Decision details
Core Strategy Programme
Decision Maker: Cabinet.
Decision status: Recommendations Approved
Is Key decision?: No
Is subject to call in?: Yes
Purpose:
A progress report on the Core Strategy
programme, and the results of further evidence base work.
Decision:
1. That the Core Strategy programme be rescheduled to take account of the need to review the evidence base for the Core Strategy including the housing and employment targets and the Council’s 5-year housing land supply.
2. That Officers be authorised to start work on a new Strategic Housing Market Assessment, a Strategic Housing Land Availability assessment and a Strategic Economic Development Land Availability Assessment.
Reasons for the decision:
The
Publication draft of the Core Strategy was due to be presented to
Cabinet on 21 November 2012 for approval to undertake the next
stage of public consultation (regulation 19) in December
2012. In parallel with the Core
Strategy programme, the adoption of the Integrated Transport
Strategy was due to be considered at the same meeting. The two documents are co-dependent because
of the need for transport infrastructure to support strategic site
allocations.
In
recent months a number of core strategy examinations in other parts
of the country have been suspended because the presiding Inspectors
were not satisfied with the evidence supporting the local
authorities’ housing and employment targets. The implications arising from these suspensions
need to be given full consideration, particularly in the context of
the National Planning Policy Framework (NPPF), to ensure the
Council’s evidence base is robust enough to support
Maidstone’s Core Strategy at examination.
There
also appears to have been a shift at examination from locally
determined targets to a greater emphasis on meeting national
projections. This includes greater emphasis on demonstrating cross
boundary working and also bearing in mind that the South East Plan
targets have still not been revoked.
The
comments received during recent consultations on the draft Core
Strategy Strategic Site Allocations and the draft Integrated
Transport Strategy together with representations submitted on Core
Strategy policies in 2011 will be fully considered as part of the
review of the evidence base.
Unsound
core strategies
Three
key Inspectors’ reports on core strategy examinations have
been considered: Bath & North East Somerset (June 2012),
Salford (September 2012) and West Berkshire (July
2012). The first two examinations have
been suspended. Following an initial
examination suspension, the West Berkshire Core Strategy was on
balance found sound because of a substantial strategic land
allocation that met the aims of the NPPF in the short
term. However, the West Berkshire Core
Strategy will be subject to an early review to address the
Inspector’s outstanding concerns.
Housing targets and the South East Plan
A
common theme running through all three Inspectors’ reports is
the local authorities’ inadequate demonstration of a
realistically deliverable supply of housing land to meet identified
housing targets.
The
National Planning Policy Framework (NPPF) published in March 2012
confirms that local authorities can continue to draw on evidence
submitted to regional strategies “supplemented as
needed by up-to-date, robust local evidence” (NPPF para
218). Whilst acknowledging that core
strategies needed to be in general conformity with regional
strategies, the Inspector for West Berkshire (in making specific
reference to the South East Plan) stated:
“The SEP was not able to plan for
all need and demand and it indicates (7.6-7.7) that local planning
authorities can test higher numbers through their development
plans. The SEP had a long evolution before its final approval in
2009 and much of the evidence dates from much earlier, eg 2004
household projections. Its assessment of housing needs and demand
is not therefore up to date”.
Up-to-date demographic information
The
West Berkshire Inspector stipulated that the most up-to-date ONS
based household projections (i.e. DCLG published household
projections 2008) should form part of any assessment of housing
need and demand.
Use of environmental constraints
The
NPPF gives emphasis to meeting objectively assessed needs, with
sufficient flexibility to adapt to changes, unless adverse
environmental impacts can be demonstrated (NPPF para
14). The Sustainability
Appraisal/Strategic Environmental Assessment for the West Berkshire
Core Strategy did not fulfil this need because the South East Plan
target was assumed to be the local level of need, whereas more
up-to-date evidence demonstrated a greater need. Even where the need for affordable housing is
substantially greater than the annual average for overall housing
provision, the NPPF expects this need to be met in full unless
adverse environmental impacts can be demonstrated. Affordable housing need must be given weight in
assessing the overall level of housing need.
The SHMA and the Housing Market Area
The
NPPF requires local authorities to have a clear understanding of
their housing needs through the preparation of a Strategic Housing
Market Assessment (SHMA), working with neighbouring authorities
where housing market areas cross administrative boundaries (NPPF
para 159). Bath and North East Somerset
had failed to examine its housing market area, only looking within
administrative boundaries in its SHMA.
The integration of housing and employment targets
Strategies for housing, employment and other land uses should be
“integrated” and “take full account of relevant market and economic
signals” (NPPF para 158). The
Inspector for Bath and North East Somerset emphasised that this
does not mean there is justification for making this link the
primary consideration because there is not a linear link between
homes and jobs (i.e. by the use of a conversion
factor). However, it is important to
ensure that there are sufficient workers to fill planned jobs or to
achieve other objectives such as a reduction in out
commuting.
Maidstone’s housing target
In 2010
the government announced its intention to abolish regional
strategies and, although that decision was subsequently quashed
following judicial review, the revocation of regional strategies
was pursued through the Localism Bill.
Despite the enactment of the Bill in 2011, the regional strategy
for the south east remains part of the development
plan. It was in the context of the
proposed revocation of the South East Plan that the Council
resolved to test the regional spatial strategy housing target of
11,080 dwellings for the period 2006 to 2026. There was no nationally prescribed methodology to
establish a local target so the Council had a certain amount of
freedom to develop its own methodology.
MBC housing target – demographic evidence
Part of
the work to determine the local housing target comprised a series
of demographic and labour supply forecasts, which were commissioned
from Kent County Council (KCC), and published in October
2010. The dwelling based forecasts were
produced to gain an understanding of how the different dwelling
targets would correlate with population forecasts based on varying
migration trends (i.e. zero net migration, and 5/10/19 year
migration trends). The forecasts used
2006 DCLG household projections which was the latest published data
at that time.
On 9
February 2011, Cabinet resolved to consult the public on a target
of 10,080 homes in a dispersed pattern of development. Although the methodology used to set the housing
target was untested at examination, the target was supported by
demographic forecasts and the evidence submitted to the South East
Plan examination. The subsequent
publication of the NPPF in March 2012 confirmed that local
authorities could continue to draw on evidence submitted to
regional spatial strategies, supplemented by up-to-date evidence
(NPPF para 218).
New recent demographic data
However, core strategy examination Inspectors are clearly
placing little weight on the evidence submitted to the regional
spatial strategy examination, deeming it to be out-of-date because
of being based on 2004 household projections and, in the absence of
up-to-date evidence, are emphasising the need to use the latest
2008 base date DCLG household projections that were published in
November 2010.
The
demographic and labour supply forecasts for Maidstone were
published in October 2010 and were based on 2006 DCLG household
projections which were the latest published figures at that
point. The forecasts are now being
updated, using 2008 DCLG household projections as part of the
assessment, and the assumptions that feed into the new demographic
forecasting model now used by the County are being
scrutinised. This review must be
undertaken before the Council proceeds to Publication consultation
on the Core Strategy and Submission.
The SHMA and the SHLAA
The
Maidstone Strategic Housing Market Assessment (SHMA) was published
in 2010 and identified Maidstone as a single housing market area
(HMA). The SHMA looked at the extent of
the HMA for Maidstone and concluded that, based on 2001 census data
and the results of the SHMA household survey, Maidstone borough had
a relatively high level of self-containment. Taking account of the backlog of need, the SHMA
identified an affordable housing need that is double the
Council’s current annual housing target. Such a need clearly cannot be met in
full.
The
Planning Inspectorate places great emphasis on the SHMA at
examination, because it is the key document which forms the basis
for developing planning policies by considering the characteristics
of the housing market.
Maidstone’s SHMA must be updated to reflect 2011 census data
and the latest demographic forecasts to ensure it satisfies the
NPPF requirement for local authorities to identify objectively
assessed needs (NPPF para 14). A review
also offers the opportunity to re-examine Maidstone’s HMA as
part of the Council’s duty to cooperate, although the outcome
of a review may confirm Maidstone as a single HMA.
The
Maidstone Strategic Housing Land Availability Assessment (SHLAA)
was prepared in accordance with national guidance and was published
in 2009. Since then the Council has
monitored SHLAA sites that have been granted planning permission
and acknowledged additional sites that have been submitted since
the publication date.
The
starting point for setting a dwelling target is the identification
of housing need through demographic forecasting and the
SHMA. The next step is to understand
Maidstone’s capacity to deliver the identified
need. This work will be a crucial part
of the evidence base if Maidstone were to be in a position of
having to justify a target lower than its identified need at
examination. A new SHLAA will be
required, beginning with a borough wide call for sites, and
followed by an assessment and sustainability appraisal of all sites
(similar to that undertaken for potential strategic site
allocations).
Economic development needs and SEDLAA
Maidstone’s economic development land requirements must be
integrated with its housing needs, taking full account of market
and economic conditions. The delivery
of sites to meet the borough’s identified needs and demand
must be tempered by its ability to deliver enough sustainable sites
and to provide an adequate supply of labour. This is particularly important in the context of a
continued market recession.
Further
work on employment demand is currently underway, in parallel with
demographic forecasts. To gain an
understanding of the capacity of the borough’s economic
development land, a Strategic Economic Development Land
Availability Assessment (SEDLAA) should be undertaken alongside the
SHLAA. This would also be followed by
an assessment and sustainability appraisal of potential
sites.
Five
year housing land supply
Each
year local authorities must demonstrate a 5-year supply of
deliverable housing sites. Maidstone
has maintained a 5-year supply to 1 April 2011 but is unlikely to
meet this requirement from 1 April 2012. Although the Council continues to experience high
levels of dwelling completion rates on sites with planning
permission, the windfall sites on previously developed land that
formerly contributed towards this supply at a steady pace are no
longer materialising at the same rate.
This issue must be addressed.
Implications of rescheduling the Core Strategy programme
Rescheduling the Core Strategy programme will take the
document’s Submission date beyond March 2013, which is the
end of the transitional period for local plans set out in the
NPPF. In April 2013, due weight will
still be afforded to policies adopted since 2004 according to their
degree of consistency with the NPPF (NPPF paras
214-215). Maidstone’s development
plan document policies for affordable housing and open space were
adopted in 2006 so can be given due weight. Due weight will also be given to emerging plans
and policies depending on their stage of preparation (NPPF para
216).
Given
the Inspectors’ reasons for suspending core strategy
examinations, together with the impacts of the recession and the
need for up-to-date data, a rescheduling of the programme is
required to ensure the evidence supporting the Maidstone Core
Strategy is sound. To a large extent it
is “business as usual” for the development management
process because the saved local plan policies used to determine
planning applications generally accord with the NPPF, and
affordable housing and open space policies are given (and will
continue to be given) due weight until such time as they are
superseded by new policies.
Furthermore, the Council has had a good record of winning appeals
since the NPPF has come into effect.
Meanwhile, successful consultations on the draft Core Strategy
strategic site allocations and the draft Integrated Transport
Strategy were completed in October 2012. The consultation events were very well attended,
and the Council has received 2,654 comments from 1,170 individuals
and organisations on the draft strategic site allocations; and 594
individuals and organisations submitted 1,869 comments on the draft
transport strategy. The strategic site
allocations policies will be merged with the draft Core Strategy
policies, and the document will be appropriately amended as a
result of the two consultations undertaken in 2011 and
2012. The Integrated Transport Strategy
will be reviewed in the light of comments received and amended
accordingly, and will reflect any modifications to the Core
Strategy.
A
progress report on the Core Strategy, Integrated Transport Strategy
and related documents will be presented to Cabinet by March
2013.
Cabinet were requested to give Officers authorisation to start work on the SHMA, SHLAA and SEDLAA immediately.
Alternative options considered:
Cabinet could resolve to proceed with the current Core Strategy programme and to not review the evidence base supporting its housing and employment targets. This approach is not recommended because of the exceptionally high risk that, without up-to-date evidence to support its targets, the Core Strategy will not be found sound.
Wards Affected: (All Wards);
Details of the Committee: None
Contact: Rob Jarman, Head of Development Management Email: suewhiteside@maidstone.gov.uk Email: Robjarman@maidstone.gov.uk.
Report author: Rob Jarman, Sue Whiteside
Publication date: 23/11/2012
Date of decision: 21/11/2012
Decided: 21/11/2012 - Cabinet.
Effective from: 01/12/2012
Accompanying Documents: