Issue 2, Edgars Limited, Representor 106
H
WEST OXFORDSHIRE
LOCAL PLAN 2031
Examination in Public
Stage 1 – Issue 2
Statement
on behalf of
Rectory Homes (Mr Webb)
Representor 106
September 2015
Issue 2, Edgars Limited, Representor 106
Introduction
1.
This statement is submitted on behalf of Rectory Homes and Mr Webb. Rectory
Homes have recently acquired an interest in Land at North Leigh which is
owned by Mr Webb. This statement should be read alongside and as an update
to Mr Webb’s previous representations.
2.
The following sections of this statement consider and respond to the Inspector’s
Stage 1 Matters and Questions with respect to Issue 2 – Overall housing
requirement.
It should be read alongside and as an update to Mr Webb’s
previous representations which are now taken forward on behalf of Rectory
Homes (Rectory).
3.
The following responds to the particular questions of the Inspector under this
issue as relevant to Edgar’s previous representations.
The demographic starting point
2.3 The Council’s position is that the latest DCLG household projections
(published 27 February 2015) should be used as the starting point in
preference to the demographic modelling in the SHMA (see WOLP1,
3.25). Is this new starting point a necessary change or, nevertheless, a
reasonable one for the Council to use in preference to the SHMA?
4.
The NPPG states that ‘wherever possible local needs assessments should be
informed by the latest available information’ but also that ‘this does not
automatically mean that housing assessments are rendered outdated every
time new projections are issued’ (Ref Paragraph: 016 Reference ID: 2a-01620150227).
5.
It is not a necessary change. Rectory are concerned that the use of the more
recent 2012 household projections, based on trends from the previous 5 years,
reflect a period of low housebuilding and a period influenced by the economic
recession.
6.
The Council consider that high rates of housebuilding in the period 2005-2007
inflated previous projections. Rectory consider that the projections used should
take account of periods of higher housebuilding rates as they reflect more
buoyant economic conditions (and high levels of demand for housing) as well
as periods of recession.
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Issue 2, Edgars Limited, Representor 106
7.
Rectory is concerned that the 2012 projections reflect a period of recession and
relatively low housebuilding in the district and as such reflect assumptions
which will underestimate the growth in households over the plan period.
Migration
2.4 The Council’s preferred demographic starting point is to take an
average from projections derived from migration assessed over 10
years and 5 years, giving 423 households per annum (pa) and 446 new
homes pa (WOLP1, 3.29, drawn from HOU1, 3.44 and Appendix 1,
Report by John Hollis, Table 1). Note in Table 1 the differences
between the household projections and the corresponding dwelling
requirement new homes. (which allows for a 5.167% vacancy/2nd
homes rate). All statements should make clear at all times which terms
are being used.
2.5 Is an adjustment to the migration component of the DCLG
projection for West Oxfordshire, necessary? If not necessary, is the
Council’s preferred adjustment still reasonable?
8.
Rectory does not consider the Council’s approach is sound. The premise of the
Council’s use of the 2012 projections is partly on the basis that previous
projections incorporated inflated migration trends.
9.
The Council rely on the NPPG (Ref ID 3-036-20140306) which states that if
there is robust evidence that past high delivery informing projections is no
longer realistic – projections can be adjusted down accordingly.
10.
Rectory consider that the past high delivery rates reflected a period of
economic buoyancy and when the supply of housing was more in line with
demand.
There is not robust evidence that such circumstances could not be
expected again.
11.
The Council’s approach to adjust downwards migration trends by averaging a 5
and 10 year average is not considered reasonable. Rectory consider that the
migration trends used should take account of periods of economic buoyancy
and high delivery/demand and that use of higher, longer term 10 year
migration rates is a more robust approach.
Market signals
2.20 Do market signals support an uplift above the demographic
starting point? If so, is this uplift complementary with and similar in
scale to the uplift parties consider justified in response to affordable
housing need? (I do not want further evidence on the signals
themselves and at the hearing I am hoping that a detailed discussion
of the signals will not be necessary.)
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Issue 2, Edgars Limited, Representor 106
12.
Rectory would highlight that the Council’s evidence (for example HOU1, E19)
indicates that the SHMA considered market signals but made no adjustment to
the demographic projection for West Oxfordshire. This is also highlighted to be
a reflection of strong past housing supply which helped to minimise the
imbalance between supply and demand and associated price increases (HOU1,
E19, bullet point 3).
13.
However, the Council now advocates a lower housing requirement on the basis
that past high delivery influenced the demographic baseline.
Rectory is
concerned that should this be accepted, market signals should be reviewed and
a significant uplift applied to reflect high demand.
Otherwise, this appears
contradictory.
14.
Any reduction the demographic baseline based on past high delivery should be
at least compensated by an uplift to reflect higher levels of demand which the
SHMA and the Council recognise. The uplift should also consider affordable
housing need as it is clear that from the Council’s evidence (WOLP1 3.76 –
3.77) that the housing target as proposed will not address the total affordable
housing need identified in the SHMA.
It is however noted that the
recommended SHMA target of 660 homes per annum was based on an uplift to
align with the ‘committed economic growth’ scenario which Rectory considers
most appropriate.
Economic
strategy
and
growth
and
homes/workforce/jobs
compatibility.
2.21 The SHMA took into account housing needs based on securing a
sufficient workforce to deliver the jobs anticipated to arise under the
Committed Economic Growth scenario (eg SHMA, Table 90). This
growth scenario reflects the above-trend economic opportunities and
potential of Oxfordshire as assessed in Economic Forecasting to Inform
the Oxfordshire Strategic Economic Plan and SHMA February 2014
(ECON2). HOU1 (eg 3.98) and WOLP1 (3.83 - 3.91) explains why the
Council now considers that this scenario should not be taken into
account in deriving the housing requirement and its reliance on the
economic baseline projection.
2.22 For the reasons given by the Council in WOLP1, including the
closure of Caterham F1 team in the district and the limited funding
secured in the Oxfordshire Growth deal compared with what had been
sought to support the ambitions of the LEP Strategic Economic Plan
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and the related lower jobs growth expected to 2021, is the Council’s
reliance on the baseline line projection justified?
15.
Rectory would highlight concern that the Council’s reasons for now relying on
the baseline projection reflect a pessimistic and short term view. It is noted
that the Caterham F1 team, previously based at the Leafield Technical Centre,
went into administration and closed in 2014. It should also be acknowledged
that the Leafield Technical Centre has been the base of other F1 teams in the
past including Arrows F1 and Super Aguri F1. There would not appear to be
reasons why it may not be occupied by another F1 team in the future.
16.
The Council also question the potential for further indirect jobs as being
dependent on job growth elsewhere in the knowledge economy spine.
The
Council’s Economic Snapshot (ECON 1, Figure 8.1), however, recommends the
Council position itself more with the Oxfordshire Knowledge Economy and
growth plans of the Strategic Economic Plan.
If realised, this would indicate
more potential for direct jobs under a planned economic growth scenario.
17.
The Council indicate that they remain fully supportive of the LEP Strategic
Economic Plan. The ‘Committed Economic Growth’ scenario forms the basis of
the SHMA’s recommended housing requirement for West Oxfordshire and was
tested and agreed in light of the Strategic Economic Plan.
The Council’s
reliance on the baseline scenario is not justified.
2.23 As argued by the Council, is the jobs led model used in the SHMA
too circular and thus flawed to justify a housing requirement (HOU1,
3.80-3.89)?
18.
The Council agreed the jobs led model used in the SHMA. No alternative model
which
considers
the
planned/committed
economic
growth
scenario
for
Oxfordshire as a whole and the aspirations of the Oxfordshire Strategic
Economic Plan has been presented.
2.24 Are other Councils in Oxfordshire still pursuing the Committed
Economic Growth scenario to inform their Local Plans and Economic
Strategies?
If
so,
does
that
support
its
credibility
and
likely
achievement?
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19.
It is understood that the housing targets of both the Cherwell and Vale of White
Horse Local Plans reflect the Committed Economic Growth scenario. This
supports its credibility and likely achievement – and in Cherwell’s case this
having been examined and found sound.
20.
The Committed Economic Growth scenario reflects the Oxfordshire Strategic
Economic Plan which is one of the cross boundary programmes which the
Oxfordshire Growth Board is working to deliver – and to which West
Oxfordshire is party.
2.28 Is the Council’s approach consistent with the Government’s
commitment to securing economic growth and the role of the planning
system in this regard (eg NPPF 18-20?)
21.
The Council are party to and fully support the Strategic Economic Plan.
The
Council also agreed the basis of the Committed Economic Growth scenario of
the SHMA which resulted in the SHMA conclusion of objectively assessed need
for West Oxfordshire of 660 homes per annum.
22.
In planning for a lower housing target than required to meet Committed
Economic
Growth
the
Council’s
approach
is
not
consistent
with
the
Government’s commitment to securing economic growth.
Overall approach
2.30 On the basis of the Council’s different approach to identifying the
OAN/housing requirement for West Oxfordshire compared with that
set out in the SHMA for the whole HMA (eg updated demographic base,
more limited uplift for affordable housing, different economic
projection), does the Council’s approach now comply with NPPF
paragraph 159 - to prepare a SHMA, working with neighbouring
authorities where housing market areas cross administrative
boundaries - and what are the implications?
23.
In Rectory’s view, the Council’s approach does not comply with the NPPF
paragraphs 47 and 159 which require a clear understanding of housing needs in
their area drawn from a SHMA which has assessed housing needs, addresses
affordable housing needs and caters for housing demand.
24.
The NPPF paragraph 47 requires that the evidence base is used to ensure Local
Plans meet full market and affordable housing needs across the housing market
area.
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25.
In Rectory’s view, the Oxfordshire SHMA 2014 provided an NPPF compliant
assessment of objectively assessed needs.
The Council still recognise the
Oxfordshire SHMA as the most current and comprehensive assessment of
housing need for the HMA (WOLP1, para 1.4).
26.
The Council took a lead role in commissioning and also signing off the
Oxfordshire SHMA. The Council also imply that their current criticisms of the
Oxfordshire SHMA take their lead directly from the SHMA (WOLP 1, paragraph
1.8).
27.
Rectory does not understand why, if the Council had concerns regarding the
SHMA approach for West Oxfordshire, these concerns were not addressed prior
to the finalisation of the SHMA.
28.
In Rectory’s view, the Council’s approach is unsound in failing to address
objectively assessed needs across the HMA.
29.
Furthermore, should the Council’s criticisms of the SHMA be accepted, then this
undermines the basis of the SHMA and consequently there will not be a
comprehensive and NPPF compliant SHMA assessment of objectively assessed
needs for the Oxfordshire HMA.
30.
This is effectively acknowledged by the Council in WOLP1 para 1.15 whereby it
is stated that the suggested updated demographic information will ultimately
need to be fed into a review of the SHMA but that no decision has been taken
on this.
31.
It also clear (for example WOLP1 para 1.11) that the most recent DCLG
projections also indicate different baseline projections for other authorities in
the HMA.
32.
The Council’s approach implies the SHMA is out of date, and not just for West
Oxfordshire.
It also undermines the ‘post-SHMA’ work of the Oxfordshire
Growth Board to address Oxford’s unmet housing needs.
If the Council
considers that a SHMA review is now needed, this casts doubt on their cooperation as part of the Oxfordshire Growth Board and the timetable to address
Oxford’s unmet needs.
33.
The failure to provide an up-to-date and comprehensive SHMA for the
Oxfordshire HMA on which to test objectively assessed needs is also an
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unsound approach as it is contrary to NPPF paragraphs 47 and 159. Should the
Council’s criticisms of the SHMA be accepted, such a consequence would also
mean that the Council’s approach is unsound.
34.
Should the Council’s criticisms of the SHMA be accepted, Rectory consider that
a SHMA review will be required to provide sufficient and robust evidence for the
HMA as a whole to enable an NPPF compliant Local Plan to be adopted.
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