I wondered if anyone had looked at this new methodology and in
particular the addition of step 4 to the calculation, namely the
uplift of 35% on housing need to those areas which are the largest
cities/urban areas by population?
I am struggling to see how this can in any way be classed as a robust
assessment of 'housing need'. The assessment of housing need,
generally one of the first things you do in plan making, is a
'policy-off' calculation of what your housing need is, usually
considering things like population, migration, household formation
etc. You then work out what you are actually going to plan for by
setting a housing requirement in your plan, after considering other
matters including constraints.
Under the current system this includes the Duty to Co-operate and
consideration of meeting needs in other authority areas if they cannot
be met in the area of need.
However, this new methodology is clearly 'policy-on'. Government has
set out that the purpose of the new methodology is to direct housing
into certain areas. Basically, the cities, irrespective of where
actual need is. The 35% is, like many numbers we are given
by Government, random and arbitrary. Where does it come from? But more
importantly and fundamentally, I do not see how this can derive a
true, robust assessment of housing need for an area as the first stage
of plan making.
Most cities already have significant needs just by considering
population growth, without adding in 35%.
This change to the standard method has come about due to serious
concerns on impacts for areas not being able to accommodate growth
under the previous methodology (also known as the mutant
algorithm) which was proposed along with the publication of the
Planning White Paper. So where is the opportunity to respond to this
latest (December 2020) methodology?
has any0one else got into considering this yet, particularly from any
of the 20 affected 35% areas?
Cheers
Jon
