Re: Taking account of backlog/under delivery when determining new local pla - Public forum - Planning Advisory Service (PAS)

Carolyn, Hi. At Bradford we will shortly be looking at calculating the overall requirement for housing over the Core Strategy period which in our case will run to 2029. The Yorkshire and Humber Spatial Strategy has literally just been revoked so we no longer have the RSS housing target in place. The RSS covered the period 2004 -2026 with a housing target of 1560 per annum for the period 2004 to 2008 and 2700 per annum over the period 2008-2026. Over the period 2004 to 2012 there has been a significant, a very significant shortfall in delivery against these targets in part of course due to the state of the economy and housing markets. We have no data or evidence to suggest that the previous RSS targets were unsound - although subsequent releases of the official population and household projections have waxed and waned the RSS figures look to have been reasonable estimates of need. We now have an idependently produced housing requirement study in place which I am happy provides a robust look at future need, but this study does not look backwards or address issues of meeting previous under supply. Your post is therefore opportune - I am working on the assumption that even though the RSS is no longer in place, the only way to show that the Council is planning positively i.e. in line with the NPPF is to seek to make up the undelivered RSS related shortfall by adding the deficit to our new target in the Core Strategy. I am therefore interested to see how others are addressing this issue. In our Yorkshire and Humber Region there seem to be inconsistsent approaches and without wanting to sound too crtiical I feell some are trying to conveniently re-set the clock to year zero, ignore previously unmet need, and basing this on realtively flimsy argument and evidence. In addtion to hearing other people's perspective's I would be grateful if someone from PAS / this website could indicate whether there is any written record of the PINs advice given at the roadshow to which Carolyn refers. The reason it woukld be useful is put simply we may have problems convincing members to plan for previous unmet need based on now revoked RSS targets unless there is something written down to indicate that this is the correct approach.

Simon, I'm prepared to air my ignorance on this subject in hope that I can also get some clarity. If you have carried out an up-to-date and robust SHMA, then I would presume that this provides you with a figure of need from the date of the SHMA, forwards. Therefore, you can presumably set the clock to 'year zero' as you can demonstrate that you have an understanding of need in the area, borne out by up-to-date evidence. There can't be any other need hiding away somewhere if it isn't shown in the SHMA, can there? In other words, what the new SHMA tells you, will take account of any previously unmet need. If you don't have an up-to-date SHMA, then you will have to be looking at past under-delivery and build that in to your need for the next 5 years (if we assume the 'Sedgefield' method is preferred over the 'residual' one), until you have updated your SHMA. This is an acceptable (and accepted) proxy in the absence of more up to date information. The point is, you have to demonstrate you are planning to meet objectively assessed needs in your area. Up-to-date evidence will provide you with a robust figure you have to plan for. In the absence of up-to-date evidence, the only proxy you have is to build in under-delivery from the current plan period. It is absolutely not appropriate to re-set the clock on flimsy arguments and evidence. It is entirely appropriate to do so with robust and up-to-date evidence. This is another area that highlights the importance of monitoring. This seems so obvious to me that I must be wrong. I look forward to being put right by someone (or lots of someones).

Regarding the issue of whether there is a note of the PINS advice given at the roadshow I have checked with PAS and they have confirmed that there are no formal notes of the roadshow sessions. PAS are however working to produce something on the topic of determining housing requirements which should be published shortly. The revised SHMA guidance should also in due course shed further light on this topic although as far as I am aware there is as yet no indication when this might be published. I agree with Adam Dodgshon that for the time being the best way to address this issue is to focus on producing an evidence base which is robust and up to date. If anyone knows of good examples of methodologies for determining housing requirements which have been endorsed through the examination process or are going through the examination process I would be interested to hear from you.

Carolyn At West Lancs, we've just finished our Local Plan Examination Hearings. We discussed housing requirements at the first hearing session. WLBC proposed to base the Local Plan housing requirement upon the most recent published household projections (2008-based), and to add on to that the deficit in housing completions compared with the RSS from 2003 (RSS base date) to 2012 (Local Plan base date), which we called 'the RSS deficit'. This approach seems to tie in with Adam's third paragraph above (although we went for a phased, rather than Sedgefield, approach - a whole separate discussion!) As part of our evidence base, we published a housing technical paper setting out our reasoning behind our proposed housing requirement. On the specific matter of taking into account any past backlog in housing delivery, the technical paper highlighted two "schools of thought", one saying that household projections take into account failure to meet past needs, the other saying they do not. The following extract from the Technical Paper sets out the second "school of thought": "… A failure to meet housing need results in households not forming at ‘natural’ or ‘expected’ rates due to a lack of suitable accommodation, or affordability issues (for example a grown-up ‘dependent’ not being able to afford a property of his / her own at age 20-30+, and staying with parents longer than desired). As such households do not end up forming, they are not detected or measured in the ‘trends’ which influence the household projections, and therefore the household projections do not reflect the real-life housing need. The failure to meet housing needs results in a ‘pent-up demand’ for housing, which should be measured or estimated, and added on to household projections. Informal advice on this matter given by the Department for Communities and Local Government … states the following: 'The net change in household numbers in the projections series will not explicitly reflect any backlog of demand. … In terms of assessing housing need … you will need to include a separate assessment of the backlog of need in your area to add to the net change in households shown in the projections data.' " (We used the 'RSS deficit' as an estimate of the backlog of need.) Participants in the examination process generally agreed that it was correct to add the "RSS deficit" to our base housing requirement. The main source of disagreement was whether the 'base element' of our housing requirement should be the 2008-based household projections, or the RSS requirement. Given the hearings sessions only finished yesterday, it will be some time before we know whether our proposed housing requirements have been endorsed or not.