Inspector rejects South Worcestershire's Development Plan housing evidence
Photo courtesy of brianac37 on Flickr
4th November 2013
Planning Inspector Roger Clews’ Interim Conclusion of South Worcestershire’s Development Plan (SWDP) has questioned the housing evidence provided based on 23,200 dwellings required by 2030.
Malvern Hills District Council, Worcester City Council and Wychavon District Council, who constructed the joint local plan, will now need to do undertake more work on the technical evidence used.
In a letter to the councils, he said, the number of homes required “is likely to be substantially higher than the 23,200 figure identified in the submitted Plan.”
He said “I consider that there are three fundamental shortcomings in the approach taken in the SHMA. In combination they mean that its assessment of housing need is unreliable and does not provide a sound basis for the planning of housing provision in the Plan area.”
Firstly, he said “The SHMA does not use Household Representative Rates (HRR) drawn from the 2008-based DCLG household projections or any other official population or household statistics. Instead, for the purposes of the SHMA, HRR were recalibrated using the total number of occupied properties in the Plan area in 2011, drawn from Council Tax records.”
By contrast, when the 2011 household figures drawn from the 2008-based household projections are compared with the 2011 Census figures, the overall discrepancy is significantly lower, albeit with greater divergences in the individual figures for two of the three districts.”
Secondly, he said “The job growth figures underlying CS4 were based on employment forecasts for the three South Worcestershire districts produced by Cambridge Econometrics [CE] in 2009. It appears to have no basis in current trends and it is not reflected in any of the other employment forecasts provided to the examination.”
His third point highlighted a lack of convincing evidence to support the assumed increases in older people’s economic participation rates.
On the matter of the Duty to co-operate with neighbouring Local Authorities, he said “The main area of controversy is whether or not the South Worcestershire Councils’ have co-operated effectively over housing provision with the three north Gloucestershire councils who are producing a Joint Core Strategy, and with Birmingham City Council. It is argued that the Plan fails to take adequate account of unmet housing need in the JCS area and in Birmingham.
Turning to Birmingham, it may well be, on current evidence, that the City Council [BCC] will face a substantial shortfall of land within its boundaries to meet its arising housing need. The extent of the shortfall, and proposals for how it might be addressed, is currently being considered through a sub-regional Strategic Housing Study.”
The SWCs are not directly involved in the sub-regional Strategic Housing Study and the inspector agreed this appropriate given their distance from Birmingham.
Clews concluded “At this time, therefore, there is no clear evidence that any land in South Worcestershire will be required to meet part of Birmingham’s housing need. It would be contrary to the plan-making objectives of the National Planning Policy Framework [NPPF] to delay the examination of the Plan until any such evidence may have emerged. In that event, the on-going duty to co-operate will require the SWCs to engage with BCC and other authorities over the issue.”
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