Inspector’s pre-hearing questions November 2014: Section 2, Housing needs
Eastleigh Borough Council response
EiP document ref.
EBC/4/2
Eastleigh Borough Local Plan
Examination
Inspector’s pre-hearing questions
November 2014:
Section 2, Housing needs
Eastleigh Borough Council’s response
28 October 2014
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Inspector’s pre-hearing questions November 2014: Section 2, Housing needs
Eastleigh Borough Council response
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Inspector’s pre-hearing questions November 2014: Section 2, Housing needs
Eastleigh Borough Council response
Section 2, Housing needs
2.1 There appear little dispute that Eastleigh falls entirely within a greater
Southampton Housing Market Area (HMA) as defined in the PUSH SHMA
(EBC/H4A (3.49 – 3.61). Any further comment?
EBC2.1 No further comment.
2.2 Does the Plan adequately provide for Eastleigh Borough’s reasonable share
of objectively assessed housing needs within the HMA based on current
evidence?
EBC2.2 Yes, on the basis of current evidence the Plan adequately provides for
Eastleigh Borough’s reasonable share of objectively assessed housing
needs within the HMA. This is explored in greater detail in chapter 4 of
the Housing Background Paper (EBC/H1), section 4 of the Council’s
response to the Inspector’s preliminary comments and questions
(EBC/2) and in paragraphs 2.43 to 2.46 of the Local Plan itself.
2.4 As a starting point, does the SHMA come to reasonable conclusions as to
housing needs based on demographic factors (population/household projections)
consistent with the evidence available at the time the SHMA was undertaken?
EBC2.3 Yes. Recognising that the 2011-based rates are likely to contain a
degree of constraint in household formation, whereas the 2008-based
rates are likely to over-estimate need, the core demographic
conclusions fixed on a midpoint between the 2011- and 2008-based
rates. For the whole of the PUSH area this represented a housing need
for 4,160 homes per annum (p.a.), with 2,045p.a. in the Southampton
HMA and 615p.a. in Eastleigh. The use of a midpoint headship
assumption is similar to the method used by NLP in their report for
Gladman (see representation ID 6666).
EBC2.4 The SHMA therefore came to a set of reasonable conclusions for
housing needs, although these must now be considered in view of more
up-to-date demographic information.
2.5 Should the population/household projections relied on by the SHMA be
adjusted to take account of the more recent 2012-based sub-national population
projections and the further analysis set out in the JGC study June 2014
(EBC/H1A)?
EBC2.5 Yes, however this does not mean that the SHMA is in itself out-of-date.
The SHMA is one input to the objective assessment of housing needs for
the PUSH area (including the borough and the Southampton HMA), and
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Inspector’s pre-hearing questions November 2014: Section 2, Housing needs
Eastleigh Borough Council response
was based on the most up-to-date information available at the time. It
is relevant to consider changes to the base data (Planning Practice
Guidance, ID 2a-016-20140306) and these are material to the Eastleigh
Borough Local Plan 2011-2029. However, the outcomes from the
objective assessments (see EBC/H1A, Section 9; EBC/H1, paragraphs
4.65-4.98) support the calculation of housing requirements using the
PUSH South Hampshire Strategy (EBC/G7) and therefore generate
conclusions that are consistent with those obtained using the PUSH
SHMA. An up-date to the outcomes of the PUSH SHMA to incorporate
the 2012-based DCLG household projections (when these are released)
is already intended as part of the work to identify what level of
development should be planned for across the PUSH area. Through
Policy MR1, any up-date that requires a different response to the
Submitted Eastleigh Borough Local Plan 2011 - 2029, July 2014
(hereafter the Submitted Local Plan)1 can be taken forward.
2.6 Does the SHMA provide a reasonable assessment of affordable housing
needs?
EBC2.6 Both the NPPF and PPG make it clear that the needs across a housing
market area are the critical measure rather than those of an individual
district. The findings of the SHMA in relation to affordable housing
needs within the Southampton HMA area are considered to provide a
reasonable assessment of affordable housing needs based on the
information available at the time. However, as with any projection of
future needs, the findings are dependent on certain assumptions e.g.
future income levels and the proportion that will be available to be
spent on accessing the housing market.
EBC2.7 The validity of the projections at a borough level are considered to be
less certain, as discussed in Chapter 4 of the Housing Background Paper
(EBC/H1, in particular paragraphs 4.80 to 4.86 & 4.93 to 4.95).
2.7 Is any adjustment in housing provision above demographic projections
required to help meet the identified need for affordable housing?
EBC2.8 No. For the reasons set out in the Housing Background Paper (EBC/H1,
paragraphs 4.48 - 4.50), the affordable housing needs across the
Southampton HMA are capable of being met within the existing planned
overall housing supply.
1
Submitted Eastleigh Borough Local Plan 2011 - 2029, July 2014, (the Submitted Local Plan)
comprises i) Revised Pre-submission Eastleigh Borough Local Plan 2011 - 2029, published February
2014 and ii) Schedule of Proposed Minor Changes, submitted to the Secretary of State in July 2014
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Inspector’s pre-hearing questions November 2014: Section 2, Housing needs
Eastleigh Borough Council response
EBC2.9 As well as the role of the private rented sector (see paragraph 2.12
below), we would draw attention to paragraph 7.3 of the Planning
Advisory Service (PAS) Technical Advice Note (Objectively Assessed
Need and Housing Targets2) published in June 2014. In summary this
notes that calculations of affordable housing need also comprise
affordable housing needs generated from existing households such as
those in unsuitable housing or projected to fall into need in the future.
Such needs do not create a net requirement for additional dwellings,
except for those who are currently homeless or ‘concealed’. As such, if
the occupiers move into suitable housing they will vacate a property
that could be occupied by people for whom it is more suitable.
EBC2.10 On the basis that all such households are able to move into suitable
housing, and with particular reference to Table 34 of Appendix X (sic) of
the SHMA (EBC/H4A, page 79), the following revised calculation of
affordable need in the Southampton HMA requiring additional affordable
housing can be provided:
4,033 (backlog need) plus 51,903 (newly forming households) minus
44,735 (supply) = 11,201 or 487 dwellings per annum
EBC2.11 Across the HMA it is clear that the affordable housing outputs do not
require an increase in estimates of the overall housing need (of all
tenures). There is a precedent for such an approach being accepted by
a planning inspector (see paragraph 57 of the 2 October 2014
Inspector’s Report for Mendip District Council’s Local Plan
(www.mendip.gov.uk/inspectorsreport), attached as Appendix 1 to this
document (page 17 below).
2.8 Are the assumptions made in the SHMA and by the Council about the
continuing role of the private rented sector with public subsidy reasonable in
assessing the need for new affordable housing?
EBC2.12 Yes. Whilst it is accepted that the private rented sector is not a form of
affordable housing as defined by the NPPF, it makes an important
contribution towards meeting the housing needs of some households.
There is no indication from government that there is appetite to
fundamentally reform the private rented market, nor that the role of
registered social landlords would be changed fundamentally. In the
absence of evidence to the contrary, there is no reason to ignore its
continuing potential to contribute to meeting future needs.
2
http://www.pas.gov.uk/documents/332612/6363137/Objectively+Assessed+Need+and
+Housing+Targets/f22edcc2-32cf-47f1-8e4a-daf50e4412f7
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Inspector’s pre-hearing questions November 2014: Section 2, Housing needs
Eastleigh Borough Council response
EBC2.13 The findings of the Inspector on the Mendip Local Plan (2 October 2014)
are pertinent to this matter. An extract of which is attached as
Appendix 1 to this document (pages 15-17 below).
2.9 In meeting overall affordable housing needs, to what extent, if any, is the
Council relying on delivery of new affordable housing by means other than the
policy percentage required from market housing developments (see EBC/2,
4.14)? Is any such reliance justified/realistic?
EBC2.14 The Council is not relying on providing any additional affordable housing
other than as a proportion of open market housing in accordance with
policy DM28. However, in the Council’s response to the Inspector’s
preliminary comments and questions (EBC/2, paragraph 4.14) other
mechanisms are identified through which the Council is seeking to
address local housing needs.
2.10 Do market signals indicate that there should be any uplift in the
assessment of need over and above demographic and other factors addressed
above? (See SHMA EBC/H4A, 6.90-6.97.) Does the recognition in the SHMA
(11.11-11.15) that: market characteristics did lead to a level of suppressed
household formation and the consequential adjustment made to the most recent
headship/household formation rate used in the favoured projection, adequately
take account of this market factor?
EBC2.15 The JGC study identifies two principal causes for the observed
suppression of household formation in the period 2001 - 2011: market
factors and the changing composition of some new households due to
international migration (EBC/H1A, paragraph 6.6). The study found that
up to 51% of the suppressed household formation within the
Southampton HMA could be attributed to market factors (EBC/H1A,
paragraph 6.7). A figure of up to 73% is identified within Eastleigh
borough. A partial return to 2008-based trends could address the
suppression of household formation resulting from economic factors
that are apparent from post-2007/8 market signals (e.g. increasing
rental values, increasing overcrowding) and a requirement of around
2,005 dwellings per annum is identified within the Southampton HMA
(EBC/H1A, Figure 8.4). Within Eastleigh borough, a supply of c.9,900
new dwellings (2011 - 2029) is suggested for this purpose (EBC/H1A,
Figure 8.3). In addition, it should be noted that market signals only
identify relatively modest market pressure in Eastleigh after also taking
account of longer-term assessments (of house prices, affordability and
rates of development)(EBC/H4A, paragraph 6.97 and EBC H1,
paragraph 4.43). The SHMA suggests that this evidence does not
provide a rationale for increasing the housing supply above
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Inspector’s pre-hearing questions November 2014: Section 2, Housing needs
Eastleigh Borough Council response
demographic projections in order to improve affordability (EBC/H4A,
paragraph 11.15).
EBC2.16 A total supply of 10,596 new dwellings is now identified (EBC/4/3,
Appendix 3) as having the potential to come forward in the Plan period.
In the context of the long-term trends in local market signals, relative
to national or sub-regional trends, further Eastleigh-specific action is
not justified (EBC/H1, paragraph 2.20).
2.11 Will the Plan’s housing provision and resulting increase in local workforce
facilitate expected/planned economic growth and employment provision as
reflected in:
a) The Plan’s overall employment proposals in policy S4;
b) The intentions of the PUSH South Hampshire Strategy 2012,
c) The ambitions of the LEP as set out in the Solent Strategic Economic Plan
March 2014 (EBC/G15)?
(The Council’s position is primarily set out in EBC/G12, drawing on other
evidence.)
EBC2.17 Yes in response to all parts of the question. Table 6 of EBC/G12 shows
that the planned housing provision will involve an increase in the
working population sufficient to meet the proposals in S4. In doing so,
the Submitted Local Plan will meet the objectives of the PUSH South
Hampshire Strategy, because the vast majority of planned development
(more than 90,000m2) is for industrial purposes; cf. Policy 6 of the
South Hampshire Strategy (EBC/G7). It will also meet the ‘policy off’
baseline labour demand that underpins the Solent LEP Strategic
Economic Plan (see EBC/G12, Table 8). The ambitions of the Strategic
Economic Plan have additional employment growth implications for the
borough through its support for development at the Ford-AirportRiverside strategic site (EBC/G15, page 104), parts of which are in
Eastleigh borough and are covered by policies E9, E10 and E12 in the
Submitted Local Plan. The surplus labour supply available after meeting
the labour demand implications of the Submitted Local Plan/Solent LEP
baseline requirements is considered to be sufficient to meet the job
requirements for developing the Ford-Airport-Riverside strategic site in
accordance with the Submitted Local Plan (see EBC/G12, page 28).
Therefore the LEP’s ambitions for job growth, as they relate to the
borough, are facilitated by the Submitted Local Plan.
2.12 Projections Proj A and Proj B in the SHMA (EBC/H4A) indicate a housing
requirement above those based on demographic modelling. (The figures for
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Inspector’s pre-hearing questions November 2014: Section 2, Housing needs
Eastleigh Borough Council response
Eastleigh for the plan period are summarised in EBC/H1, Table 4.2) Is the
caution about relying on these projections expressed in the SHMA (11.20-11.22)
justified for this Plan?
EBC2.18 Yes. There are a number of additional uncertainties in economic
projections relative to those for the purely demographic projections in
the SHMA (see EBC/H4A, paragraphs 7.36 and 7.50) (NB: the PROJ A
and PROJ B scenarios include assumptions about demographic
changes). These uncertainties include: how employment rates might
change in the future (linked to changes in the pensionable age, the
future value of pensions, personal health); how commuting patterns
might change (linked to changes in home working, fuel prices); and the
influence of double-jobbing (for related considerations, see EBC/G12,
paragraph 3.1.7).
EBC2.19 Most significantly, the influence of these factors and their uncertainties
undermines the use of the associated SHMA projections, as the
additional assumptions are: 1) not correlated with any detailed
interrogation of economic prospects in the PUSH area (EBC/H4A,
paragraphs 7.51-7.52); and 2) largely responsible for requirements
that are substantially greater than the LEP’s own objective assessment.
The LEP’s assessment identifies the potential for approximately 43,800
additional jobs for the period 2013 - 2030 (Solent LEP Economic
Outlook, pages 5 - 63) This compares with approximately 92,500 or
93,000 additional jobs for the period 2011 - 2031 for PROJ A and PROJ
B respectively (EBC/H4A, Appendix U, Table 12 ). It should also be
noted that the SHMA analysis for PROJ A or PROJ B is described as
indicative, in advance of the more detailed work that was undertaken
on behalf of the Solent LEP for its Strategic Economic Plan (EBC/H4A,
paragraph 7.35). Notwithstanding this implied preference for the Solent
LEP results, the large degree of uncertainty associated with long-term
economic projections should be recognised as a substantial limiting
factor, when considering economic scenarios such as PROJ A and PROJ
B (see paragraph EBC2.20 below).
2.13 The Employment Land Requirements Study Update (by Nathanial Lichfield
and Partners) May 2014 (EC1b1) sets out employment floorspace forecasts
based on Experian economic projections of March 2014. The floorspace
forecasts based on labour demand are much higher than the provisions made in
the Plan:
3
http://solentlep.org.uk/uploads/documents/OE_Solent_LEP_report_March_2014.pdf
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Inspector’s pre-hearing questions November 2014: Section 2, Housing needs
Eastleigh Borough Council response
a) Is the Council justified in not seeking to increase employment provision in
response to these forecasts and in preferring Oxford Economics projections for
the Solent LEP and other forecasts for employment floorspace? (See EC1c July
2014: BT1-BT8, BT9-BT19, BT20-BT27 and box on p32.)
EBC2.20 Yes. Employment provision should not be increased to reflect the
outcomes of the NLP updated labour demand scenarios (EBC/EC1b1).
The reasons for this are set out given in EBC/EC1c, principally: that
economic growth assumptions can lead to errors that are very
substantial (EBC/EC1c, BT44, pages 14-15); that the chosen geography
is partly responsible for this (BT5, page 15; see also: EBC/EC1b1,
paragraph 2.5); and that sense tests using other methods and results
for a more reliable geography (the Solent LEP area) suggest that the
updated scenarios are less robust estimates of future demand (BT1419, pages 18-20). The PPG also implies support for using the Oxford
Economics projections for the Solent LEP area in preference (Paragraph
008, ID: 2a-008-2014036). Both sets of projections (Oxford Economics
and Experian) take account of the new economic context, i.e. the
emergence from recession, however long-term projections are
particularly sensitive to optimism/pessimism in the macroeconomic
outlook (EBC/EC1b1, paragraph 2.50) and it is more reasonable to
recognise the national and global economic risks ( EBC/EC1c, paragraph
3.1.13) in setting development requirements.
b) The PUSH Strategy 2012 apportions employment floorspace requirements
between the constituent authorities, with a cities first approach (EBC/G7, Policy
6) and the LEP Economic Plan targets a limited number of public sector
interventions to promote growth. Does satisfactory alignment of the Plan with
these documents outweigh employment provision based on Borough-only
employment forecasts?
EBC2.21 Yes. Alignment with these documents enables the Council to discharge
its duty to co-operate (NPPF, paragraph 181) and there is insufficient
reason to depart from their provisions. The updated NLP labour demand
scenarios are based on projecting forward past trends for employment
growth within the borough using macro-economic assumptions. Past
economic growth within the borough may not be repeated as
businesses wishing to locate in south Hampshire will be faced with
different choices (the availability of floorspace across the sub-region will
Please note that ‘BT’ stands for Boxed Text. See EBC/EC1c, where substantial new
additions to the evidence were made at July 2014 in the form of boxed text, to enable
their differentiation from matters that had previously been considered in preparing the
Revised Pre-submission Eastleigh Borough Local Plan (February 2014).
4
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Inspector’s pre-hearing questions November 2014: Section 2, Housing needs
Eastleigh Borough Council response
not mirror the past (EBC/EC1c. Tables 4 & 5)) and they may weigh the
factors affecting their choice differently. Borough boundaries do not
generally determine business choices (EBC/EC1c, paragraph BT10),
whereas the Solent LEP area more closely approximates to a selfcontained economic area and so is less susceptible to spatial variations
in employment growth. The requirements for the borough derived from
the Solent LEP employment forecasts are robust compared with past
trends in the development of floorspace (EBC/EC1c, paragraph BT14 BT19) and they broadly agree with the South Hampshire Strategy
(EBC/G7, Policy 6). Moreover, there are no market signals or data on
market intelligence that count strongly in favour of increasing the
supply of floorspace in Eastleigh in particular (EBC/EC1c paragraphs
3.1.3 - 3.1.13).
EBC2.22 It is recognised that the supply of new premises (NB: not necessarily
additional floorspace, but its quality and nature) should increase across
the LEP area/south Hampshire generally. This will be facilitated by the
Submitted Local Plan and other local plans in south Hampshire
(EBC/G7, Policy 6).
2.14 Does the Plan have sufficient flexibility to accommodate more employment
development if economic conditions are more favourable than the forecasts
relied on by the Council? What would be the implications for the adequacy of
housing provision if any such flexibility was taken-up by more employment
development?
EBC2.23 The Plan has sufficient flexibility to accommodate more employment
development, whilst respecting the most robust assessments for
growth. The quantum of planned development is described as a
minimum (policy S2) to recognise that projections of need are not
sufficiently accurate to be considered definitive and that the policy
imperative is to encourage growth (NPPF, paragraph 19). This is
reflected in the development management policies of the Submitted
Local Plan (DM11 - 12) which support the redevelopment and
intensification of existing sites to complement the planned allocations.
Moreover, locations are identified within the plan that could
accommodate additional B Class floorspace (most notably policies E10
and E12, but also E9); and other employment-related uses (policies
CF1, E2, E6, E7, HA2). Policies E10 and E12 in particular provide
sufficient flexibility to accommodate up to 2,600 additional B Class jobs.
This would bring the labour demand associated with the Submitted
Local Plan’s B Class and A1 Class development to around 5,800 total
jobs (see EBC/G12, Table 6/Figure 3). This compares to a potential
labour supply of 8,933 residents ( EBC/G12, Table 2). Even accounting
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Inspector’s pre-hearing questions November 2014: Section 2, Housing needs
Eastleigh Borough Council response
for the labour demand associated with other sectors of the economy
(EBC/G12, Section 5.2), it is considered that the planned housing
provision would be adequate to meet labour demand within the borough
to 2029.
2.15 How should Eastleigh Borough’s appropriate share of objective need within
the HMA be determined? Should it be done by an objective assessment for the
Borough only (eg EBC/H1 4.68 and EBC/H1A Fig 9.1) or should it be informed by
the South Hampshire Strategy 2012(EBC/G7) (rolled forward to 2029) and, in
due course, by the review of that Strategy?
EBC2.24 The apportionment of south Hampshire’s agreed housing requirements
has, to date, been determined through joint working by the PUSH
authorities. The sub-region has been confirmed as consisting of two
overlapping housing market areas (EBC/H4A, paragraph 3.49) and it is
therefore reasonable and logical that all the PUSH authorities should
work together on the apportionment of housing requirements.
EBC2.25 Indeed, it is only by enabling the Council to work in partnership with
other authorities in the PUSH area, to review the South Hampshire
Strategy (EBC/G7) that the objectives, principles and policies of the
NPPF would be met (NPPF, paragraph 157). The apportionment of the
future housing requirement for the PUSH area, with any necessary
updating in the light of new data, must have regard to objective
district-level analysis (e.g. in the SHMA). However, the inadequacies of
these analyses (e.g. EBC/H1, paragraph 4.89) should preclude their use
in identifying an appropriate share for the borough without a
corresponding review of the South Hampshire Strategy. Therefore, it is
reasonable to roll-forward the South Hampshire Strategy to determine
the borough’s share of the objective need for the Southampton HMA,
after considering the objectively assessed need (as per: EBC/H1,
EBC/H1A, EBC/H4A) and the requirements of national policy and
legislation. It is unreasonable to use a borough-only objective
assessment to determine this share, when considering national policy
and legislation.
2.16 In the context of all the evidence, does provision in this Plan represent a
reasonable contribution to meeting objective assessed housing needs within the
Southampton HMA?
EBC2.26 Yes. The Council’s Housing Background Paper (EBC/H1, Section 4)
considers at length the apportionment of the objectively assessed need
in the Southampton HMA and the provision currently planned by the
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Eastleigh Borough Council response
authorities that make up the market area. The JGC study for the
Council (EBC/H1A) updated the projections in the light of the 2012based sub-national population projections published early in 2014, (this
study is described at EBC/H1 from paragraph 4.55). The conclusions of
the SHMA identified the ’most robust’ housing requirement for the
Southampton HMA as 2,045 dwellings per annum; the JGC study on the
same basis produced a slightly lower figure of 2,019 dwellings per
annum.
EBC2.27 Section 5 of EBC/H1 discusses how the identified need in the
Southampton HMA will be met. The analysis shows that the planned
provision by the relevant authorities, including Eastleigh, is only 50
dwellings per annum below the SHMA requirement to 2026 and about
25 per annum below the JGC requirement (750 and 375 homes
respectively over the full period to 2026) (EBC/H1, Table 5.1 at
paragraph 5.2).
EBC2.28 This marginal shortfall in the period up to 2026, and how to address the
subsequent need beyond 2026 is most appropriately addressed through
the update to the South Hampshire Strategy. The Eastleigh Borough
Local Plan 2011-29 commits to providing a minimum of 10,140
dwellings with sufficient flexibility in its strategy to deliver more than
this. Current calculations (EBC/4/3, Appendix 2) are that there is
potential for 10,596 dwellings in the period to 2029 which is some 456
more than the plan requirement. Note: this is a small increase from the
31 March 2014 position set out in EBC/H1, paragraph 5.14.
EBC2.29 Until the South Hampshire Strategy is updated, the flexibility shown in
the Plan will ensure a reasonable contribution to the objectively
assessed housing need within the Southampton HMA. There is no
reasonable basis for quantifying, at a borough level, an apportionment
of the marginal shortfall in the period to 2026 nor indeed how all
housing need beyond that time will be most appropriately met.
2.17 Given all the above, did the Sustainability Appraisal sufficiently address
reasonable alternatives in relation to the overall scale of housing?
EBC2.30 Yes. Appendix 2 of the Sustainability Appraisal sets out the appraisal of
the range of options for housing growth considered. These are taken
from the PUSH Spatial Strategy (EBC/G7) and the PUSH SHMA 2014
(EBC/H4A) and cover options across the range of the scenarios
discussed in the SHMA, including both the higher and lower ends.
EBC2.31 The Council has also taken account of alternative figures for the
borough in assessing future housing needs (see EBC/H1, Table 4.2 and
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Eastleigh Borough Council response
paragraphs 4.69-4.70). These figures fall within the range of growth
scenarios in Appendix 2 of the SA and are therefore considered to fall
within the scope of the appraisal. The SA appraisal concludes that
options at the extremes of the range appraised are not appropriate to
be taken forward due to significant negative effects on the three
sustainability themes ‘community’, ‘economy’ and ‘environment’
(EBC/G2, pages 87-90). Alternative figures that have been put forward
in support of representations to the Revised Pre-submission Eastleigh
Borough Local Plan 2011-2029 and which lie outside the range
appraised are not considered to be reasonable.
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APPENDIX 1
Extract from ‘Report on the Examination into Mendip District Local
Plan Part 1: Strategy and Policies’ (Inspector’s Report 2nd October
2014; File Ref: PINS/Q3305/429/1)
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