Written evidence from Tetlow King Planning
As you are aware, we were commissioned by the National
Housing Federation (NHF) to carry out research in to the impact
of the proposed revocation of regional spatial strategies on housing
targets in England.
Our research was formally submitted as evidence to
your Committee on 15 September 2010. We then appeared alongside
the NHF at the 8 November 2010 hearing.
Subsequently at the 22 November 2010 hearing the
Rt Hon Eric Pickles MP was questioned about the findings of our
research. He responded by claiming:
"I am sure the Committee doesn't need me
to point out how iffy that evidence was. It was conducted on the
basis of a telephone call in which the person at the other end
might decide on various numbers. No formal decision has been taken
by local authorities."
Mr Pickles' dismissive comments are unwarranted.
Having discussed the matter with Josephine Willows, Inquiry Manager,
we herewith submit supplementary evidence in rebuttal.
Our supplementary evidence takes the form of an updated
version of the previously submitted report. This includes updated
figures and an expanded section on methodology.
Inter alia our update demonstrates that:
- The number of homes no longer being planned since
the Government announced its intention to abolish regional strategies
has now increased to a total of around 201,509. This number
has risen dramatically since our first assessment was carried
out on in July 2010; this concluded that 84,530 dwellings were
no longer being planned for.
- 88% of the estimated 201,509 dwellings derive
from official local authority sources, such as Core Strategy consultation
documents or press releases. Whilst it is true that the remaining
12% do come from unofficial tip offs or estimates we have been
very cautious in applying such figures. As our research has evolved,
however, it has become evident that some unofficial reductions
from earlier iterations have subsequently been formally confirmed
by local authorities. In every case where this has occurred our
earlier estimates have been proved to be either correct or an
underestimate of the final total reduction. In no instance have
we been shown to have exaggerated the reduction.
- The local authorities mentioned in our report
have, for the most part, set out or decided to set out their reduced
housing targets in Core Strategy consultation documents, in preference
to the RSS figures. Despite the lack of any independent testing,
many of the authorities concerned are according these reduced
housing targets full planning policy status and using them as
the basis for calculating current five year land supply requirements.
It is disingenuous for the Secretary of State to
suggest that our figures have no formal basis. The vast majority
of the figures quoted in our report are from official sources
in the public domain and are already being used as part of local
planning policies to determine planning application and fight
appeals. Where unofficial sources have been used, experience has
shown that they may be erring on the side of caution.
It is particularly disappointing that Mr Pickles
MP provided no different evidence of his own to substantiate his
assertions. We would have expected the civil servants within the
DCLG to at least have a finger on the pulse; and wonder whether
he was sufficiently briefed.
SECTION 1—INTRODUCTION
1.1 The National Housing Federation (NHF)
originally commissioned Tetlow King Planning in
June 2010. The original brief was to prepare
a report examining the impact of the Right Hon Eric Pickles MP's
letter to Council Leaders dated 27 May 2010 announcing the Coalition
Government's intention to "rapidly abolish" Regional
Plans/Regional Strategies/Regional Spatial Strategies (the all
encompassing abbreviation 'RSS' is utilised throughout the rest
of this document).
1.2 Tetlow King Planning is a national town planning
consultancy specialising in housing. We operate and act for a
wide range of clients across the public and private sectors, including
local authorities, government organisations, house builders, housing
associations, investors and landowners. Further details are available
at www.tetlow-king.co.uk.
1.3 Our original report of July 2010 examined
the implications of the recent announcements on housing targets
in emerging local Core Strategies and the determination of planning
applications. The original report concluded that the Eric Pickles'
letter had had a very significant initial impact in reducing the
planned housing targets of local authorities, both directly and
indirectly. Including unofficial estimates we quantified this
as 80,400 dwellings.
1.4 At the time a number of other authorities
had also refused applications for strategic housing developments
or delayed work on them, citing the Eric Pickles letter. This
amounted to 4,130 dwellings, producing a grand total of
84,530 dwellings.
1.5 A number of updates to this research have
been carried out. The full time line is shown below.
6 July 2010—The Secretary of State officially
revoked all RSS across England.
19 July 2010—The first assessment was carried
out. This concluded that 84,530 dwellings were no longer
being planned for.
2 September 2010—A brief update of some of
the figures was carried out for Channel 4 News. This found that
98,740 dwellings had been cut from housing targets in England.
15 September 2010—An updated report was submitted
to the DCLG Select Committee as evidence for the Inquiry in to
the Abolition of Regional Spatial Strategies. This found that
139,589 dwellings were no longer being planned for.
4 October 2010—The third update was carried
out and uncovered more reductions in housing targets by local
authorities in England. The NHF press release announced that plans
for around 160,000 dwellings had been dropped and Tetlow
King Planning expected that figure to rise to between 280,000
to 300,000 in 12 months.
8 November 2010—The NHF and Tetlow King Planning
appeared at the House of Commons Communities and Local Government
Select Committee Inquiry into the Abolition of Regional Spatial
Strategies. An update was prepared for the Committee; which concluded
that figure now stood at 181,734 dwellings.
10 November 2010The High Court ruled that the Secretary
of State's decision to revoke all RSS was unlawful.
22 November 2010—Appearing at the Select Committee
Inquiry into the Abolition of Regional Spatial Strategies, Mr
Pickles was questioned about the research by Tetlow King Planning
submitted to the Select Committee on 8 November. He responded
by saying:
"I am sure the Committee doesn't need me
to point out how iffy that evidence was. It was conducted on the
basis of a telephone call in which the person at the other end
might decide on various numbers. No formal decision has been taken
by local authorities."
13 December 2010—BBC News at One ran a story
on the most recent update on the research by Tetlow King Planning.
This concluded that 200,245 dwellings were no longer being
planned for.
1.6 The second section of this report briefly
sets out the methodology of the research and reflects on some
strengths and weaknesses. Section 3 sets out the findings. Our
conclusions can be found in the fourth section.
1.7 In response to Mr Pickles comments made on
the 22 November 2010, the research has been updated with further
elaboration of the methodology.
1.8 This update is submitted to the Select Committee
as supplementary evidence. It concludes that the number of houses
that are no longer being planned for in England is now 201,509
dwellings as a direct and indirect result of the Pickles letter
and the revocation of RSS.
SECTION 2—METHODOLOGY
Background
2.1 The NHF originally commissioned the research
to ascertain what impact the Coalition Government's announcement
that RSS were to be abolished was having on the behaviour of Local
Planning Authorities (LPA), focussing specifically on housing
targets in emerging Core Strategies and the refusal of applications
for strategic housing developments.
2.2 The Eric Pickles letter to Council Leaders
(dated 27 May 2010) set out the Coalition Government's intention
to 'rapidly abolish' RSS (Appendix A). The letter stated that
decisions on housing supply 'will rest with Local Planning
Authorities...without the framework of regional numbers and plans'.
2.3 In the immediate aftermath of this a number
of authorities announced that they would be reducing their housing
targets or suspending work on Core Strategies. A number also delayed
the determination of large strategic housing developments. The
NHF wanted to get a 'fuller picture' of the impacts across the
South and East of England (excluding London where the regional
plan is not being abolished).
2.4 After the completion of our initial report
the Secretary of State officially revoked RSS, on 6 July 2010.
We subsequently became aware of both further cuts by some of the
authorities initially identified and of further local authorities
across the country reducing their housing targets below those
set out in emerging and adopted RSS. In addition, there has been
a number of planning applications and appeals for large housing
developments in which the revocation of the RSS has been cited
as the principal reason for refusing planning permission.
2.5 On the 10 November 2010 the High Court ruled
that the Secretary of State's decision to revoke each and every
RSS was unlawful. The effect of this was that whilst the Localism
Bill will eventually formally abolish RSS, they will remain part
of the development plan until the Bill receives Royal Assent.
METHOD
OF RESEARCH
2.6 For the original report, it was agreed that
the best method of collecting this information was a telephone
survey of planning policy departments; combined with Tetlow King
Planning's own local knowledge and planning expertise.
2.7 The initial research covered 152 local
authorities. National Park Authorities were excluded. The
research split the authorities into three regions coterminous
with RSS boundaries: South West England, South East England and
the East of England .
2.8 The telephone survey was carried out between
28 June and 2 July 2010. The interviewers identified themselves
as employees of Tetlow King Planning seeking information on the
Core Strategy and the implications of the Eric Pickles letter.
2.9 The scope of the subsequent updated research
has been broader and includes official announcements across the
whole of England, not just the three regions previously considered.
The further research has been based on the monitoring of national,
local and professional media, in addition to our own intelligence
and other projects. The initial telephone research also highlighted
a number of dates when official announcements were to be made
by local authorities on new housing targets. These were followed
up.
2.10 A full telephone survey of all authorities
across England was not carried out; however further telephone
calls to individual local authorities were made where appropriate
to establish the accuracy of data.
Official Housing Target Amendments
2.11 There were many examples of official announcements
of reduced housing targets in emerging Core Strategies and Local
Authority Press Releases. Some of these were as a direct result
of the Pickles letter. Others had been more indirectly influenced.
2.12 Some authorities had already been planning
for lower targets before Eric Pickles' letter was released. Several
of the West of England Authorities had released Core Strategy
consultation documents setting targets below the emerging RSS
figure. Some had been more influenced by Caroline Spelman MP's
letter, sent in August 2009, advising local authorities of a potential
Conservative Government's intention to abolish the RSS and not
to progress controversial housing targets. Others had intended
to legally challenge the South West RSS if adopted and so had
not been planning on the basis of the emerging RSS figures in
any case.
2.13 These authorities have still been included
in our findings. Their reductions cannot solely be considered
as the outcome of the Eric Pickles letter. However, this letter
may have been used to further justify their earlier strategy.
2.14 A good example is Bristol City Council (BCC),
which had submitted its Core Strategy to the Secretary of State
with a reduction of 6,000 on the emerging RSS figure. The Inspector's
initial comments prior to the Examination had been that the Core
Strategy appeared unsound in setting a target below the emerging
RSS figure. However, BCC's case for this lower figure at the first
hearings into the housing provision heavily relied on the Eric
Pickles letter.
2.15 Local authorities will have taken their
decisions to cut housing targets against different policy backgrounds.
This could have been:
- After the Caroline Spelman MP's letter was sent
to Council Leaders.
- Following on from the Eric Pickles letter sent
on 27 May 2010.
- Following the official decision to revoke the
RSS on 6 July 2010
- After the CALA Homes High Court decision reinstated
RSS as part of the development plan.
2.16 In all cases, local authorities have been
planning for life when they will be able set their own housing
targets which do not comply with RSS.
2.17 As our research has been updated and the
figures have increased following further announcements from local
authorities these "indirect" reductions form an even
smaller proportion of the total figure. The indirect figures now
make up only 14% of the total headline figure of 201,509 dwellings.
2.18 As stated above, since the successful legal
challenge by CALA Homes, RSS once again form part of the development
plan. However, we have noted that this has not dissuaded local
authorities from continuing to reduce their housing targets; as
they are aware that the RSS will eventually be abolished by the
Localism Bill.
Unofficial Housing Target Amendments
2.19 Part of the brief set by the NHF for the
original report was to uncover any unofficial information on changes
to housing targets. Five distinct types of authorities were identified
in this respect. Each is set out below and the different approaches
used are explained.
- 1. Local authorities which are considering
setting a lower target which did not accord with the relevant
RSS, but are yet to make an official announcement.
- 2. Local authorities where officers were
prepared to unofficially speculate what the housing target may
eventually be.
- 3. Local authorities where officers were
not prepared to speculate over figures. Officers were then asked
about members' and local residents' objections to RSS imposed
figures and how likely they considered it that there would be
some reduction. Then, using local knowledge of the district and
our planning knowledge, a judgement was made on what the reduction
or increase in the figure might be. On each occasion a cautious
approach was used when projecting a figure. On most occasions
this relates to a particularly unpopular urban extension.
- 4. Local authorities in which officers were
prepared to suggest that a decrease is very likely, but there
was insufficient information or evidence to make an informed judgement
on how much.
- 5. The remainder of local authorities either
already had Core Strategies adopted; were happy with the housing
targets in the RSS; or would not speculate as to whether the housing
target would increase or decrease following formal discussions
with members.
2.20 The figures behind our unofficial estimates
have only come from authorities in the second and third categories.
As stated a cautious approach has been used when projecting figures.
2.21 Given that officer speculation was unofficial
it is not considered appropriate to release details of individual
authorities. Instead an aggregated figure is given for each region.
2.22 In this updated report, official announcements
on targets which were previously unconfirmed have simply been
reclassified. It is not considered appropriate to state where
this has happened as this would identify where unofficial tip-offs
had occurred.
2.23 As the research has evolved over the months
most of the unofficial figures have become official. We have observed
that on every occasion where a figure from the second category
has been used it has proved to correct or the final reduction
was larger than suggested.
2.24 An example of this is an authority where
the officer told us that a further reduction on top of the official
reduction was extremely likely in the future of around "a
couple of thousand homes" relating to a specific urban extension.
This proved to be correct and a further two and a half thousand
homes were also cut from the housing target on top of this.
2.25 For unofficial figures which fall into the
third category, our estimates have been exceeded on every occasion
bar one, where our estimate of 100 homes to be cut proved to be
correct.
2.26 It is important to note that all figures
will ultimately be subject to testing at examination and could
alter in the long or medium term. In theory Inspectors could order
local authorities to revise their housing targets upwards back
towards RSS levels. However given the localism agenda and the
thrust of likely changes to the examination process this does
seem unlikely. It should also be noted that the original research
was carried out prior to any formal Coalition Government announcements
on house building incentives. In November 2010 consultation began
on the New Homes Bonus; but we have not seen any discernible subsequent
decrease in housing target reductions being announced.
2.27 The final figure can only be considered
approximate, as it includes precise figures, combined with forecasts.
However, we have provided a breakdown below of the percentages
of the final headline figures which fall into each category:
- Official figures (inc. Applications and appeals)—176,799
dwellings (88%).
- Unofficial estimates from officers (second category)—18,350
dwellings (9%).
- Unofficial estimates our estimates (third category)—6,360
dwellings (3%).
- Grand Total—201,509 dwellings.
2.28 The above analysis clearly shows that the
vast majority of our total figure (88%) comes from official documents,
press releases or statements produced by local authorities which
are in the public domain.
2.29 The reductions to housing targets will not
yet be found in adopted Core Strategies. Some local authorities
are close to adopting their Core Strategies with these new figures,
but for the most part they are within consultation documents and
press releases. However these new reduced local housing targets
are, for the most part, being applied as planning policy and utilised
as the basis for calculating the local five-year housing supply
within the terms of PPS3. The new reduced housing land supply
"requirements" are in turn being used to refuse applications
and fight appeals for large new strategic housing developments
previously anticipated in the RSS. Such schemes are being opposed
on the grounds that they are no longer required in order to meet
revised lower local housing targets.
2.30 Given the high proportion of the figures
that are from official local authority sources and are currently
being used for housing land supply purposes, we consider it disingenuous
for the Secretary of state to claim that the research is "iffy"
and:
"conducted on the basis of a telephone call
in which the person at the other end might decide on various numbers.
No formal decision has been taken by local authorities."
2.31 Only 9% of the figures are based on unofficial
officer speculation; which on every occasion so far has subsequently
proved to be correct, and if anything overly cautious. A further
3% is based on discussions with officers and our own local knowledge.
Again, these have previously proved to be ultra-cautious estimates.
Delayed or Refused Planning Applications and Appeals
2.32 In our first report, each local authority
was also asked about whether it was aware of any applications
in the district which had been refused or delayed due to the Eric
Pickles letter. For this updated report, we have added in other
planning applications that have used the revocation of the RSS
as a reason for refusal. These are listed individually in the
following section.
Dismissed Planning Appeals
2.33 We have uncovered a number of planning appeals
where the revocation of the RSS has been one of the main reasons
for the appeal being dismissed by the Secretary of State.
2.34 In two cases we highlight the application
was recommended for approval by the Inspector, but the Secretary
of State used the revocation of the RSS to recalculate the five
year land supply.
OBSERVATIONS
Regional Variations
2.35 The vast majority of local authorities are
now at least reviewing housing targets. The official figures listed
below represent those which have completed this process and have
released revised housing targets through Core Strategy consultation
documents or press releases. The initial research noted that the
majority of reductions were coming from authorities in the South
West. Over time we are beginning to see the South East and East
of England catch up, although they are still some way behind,
as the split in figures below shows:
- South East—56,620 dwellings (official—49,620
dwellings).
- East of England—32,948 dwellings (official—22,848
dwellings).
- South West—81,256 dwellings (official—75,906
dwellings).
- Other regions—25,055 dwellings (official—23,155
dwellings).
- Delayed or refused appeals and applications—5,630
dwellings.
2.36 The reason for this imbalance between the
southern regions can be explained by the different stage the RSS
had reached in the respective regions. In the South West, the
new RSS was still emerging and therefore could not yet have been
subject to formal legal challenge, as the East of England plan
had been. Therefore, many authorities which would have challenged
the RSS when formally approved by the Secretary of State have
used this policy announcement to reduce their housing target figures
accordingly. In contrast some of the Hertfordshire districts had
already successfully legally challenged the RSS and did not have
a housing target.
Further Announcements and Reasons for Delay
2.37 Whilst a large number of authorities have
not officially announced reduced targets, we still expect more
to come in 2011. We have previously predicted that the total eventual
number of reductions may be between 280,000-300,000 dwellings
by October 2011. As can be seen from the graph below 100,000 homes
were cut from targets in just four months between August and December
2010. This suggests that our earlier prediction may ultimately
prove somewhat conservative.
2.38 There are many authorities who are still
reviewing their housing targets, and are taking some time to announce
the results of their review. The reasons for this delay are numerous.
2.39 Firstly, there is still great uncertainty
over how the Coalition Government will reform the planning system;
nearly all authorities stated in the initial round of research
that they are waiting for further guidance. Even with the publication
of the Localism Bill the picture is not much clearer. The consultation
on the New Homes Bonus has now finished, but having more details
on these incentives does not initially seem to have stemmed the
flow of housing reductions.
2.40 The second main reason for authorities not
making final decisions on their housing targets is that the role
of evidence to underpin housing targets has not been removed from
the planning guidance. PPS3 has recently been reissued, restating
the importance of Strategic Housing Market Assessments (SHMAs)
and Strategic Housing Land Availability Assessments (SHLAAs) as
forming a robust evidence base to underpin Core Strategies. When
revoking RSS, CLG Chief Planner Steve Quartermain, stated that
housing targets still need to be supported by evidence and will
be subject to examination. This should make it difficult to reduce
housing numbers in areas where the demonstrable demand and need
is high.
2.41 In 2011, we are expecting announcements
from the local authorities that make up Leicestershire, Nottinghamshire,
Derbyshire and Gloucestershire, to name but a few. Authorities
within all these counties are currently reviewing their housing
targets and the evidence that underpins them.
2.42 A very large number of authorities are still
unprepared to comment, even unofficially, until they have completed
work on their evidence base to support their housing targets.
2.43 The reinstatement of the RSS to the development
plan may slow the progress of some authorities in taking their
Core Strategy forward to the examination stage. These local authorities
will not want to have their Core Strategy examined with a housing
target that does not accord with the RSS figure, whilst the RSS
is part of the development plan.
2.44 Many local authorities are not this far
progressed and are still some distance from the examination stage.
For these authorities the reinstatement will have little effect.
They may be content to consult on a draft Core Strategy including
a new reduced housing target, in the knowledge that the RSS will
be closer to abolition by the time the Core Strategy reaches the
examination stage.
2.45 The number of planning applications apparently
refused or delayed by the Eric Pickles letter and the revocation
of the RSS was less than we might have expected. It is considered
that there are two main reasons for this:
- 1. The number of large strategic planning
applications in the system is lower than normal due to the impacts
of the recession on the housing market.
- 2. Many local authorities have announced
they are reviewing their housing targets, but have yet to announce
a new figure. Developers with sites within these authorities,
will naturally be cautious about submitting applications or appeals
for schemes which may be required by the current housing target,
but which may be at significant risk of falling foul a reduced
local housing supply requirement.
SECTION 3—FINDINGS
THE SOUTH
WEST
Official Announcements
3.1 The following authorities in the South West
have formally announced they are seeking housing targets lower
than in the Proposed Changes of the RSS. These are listed below
in addition to where Eric Pickles MP's letter was an indirect
influence on this decision.
- Exeter City Council—3,000 dwellings—On
the 29 June 2010 the Council's Executive Committee
approved a Pre-Submission consultation draft of the Core Strategy.
This contained a housing target of 12,000 dwellings. The emerging
RSS had set a target of 15,000 for the City Council. The Council's
website makes explicit reference to the Coalition Government's
intention to abolish the RSS.
- Teignbridge District Council—1,100 dwellings—Preferred
Options Core Strategy consultation draft was released in October
stating the Council considers 740 dwellings per annum to be "the
most appropriate figure". Whilst the time period is not
comparable to the RSS, this is still effectively a reduction on
the RSS figure of 795 dwellings per annum.
- Torbay Council—5,000 dwellings—LDF
Working Party agreed in the week commencing 28 June 2010 to use
10,000 dwellings as its "baseline figure" in their Core
Strategy. The RSS set a target of 15,000.
- Cotswold District Council—900 dwellings—In
July 2010, the Council announced its intention to reduce the housing
target from 6,900 set in the RSS to 6,000 dwellings.
- Bournemouth Borough Council—1,500 dwellings—The
consultation draft of the Core Strategy was released on 29 June
2010 without the urban extension to Bournemouth proposed in the
emerging RSS. Bournemouth had threatened to legally challenge
this part of the RSS if adopted.
- Taunton Deane Borough Council—4,000
dwellings—Following the change of Government, the Council
announced that the Core Strategy would now plan for between 12,000-14,000
new dwellings on 17 May 2010 due to "indications from
Government, following the General Election". This is
significantly lower than the RSS figure of 18,000 dwellings. Indirectly
influenced, as these 'indications' were confirmed by the letter
sent 15 days later.
- Bristol City Council—9,560 dwellings—The
initial research identified a 6,000 dwelling reduction in the
Council target, since then a further 3,560 dwellings has been
removed from the official target with 30,000 dwellings now only
an aspiration. There are a number of reasons for this reduction,
but the revocation of the RSS is part of the Council's justification.
In our first report this was considered to be 'indirectly influenced'
because the Council had taken the action expecting a change in
government and planning policy. In this respect they have been
proved correct.
- Bath and North East Somerset Council—10,300
dwellings—The earlier Core Strategy consultation document
in November 2009 set out the Council's intention to plan for 15,500
dwellings, lower than the 21,300 in the RSS. The Pre-submission
version of the Core Strategy in December the Council announced
a further reduction down to 11,000 new dwellings.
- North Somerset Council—13,350 dwellings—The
initial research uncovered a reduction under very similar circumstances
to BANES of 9,000 dwellings. Another round of consultation on
the Core Strategy took place in February 2010 without an urban
extension put forward in the emerging RSS. The housing targets
were again reviewed following the Pickles letter and on the day
after the report was completed the Council announced a further
reduction of between 12,750-10,750. A further round of consultation
on just three "key changes" took place in October 2010.
This asked for comments on their new housing target of 13,400
dwellings. This was a total reduction of 13,350 from the RSS target.
- South Gloucestershire Council—11,300
dwellings—Consultation on the Pre-Submission version
of the Core Strategy has now finished. This started prior to the
release of Eric Pickles MP's letter, but as with the previous
two examples it will have given them the justification to continue
with the figure of 21,500 dwellings, below the RSS figure of 32,800
dwellings.
- Cornwall Council—11,796 dwellings—Cornwall
is about to launch its Core Strategy consultation in January 2011.
This asks for comments on a range of potential housing targets
between 37,000 and 57,000 dwellings. Even the highest option of
57,000 dwellings is reduction of 11,796 dwellings from the RSS
figure. NB: the RSS figure is the sum totals of the targets of
the former authorities that now make up Cornwall Council.
- East Devon District Council—700 dwellings—The
Core Strategy consultation document released in October 2010 included
a reduction in the overall housing target of 700 dwellings.
- South Hams District Council—500 dwellings—The
Core Strategy was adopted prior to the RSS Proposed Changes being
released. This included a 500 dwelling increase to the new community
at Sherford. The Council opposed this increase and has decided
to stick with this lower figure having progressed its Site Allocations
DPD to the examination stage.
- South Somerset District Council—3,100
dwellings—The Council released their Preferred Options
Core Strategy Consultation document in October 2010. This included
a new housing target of 16,600 dwellings.
3.2 This is a total of 47,737 dwellings
reduced from housing targets as a direct result of the decision
to abolish RSS. 28,169 dwellings were reduced as an indirect
result of the letter. A total of 75,906 dwellings were
reduced from housing targets officially.
Unofficial Estimates
3.3 The research uncovered a further 5,350
dwellings unofficially likely to be reduced from various targets.
A further four authorities were likely to reduce targets, but
there was insufficient evidence or information to ascertain what
this might be. In total 17 of the 38 local authorities surveyed
in the South West are either officially or unofficially reducing
housing targets below the RSS level.
Summary
3.4 Including unofficial estimates and official
announcements for both direct and indirect reductions, the total
reduction in housing targets is 81,256 dwellings. This
amounts to around 13% of the regional target for the South West
in the emerging RSS which was 592,460 dwellings.
THE EAST
OF ENGLAND
Official Announcements
- North Hertfordshire Council/Stevenage Borough
Council—9,200 dwellings—North Hertfordshire
Council announced on 15 June 2010 that it had suspended work on
the Stevenage and North Hertfordshire Area Action Plan "for
the immediate future". This would have provided 9,200
dwellings for an urban extension to Stevenage (SNAP). The RSS
required both authorities to work together as the urban extension
would have spilled over into North Hertfordshire. Whilst it is
important to state that work has not been abandoned, given the
level of opposition to this urban extension, it is difficult to
see how it can be delivered in the new era of localism.
- Luton Borough Council/Central Bedfordshire Council—10,650
dwellings—The two authorities have jointly taken the
decision to reduce the target for the Luton/South Bedfordshire
area to 23,150 by 2026 from 33,800 dwellings by 2031.
- Borough of Broxbourne Council—640 dwellings—The
Pre-submission version of the Core Strategy was published in August
2010. This is a reduction to 240 dpa from the 280 dpa in the East
of England Plan.
- Suffolk Coastal District Council—1,088
dwellings—Suffolk Coastal District Council began consultation
on changes to its housing target in November 2010. The Council's
preferred target is 446 dwellings per annum, a reduction of 1,088
dwellings from the RSS target.
- St Albans City and District Council—770
dwellings—St Albans City and District began consultation
in December 2011 on a document entitled "The Core Strategy:
Consultation on the Strategy of Locating Future Development in
the District". This set a new housing target of 250 dwellings
per annum between 2011 and 2028 having been given the opportunity
to set their own housing target. The adopted RSS said that in
the absence of targets beyond 2021, local authorities should work
to the assumption that the figures should be rolled forward. When
taking completions in to account this amounts to a reduction of
770 dwellings in total.
- Three Rivers District Council—500 dwellings—Consultation
has just closed on "Changes to the Core Strategy Proposed
Submission document" (October 2010). This document set
out a reduction in the housing target of 500 dwellings from the
RSS, now that the Council knew that the RSS was to be withdrawn.
3.5 This amounts to a total 22,848 dwellings
from official estimates. All directly influenced by the decision
to abolish RSS.
Unofficial Estimates
3.6 The telephone survey and unofficial estimates
uncovered a further reduction of 10,100 dwellings. A further
three authorities were likely to reduce housing targets, but it
was not possible to accurately estimate by how much this would
be. In total, our research highlighted that unofficially 10 of
the 47 authorities were likely to reduce their housing targets
in the next 12 months.
Summary
3.7 This amounts to a total reduction of 32,948
dwellings from housing targets in the East of England.
THE SOUTH
EAST
Official Announcements
3.8 The official announcements on the South East
are listed below. These are:
- Bracknell Forest—2,000 dwellings—The
Council has announced it is reverting to its Core Strategy figure
which was adopted in 2006. This is 2,000 dwellings less than the
adopted RSS figure.
- Eastleigh Borough Council—6,000 dwellings—Plans
for a 6,000 dwelling "Strategic Development Area" at
Hedge End will no longer be progressed.
- Test Valley Borough Council—300 dwellings—The
Council has reduced its overall target by 300 dwellings as an
interim measure.
- South Oxfordshire Council—400 dwellings—The
Council has announced that it will limit development at Wallingford
to 350 dwellings, down from 750 dwellings.
- Horsham District Council—6,888 dwellings—The
Council has reverted to its adopted Core Strategy position of
439 dpa to 2018. The adopted RSS set a target of 650 dpa to 2026.
The Council will now continue to review its Core Strategy but
there is no indication that the new figure will be any higher
than the target in the adopted Core Strategy.
- Milton Keynes Council—6,145 dwellings—Milton
Keynes announced in its Core Strategy consultation document that
it was reducing its housing target now that it no longer needs
to comply with the RSS figure.
- Portsmouth City Council—3,568 dwellings—Consultation
on the Core Strategy began in November 2010. This included a range
of new housing targets for the city. Even the highest figure from
this range would still amount to a reduction in planned homes
from the South East Plan of 3,568. The consultation began after
the CALA Homes decision, however the Council stated that it was
able to set a lower target based on Government plans to withdraw
the RSS.
- Chiltern District Council—500 dwellings—Chiltern
released its Pre-Submission version of the Core Strategy for consultation
on 14 October 2010, reducing the housing target by 500 dwellings
from the figure set out in the RSS.
- Wealden District Council—3,000 dwellings—Wealden's
Draft Proposed Submission Core Strategy was approved at Full
Council. Prior to the revocation of the RSS by the Secretary of
State in July, Wealden had been about to publish a Core Strategy
document with the RSS target of 11,000 dwellings. Given flexibility
over housing targets, it has chosen to reduce the housing target
to 9,600 dwellings between 2006 and 2030. The South East Plan
runs to 2026, so when the timeframes are directly compared this
amounts to a reduction of 3,000 dwellings.
- Fareham Borough Council—3,250 dwellings—The
Council has announced plans to reduce the North of Fareham Strategic
Development Area to at least 6,750 dwellings. Although a second
round of consultation has now begun on whether this level of development
is acceptable. The South East Plan had proposed a target a total
of 10,000 new homes in this new settlement.
- Mid Sussex District Council—2,425 dwellings—The
Council passed a resolution on 17 November 2010 that a housing
target of 370 dwellings per year was "the most realistic
and robust requirement against which to show a five-year housing
land supply". The South East Plan target was 855 homes
per annum. This move was taken despite the reinstatement of the
RSS on the grounds that the RSS would be abolished eventually.
- Surrey Heath District Council—594 dwellings—Following
the Secretary of State's decision to revoke the RSS on 6 July
2010, the Council decided to reduce its housing target in the
Surrey Heath Core Strategy and Development Policies DPD
(July 2010). This document has now been submitted to the Secretary
of State for examination. The lower target remains despite the
reinstatement of the RSS.
- Aylesbury Vale District Council—14,190
dwellings—The reinstatement of the RSS gives
rise to a difficulties in classifying the situation at Aylesbury
as official or unofficial. We have placed it in the official category
as all the information is in the public domain. Following the
revocation of the RSS on 6 July 2010, the Council withdrew its
Core Strategy on 5 October 2010. This had been submitted for examination
to the Secretary of State. The Council released a statement announcing
that it did not support the RSS housing target and that although
it did not have a new 'official' target, it now intended to plan
for housing only arising from needs originating within Aylesbury
Vale and not to accommodate growth relating to Milton Keynes.
Officers suggested current ONS information was the best guide
to this and produced a paper for members. Within this report it
stated that by looking at 'natural growth' only 12,700 dwellings
were required up to 2026, 14,190 dwellings less than the RSS figure
of 26,890 dwellings.
With the reinstatement of the RSS on 10 November
2010, the Council now accepts that the original housing targets
have been re-established. However, in a Cabinet Report a timetable
is established to produce a new Core Strategy to plan for a 'natural'
level of housing growth. Therefore, our estimated housing target
reduction for Aylesbury Vale is still considered valid.
3.9 This amounts to a total 49,260 dwellings
from official estimates.
Unofficial Estimates
3.10 The research uncovered unofficial estimates
of 7,360 dwellings to be reduced from housing targets across
the South East. In total 8 more of the 67 local authorities surveyed
are likely to reduce housing targets in the next year.
Summary
3.11 This amounts to a reduction of 56,620
dwellings from housing targets in the South East of England.
YORKSHIRE AND
HUMBER
Official announcements
- Leeds City Council—10,200 dwellings—The
Executive Board of the City Council have approved a reduction
of the housing target to 2,260 dwellings per annum (net) from
4,300 dwellings per annum (net). However, this is an interim measure
and cannot be considered to be a permanent reduction in the Council's
housing target over the 20 year period. We have therefore calculated
the above figure based on a 25% reduction over 20 years or using
this reduction over a five year period.
A number of appeals and applications are extremely
likely to be dismissed and refused respectively as a result of
the reduced housing target. There are three appeals on greenfield
sites being fought on housing land supply grounds already. However,
these are not included in the following sections as it would amount
to double counting.
- Craven District Council—330 dwellings—Craven
has set an interim five year housing target of 184 dwellings per
annum, down from 250 in the RSS. Over five years this amounts
to 330 dwellings.
WEST MIDLANDS
Official Announcements
- Staffordshire Moorlands—500 dwellings—The
Council is about to launch a consultation document at the start
of 2011 on their preferred option figure of 5,500 dwellings. This
is 500 dwellings lower than the RSS figure.
Unofficial Estimates
3.12 Additional research has also uncovered a
further 1,900 dwellings to be reduced from housing targets
from unofficial sources.
EAST MIDLANDS
Official Announcements
- Northampton/Daventry/South Northamptonshire Councils—12,125
dwellings—West Northamptonshire Development Corporation
is made up of parts of Northampton Borough Council, Daventry District
Council and South Northamptonshire Council. The Joint Planning
Unit oversees planning policy for this growth area. On 2 November
2010, they issued a press release stating that:
"Following the Government's revocation of
RSS and the consequent removal of the housing targets....
the previous Regional target of 62,125 homes
to be built in West Northamptonshire between 2001-2026 will be
replaced with lower figure of around 50,000 homes."
DELAYED OR
REFUSED PLANNING
APPLICATIONS AND
APPEALS
3.13 Over the course of the research, a number
of planning applications were affected by the release of the letter.
These are set out below:
- Application for 2,000 homes at Barton
Farm, Winchester by CALA Homes was refused, citing the Eric Pickles
letter as a principal reason for refusal. This has led to the
successful legal challenge by CALA Homes in November 2010. A planning
appeal remains pending.
- An application for 1,200 dwellings was
refused for a site at Newmarket within the Forest Heath District.
The site fell within an area of search within the Core Strategy,
but had not yet been allocated. The scheme was refused citing
the Eric Pickles letter.
- An application for 300 dwellings Cotswold
District was refused, citing the Eric Pickles letter as one of
the reasons for refusal.
- An application for 280 homes at Emsworth
in Havant Borough Council has been delayed. The Eric Pickles letter
has been cited as part of the reason for delaying a decision.
- A planning appeal has been withdrawn for 350
homes on the edge of Tewkesbury. The appellants acknowledged
that the abolition of the RSS would undermine their arguments
on housing supply.
3.14 Two appeals have been dismissed in Cornwall
by the Secretary of State. The Inspector recommended that the
appeals were allowed, however the Secretary of State overruled
them on both occasions. He stated that following the revocation
of the RSS, Cornwall Council should be allowed to set its own
housing target. These were:
- Land at Binhamy Farm, Stratton Road, Bude—APP/D0840/A/09/2115945—450
dwellings.
- Land at Calenick Farm, Lamorran Farm and Higher
Newham Farm, Truro APP/D0840/A/09/2109056—1,050
dwellings.
3.15 The total number of dwellings which have
not been approved due to either delays, refusals or dismissed
appeals citing the intention to abolish RSS is therefore estimated
as at least 5,630 dwellings. By way of additional example,
three applications have been deferred in Cherwell District due
to the Pickles letter. Decisions are expected shortly, but no
reduction has been included as a formal decision has not yet been
made over the applications.
3.16 Furthermore, there are likely to be numerous
other examples of landowners and house builders deciding not to
proceed with appeals because of the uncertain policy climate they
are currently faced with.
SECTION 4—CONCLUSIONS
4.1 This report summarises our research on the
impact of the Coalition Government's intended revocation of RSS.
4.2 The original research, principally conducted
by telephone interviews, identified the initial impact of the
Eric Pickles letter to Council Leaders of 27 May 2010 on planning
applications and housing targets in emerging Core Strategies across
three regions. The follow up research has been wider in scope
and has identified both further reductions and further example
Core Strategies and planning decisions across the whole of England.
4.3 There are considerable regional differences
but our current estimates of the overall reductions in housing
targets can be summarised as below.
- Official announcements brought about either directly
or indirectly by the intended revocation of the RSS—171,169
dwellings.
- Unofficial announcements/estimates—24,710
dwellings.
- The delay and refusal of applications—5,630
dwellings.
4.4 This is a total of around 201,509 dwellings.
The vast majority (88%) of these estimated reductions have been
derived from official local authority sources which are in the
public domain.
4.5 It can be expected that this figure will
rise further. It is conservatively estimated that another 30 of
the 152 local authorities originally surveyed will ultimately
decide to reduce their local housing figures from the RSS baseline.
Furthermore there is increasing evidence of other authorities
outside the three regions principally surveyed making cuts also.
January 2011
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