in the birth rate, with longer life expectancy playing a minor role. This

paper refers to Britain to examine the implications of prospective changes in the age distribution for housing.

There are three broad sources of change in the number of households:

changes in the age distribution of the population;

changes in marriage and divorce; and

economic and housing market developments which affect the propensity of individuals and families to set up

a household of their own.

We are now at the peak of household formation arising from age distribution changes. As Figure 2 shows, the

maturing of the baby bus generations produces a relatively steady decline in net annual household formation, from

about 160,000 per annum in 1989 to about 40,000 per annum just after the turn of the century.

Even taking into account other causes of 'household fission', it is inconceivable that other sources of growth in the

number of households will be sufficient to offset the deceleration in annual household formation indicated by Fig. 2.

---------------------------------------------

Here is another excellent and more recent review on household formation, Changing Living

Arrangements and Household Formation: A Review Prof. Ann Berrington, University of Southampton, UK

BSPS Meeting on Estimating Future Household Formation,

London School of Economics, 16th December 2013

Page 29 of 35

Extracts from the SHMA4(a) , these tables provide the 2011 census analysis, populations and households

across the county and the projection from the latest DCLG household formation, this comes directly from

the JCS evidence base and is usefully presented in Average Household Size for each district.

Page 30 of 35

Page 31 of 35 The National Press There have been many reports in the national press, great concern expressed over how developers and councils across England are unfairly targeting the greenbelt and open countryside in preference to town regeneration on existing derelict sites. This survey carried out by the Daily Mirror gives us a valuable insight; it’s really all about a misinterpretation of the NPPF, developer profit and taking the prime sites in early phasing. What is the correct interpretation of the NPPF, evidence provided to the Parliamentary Select Committee - Review on

the effectiveness of National Planning Policy Framework, Cheltenham Alliance Evidence, 7th July 2014 [1] [2]

Page 32 of 35

Local planning - Written ministerial statement by Nick Boles on local planning The Cheltenham Alliance has studied the detail of the recent written ministerial statement by the Parliamentary under Secretary of State for Planning; many of the particular notes are very relevant to the Joint Core Strategy:

Issuing robust guidance on flood risk sites,

the reaffirmation of Greenbelt protection,

that windfalls to be counted against numbers in the plan,

stressing the importance of bringing brownfield into use first,

the issue of oversupply and delivery, and

of particular importance to the JCS, the encouragement of joint working between local authorities, but clarifying that the duty to co-operate is not a duty to accept.

These statements are clear and unambiguous; they provide a welcome clarification of the National Planning Policy Framework. The recent letter of complaint dated 3rd March 2014 to Sir Michael Pitt (CE of the Planning Inspectorate) from Nick Boles MP, who was ‘troubled and disturbed’ over the Inspectorate's handling of the Reigate & Banstead Local Plan, adds further clarification on the Government’s Green Belt policy and requested that Inspectors be copied for implementation.

https://www.gov.uk/government/speeches/local-planning

Organisation: Department for Communities and Local Government

Delivered on: 6 March 2014

Page history:

Updated 6 March 2014, see all updates

Added link to the list of guidance documents cancelled by the planning practice guidance suite.

6 March 2014 4:05pm

First published.

6 March 2014 11:04am

Policy:

Making the planning system work more efficiently and effectively

Topic:

Planning and building

Minister:

Nick Boles MP Location:

Parliament

Written ministerial statement by Nick Boles on local planning.

The coalition government is committed to reforming the planning system to make it simpler, clearer and

easier for people to use, allowing local communities to shape where development should and should not go.

Planning should not be the exclusive preserve of lawyers, developers or town hall officials.

Page 33 of 35

We are also committed to ensuring that countryside and environmental protections continue to be

safeguarded, and devolving power down not just to local councils, but also down to neighbourhoods and

local residents.

We have already taken a series of steps to cut unnecessary red tape, such as the streamlined National

Planning Policy Framework reducing 1,000 pages of planning guidance to less than 50, revoking the last

administration’s bureaucratic regional strategies and extending permitted development rights to make it

easier to get empty and under-used buildings back into public use. I would like to update the House on

progress on this ongoing work.

An accessible planning system

In October 2012, we invited Lord Taylor of Goss Moor to lead a review into the reams of planning practice

guidance that we have inherited from the last administration.

My department subsequently held a consultation on the group’s proposals, and in August 2013, we launched

our proposed streamlined planning practice guidance in draft, consolidating 7,000 pages of complex and

often repetitive documents. Today, we are launching the final version of that practice guidance through an

accessible website.

We have carefully considered representations made on the draft practice guidance and feedback from hon.

members and noble peers in recent Parliamentary debates.

I would particularly note that we are:

issuing robust guidance on flood risk, making it crystal clear that councils need to consider the strict

tests set out in national policy, and where these are not met, new development on flood risk sites

should not be allowed

re-affirming green Belt protection, noting that unmet housing need is unlikely to outweigh harm to

the green Belt and other harm to constitute very special circumstances justifying inappropriate

development

making clear that local plans can pass the test of soundness where authorities have not been able to

identify land for growth in years 11 to 15 of their local plan, which often can be the most challenging

part for a local authority

making clear that windfalls can be counted over the whole local plan period

explaining how student housing, housing for older people and the re-use of empty homes can be

included when assessing housing need

ensuring that infrastructure is provided to support new development, and noting how infrastructure

constraints should be considered when assessing suitability of sites

stressing the importance of bringing brownfield land into use and made clear that authorities do not

have to allocate sites on the basis of providing the maximum possible return for landowners and

developers

noting that councils should also be able to consider the delivery record (or lack of) of developers or

landowners, including a history of unimplemented permissions; this will also serve to encourage

developers to deliver on their planning permissions

incorporating the guidance on renewable energy (including heritage and amenity) published during

last summer and making it clearer in relation to solar farms, that visual impact is a particular factor

for consideration

allowing past over-supply of housing to be taken into account when assessing housing needs

Page 34 of 35

on the 5 year supply of sites, confirming that assessments are not automatically outdated by new

household projections

clarifying when councils can consider refusing permission on the grounds of prematurity in relation

to draft plans

encouraging joint working between local authorities, but clarifying that the duty to co-operate is not

a duty to accept; we have considered and rejected the proposals of HM opposition to allow councils

to undermine green Belt protection and dump development on their neighbours’ doorstep

We will today also cancel the previous planning practice guidance documents being replaced by the new

guidance; a list has been placed in the Library. The planning practice guidance will be updated as needed

and users can sign up for email alerts on any changes, or view these revisions directly on the site. The online

resource is at: planningguidance.planningportal.gov.uk

Encouraging re-use of empty and under-used buildings

In August 2013, my department published a consultation paper on a further set of greater flexibilities for

change of use. Further reforms will save time and money for applicants and councils, encourage the re-use

of empty and under-used buildings and further support brownfield regeneration while ensuring regard to

potential flood risk.

New homes: retail to residential change of use

Outside key shopping areas, such as town centres, we want under-used shops to be brought back into

productive use to help breathe new life into areas that are declining due to changing shopping habits. This

will not only provide more homes, but increase the resident population near town centres, thereby increasing

footfall and supporting the main high street. Reforms will allow change of use from shops (A1) and financial

and professional services (A2) to houses (C3). This change of use will not apply to land protected by Article

1(5) of the General Permitted Development Order (National Parks, the Broads, areas of outstanding natural

beauty, conservations areas, World Heritage Sites).

We recognise the importance of retaining adequate provision of services that are essential to the local

community such as post offices. Consideration will be given to the impact on local services when

considering the potential loss of a particular shop. The onus will be on the local planning authority to

establish that the proposal would have a detrimental impact on the sustainability of a key shopping area or

on local services should they wish to refuse the conversion. When considering the effect on local services

they will have to take into account whether there is reasonable prospect of the premises being occupied by

another retailer. Local planning authorities will need to have robust evidence base to justify any decision not

to permit change of use using these prior approval tests.

In addition, to increase access to retail banking and to encourage new entrants, shops (A1) will be able to

change to banks, building societies, credit unions and friendly societies, within the A2 use class. This does

not cover betting shops or payday loan shops.

New homes: agricultural to residential change of use

These reforms will make better use of redundant or under-used agricultural buildings, increasing rural

housing without building on the countryside. Up to 450 square metres of agricultural buildings on a farm

will be able to change to provide a maximum of 3 houses.

We recognise the importance to the public of safeguarding environmentally protected areas, so this change

of use will not apply in Article 1(5) land, for example national parks or areas of outstanding natural beauty.

However, we expect national parks and other local planning authorities to take a positive and proactive

Page 35 of 35

approach to sustainable development, balancing the protection of the landscape with the social and

economic wellbeing of the area. National parks and other protected areas are living communities whose

young people and families need access to housing if their communities are to grow and prosper. I would

note that a prior approval process will allow for flooding issues to be addressed.

Change of use: extending access to education

We also propose to extend the existing permitted development rights for change of use to state-funded

schools to additionally cover registered nurseries. Agricultural buildings up to 500 square metres will also be

able to change to state-funded schools and registered nurseries.

I believe that these are a practical and reasonable set of changes that will help facilitate locally-led

development, promote brownfield regeneration and promote badly-needed new housing at no cost to the

taxpayer. The reforms complement both the coalition government’s decentralisation agenda and our long-

term economic plan.

------------------------------------

If you have got this far in this appendix maybe you have time to look at this anomaly on the population statistics

for Gloucester, using the ONS 2013 Analysis Tool take a look at page 2 on this Microsoft Excel file, the Population

Pyramid for Gloucester, select Gloucester from the pull down box, do you notice anything odd about the data ...