Spelthorne Local Plan - Preferred Options Consultation: Policies and Site Allocations

Comment ID pol/511
Document Section Spelthorne Local Plan Preferred Options: policies Housing Policy H1: Homes for All View all on this section
Respondent Carter Jonas (Mr Kieron Gregson) View all by this respondent
Response Date 21 Jan 2020
Comment

Policy H1 confirms the housing requirement of 603 pa for the period up to 2035. As we have addressed through the comments in relation to Policy ST2, we consider the Council has underestimated the actual housing figure(s) required.

Whilst we support the Council in utilising the standard methodology for assessing housing need and, as stated at footnote 1 of the Plan, reviewing this figure as and when appropriate in accordance with Government guidance, the exact methodology used is unclear as our calculations suggest an annual Local Housing Need (‘LHN’) figure of 606 dwellings per annum (‘dpa’). This is broken down below:

Step 1:

Households in Spelthorne 2020 – 43,087.

Households in Spelthorne 2030 – 47,416.

This is a total of 4,329 new households over the 10-year period, equivalent to an average household growth of 432.9 pa.

Step 2:

Spelthorne’s workplace-based affordability ratio is 11.57.

The adjustment factor is calculated as ((11.57-4)/4) x 0.25 = 0.473125))

Minimum LHN pa figure = (1 + adjustment factor) x projected household growth = 1.473125 x 432.9 = 638 (rounded up).

Step 3: Where the relevant strategic policies for housing were adopted more than 5 years ago (at the point of making the calculation), the LHN figure is capped at 40% above whichever is the higher of:

(a) the projected household growth for the area over the 10-year period identified in step 1 i.e. 432.9 dpa; or

(b) the average annual housing requirement figure set out in the most recently adopted strategic policies i.e. 166 dpa.

For assessment purposes, we can apply the 40% cap to annual average household growth figure, this equates to 606 dpa when rounded. Accordingly, the cap is applied and the final starting point for the Council’s housing need figure is 606 dpa.

Government has been clear that the 2014-based household projections are used within the standard method to provide stability for planning authorities and communities, ensure that historic under-delivery and declining affordability are reflected, and to be consistent with the Government’s objective of significantly boosting the supply of homes. However, In the longer term, the Government pledged to "review the [standard methodology] formula with a view to establishing a new method that meets the principles in paragraph 18 above by the time the next projections are issued".

The 2018-based population projections are anticipated for publication in Spring 2020, with the household projections that stem from these to be published in Autumn 2020. Accordingly, we can anticipate a revised methodology to be published prior to the adoption of the Local Plan, and possibly before its submission for EiP. 

Given this uncertainty, we suggest the Council should apply an approach to planning for its development needs by providing a buffer24. In doing so, it is noted that median house price to work-place earnings have increased from 5.38 at the turn of the century, to 11.57 times in 201825 and up from a pre-financial crash (2008) level of 7.92. Further, and as set out in our response to Policy ST2, given the poor past performance of the Council which was confirmed by the MHCLG in respect of the HDT, on top of the need to apply a buffer to the current assessed need in the interests of aligning with Government policy to significantly boost the supply of housing to address unaffordability, as set out at paragraph 73 of the NPPF, a 20% buffer will need to be applied in accordance with the HDT. Thus, the figure of 606 dpa should be the absolute minimum.

We also consider the Council is placing too much reliance on the Staines Opportunity Area which will not deliver the range and mix of units as identified in the latest Strategic Housing Market Assessment (‘SHMA’).

As a consequence, we consider Policy H1 to be unsound as it is not justified nor consistent with national policy.

Proposed Change