Eden Local Plan: Interim Consultation (March 2017)...Email: [email protected] Date:...

Eden Local Plan: Interim Consultation (March 2017)

Representations on Behalf of Story Homes

April 2017

Eden Local Plan: Interim Consultation (March 2017)

Representations on behalf of Story Homes

Project Ref: 23955/A3/LD/DM 23955/A3/LD/DM 23955/A3/LD/DM

Status: Draft Draft Final

Issue/Rev: 01 02 03

Date: 28 March 2017 3 April 2017 10 April 2017

Prepared by: LD LD LD

Checked by: - DM DM

Barton Willmore LLP

Tower 12, 18/22 Bridge St,

Spinningfields, Manchester

M3 3BZ

Tel: 0161 817 4900 Ref: 23955/A3/LD/DM

Email: [email protected] Date: April 2017

COPYRIGHT

The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore LLP.

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mailto:[email protected]

CONTENTS

Page

1. INTRODUCTION & EIP PROGRESS TO DATE 2

2. OBJECTIVELY ASSESSED HOUSING NEEDS – REVISED POSITION STATEMENT 3

3. PENRITH – HOUSING DISTRIBUTION AND SITES 9

4. ALSTON – HOUSING DISTRIBUTION AND SITES 13

5. APPLEBY– HOUSING DISTRIBUTION AND SITES 14

6. KIRKBY STEPHEN - HOUSING DISTRIBUTION AND SITES 16

7. KEY HUBS – HOUSING DISTRIBUTION AND SITES 17

8. CONCLUSIONS 22

Appendices

Appendix 1: OAN Overview (August 2016)

Appendix 2: Key Hubs Allocations Site Assessment (Story Homes)

Introduction and EIP Progress to date

1. INTRODUCTION & EIP PROGRESS TO DATE

1.1 On behalf of our Client, Story Homes, we wish to set out our response in relation to

the Eden Local Plan – Interim Consultation.

1.2 Story Homes is the leading housebuilder within Cumbria and have been heavily

involved in the Local Plan process since 2014, with representations submitted to the

Preferred Options (September 2014); Settlement Hierarchy and Land Availability

Assessment (August 2015); and Submission Version (November 2015).

1.3 Examination Hearing Statements were submitted by Barton Willmore on behalf of Story

Homes in April 2016 and we participated within the various Hearing Sessions held in

May 2016; July 2016; and September 2016.

1.4 Throughout the Local Plan process and Hearing Sessions, Story Homes identified

concerns with the Submission Local Plan as drafted, which they do not consider have

been satisfactorily addressed. This remains the case. They do not consider that the

emerging Local Plan is robust or sound nor does it not meet in full the District ’s

housing needs as set out in the NPPF or PPG in relation to full objectively assessed

needs.

1.5 This Report sets out our Client’s response to the issues identified by the Inspector in

relation to the following papers:

• OAN - Revised Position Statement;

• Penrith – Housing Distribution and Sites;

• Alston - Housing Distribution and Sites;

• Appleby - Housing Distribution and Sites;

• Kirkby Stephen - Housing Distribution and Sites; and

• Key Hubs - Housing Distribution and Sites

1.6 It should be noted that our Client continues to maintain an objection to the evidence

base and methodology underpinning the emerging Local Plan.

OAN – Revised Position Statement

2. OBJECTIVELY ASSESSED HOUSING NEEDS – REVISED POSITION

STATEMENT

2.1 Story Homes acknowledges and welcomes the acceptance by the Council of the need

to review their existing position in relation to full objectively assessed needs (“OAN”)

and the proposed uplift to increase the OAN from 200 dpa to 242 dwellings per annum

(“dpa”).

2.2 Notwithstanding this, Story Homes do not support the methodology undertaken by the

Council nor do they consider that it sufficiently addresses the concerns identified in

relation to the OAN within our previous representations. We set out below a number

of comments in relation to the Council’s current position:

• Migration Trends – Within Barton Willmore’s comparative response to the OAN and

the Council’s OAN position, there are differences between the approaches used in

terms of applied mitigation trends. Clarification is required.

• Household Formation Rates – The Council has not reviewed their position in terms

of uplift to 2014 based Housing Formation Rates. They have relied and based their

assumptions on work undertaken by Barton Willmore. It is our view that Cumbria

County Council should be able to provide the Council with this information and

work should be undertaken to ensure that the Council ’s evidence base is robust

and up-to-date. A lack of time and resourcing is not a valid reason why this work

has not been undertaken.

• Market Signals – We consider that the Council should rely on the most up to date

data on affordability ratio for median property princes, and consider that a 20%

uplift is required under the LPEG methodology.

• Revised OAN – Clarification is required from the Council as to how an uplift of 26

dpa has been added to the jobs-led figure to take account of the differences

between the 5 and 10-year migration scenarios.

2.3 In addition to the above, we refer the Council and Inspector to the previous Position

Statement (August 2016) in relation to OAN. It remains Story Homes’ view that the

full OAN for Eden is between 277 – 289 dpa. That evidence remains relevant and it is

Story Homes position that the Council’s alternative model does not reflect the full


OAN. We therefore respectively ask the Inspector to consider the evidence set out in

the Position Statement (August 2016) (Appendix 1).

2.4 We would also reiterate the comments set out within the HBF response to the Interim

Consultation.

Overall Supply Position

2.5 Story Homes is concerned with the overall approach which has been taken by the

Council and its failure to allocate sufficient land to meet the proposed housing

requirement of the Borough.

2.6 The overall housing land supply position is still unknown. The Council continues to

rely on Neighbourhood Plans and windfall to deliver housing within the Borough, in

addition to extant permissions and sites under construction, which have historically

under-delivered or have stalled. It is Story Homes’ position that further land release

through allocations is the most appropriate way of delivering the housing requirements

of the District.

2.7 It is our Client’s position that the Council has failed to provide a sufficient level of

buffer within their own proposed housing requirement of 242 dpa. If the Inspector is

minded to proceed with a housing requirement of 242 dpa, a suitable buffer must be

applied to the housing requirement to ensure that a minimum of 242 dpa is delivered.

This will enable the delivery of a greater choice of sites, and boost housing delivery

and market choice in accordance with Paragraph 49 of the NPPF, and allows for a

contingency if sites fail to come forward.

Housing Land Supply

2.8 It is Story Homes’ consideration that insufficient land has been allocated to meet the

housing land supply requirement within the District over the Plan period. The Council

continues to rely on Neighbourhood Plans and Windfall sites to meet the supply, and

the strategy appears to be based on allocating the minimum level of land possible.

This is not a sound approach to development.

2.9 It is our Client’s view that the Council has failed to make any allowance or slippage of

commitments or allocations. It is our Client’s view that if a slippage rate of 10% is

assumed, the provision of a 20% buffer will allow for a 10% cushion to the overall

figure, in the event of further slippage. It is therefore our Client’s position that a 20%


buffer should be applied to the overall housing requirement to ensure that the

minimum housing targets are met.

2.10 Tables 1 and 2 show the housing land distribution based on the Council’s requirement

of 242 dpa, and our Client’s minimum requirement of 277 dpa, utilising a 20% buffer.

EDC’s Position 242 dpa

Housing

Requirement

Distribution

(%)

20% buffer

applied

Completions u/c & Extant

permissions

Residual

Requirement

Target 4,356 100 5,227

TOWNS

Penrith 2,178 50 2,614 167 324 2,123

Alston 131 3 157 2 62 93

Appleby 392 9 470 36 145 289

Kirkby

Stephen

348 8 418 21 48 349

Total Towns 3,049 70 3,659 226 579 2,854

RURAL AREAS

Key Hubs 871 20 1,045 109 260 676

Villages &

Hamlets

436 10 523 36 471 16

Total Rural 1,307 30 1568 145 731 692

Total 4,356 100 5,227 371 1,310 3,546

Table 1 – Residual Requirement based on Council’s requirement of 242 dpa

BW’s Position 277 dpa

Housing

Requirement

Distribution

(%)

20% buffer

applied

Completions u/c & Extant

permissions

Residual

Requirement

Target 4,986 100 5,983

TOWNS

Penrith 2,493 50 2,992 167 324 2,501

Alston 150 3 179 2 62 115

Appleby 449 9 538 36 145 357

Kirkby

Stephen

399 8 479 21 48 410

Total Towns 3,491 70 4,183 226 579 3,383

RURAL AREAS

Key Hubs 998 20 1,197 109 260 828

Villages &

Hamlets

495 10 598 36 471 91

Total Rural 1,485 30 1,795 145 731 919

Total 4,950 100 5,983 371 1,310 4,302


Table 2 – Residual Requirement based on Council’s requirement of 277 dpa

2.11 This demonstrates there is a need to identify additional housing land to meet the

requirements both overall and within the main towns and Key Hubs.

Housing Supply Composition

2.12 Notwithstanding the above, we have a number of comments in relation to the Council’s

overall table showing the proposed housing distribution within the OAN Statement as

outlined below:

• The level of commitments and completions for Key Hubs is different between the

Table in Paragraph 5.25 of the Key Hubs Paper and the Table on Page 19 of the

OAN Paper. The table below, shows a comparison of these different figures.

Clarification is required.

OAN Commitments Completions Residual Requirement

Key Hubs

Paper

871 259 84 267

OAN Paper 871 260 109 502

Table 3 – Comparison between OAN and Key Hubs Paper

• As identified within the above table, the residual requirement within the Key Hubs

Paper and OAN Paper is different, with the residual requirement within the OAN

Paper substantially higher.

• The evidence base used by the Council to calculate existing commitments and

completions is not up-to-date (base date April 2015). This needs to be updated.

• There are variations in the figures proposed by the Council within each Settlement

Paper in respect of the site capacities, compared to the SHLAA i.e. 234 dwellings

across the Key Hubs, however, when the sites are assessed against the Council’s

previous assessment within the SHLAA, only 192 dwellings are identified as

capable of being accommodated, a further shortfall of 42 dwellings.

• The Council has identified a number of sites within Culgaith, Lazonby and

Langwathby which could be made available if required to meet further housing

needs.

• No information is available in relation to delivery rates in Villages and Hamlets,

other than in the OAN table.

• A 30% windfall allowance for Key Hubs is too high based on past delivery within

Eden.


• The Council should allocate the land it needs to deliver rather than relying on

windfall which is not evidence based.

• The Council has rolled forward allocations from the 1996 Local Plan. This is no t a

viable approach, because some of the sites have failed to come forward in over

20 years and are considered undeliverable.

• The Council is reliant on windfall sites, however, a number of these sites have

been under-construction, or permitted for a number of years.

• Site capacity should not be treated as a maximum figure, rather it should be a

minimum.

• The overall supply is unknown because the Council is continuing to rely on

Neighbourhood Plans and windfall.

Contingency Method

2.13 It is Story Homes’ position that in relation to housing supply, a contingency plan is

required, to ensure that the Local Plan remains effective and flexible during a range

of economic conditions, in relation to housing supply. This include a range of options

and possible actions to ensure the Plan delivers the minimum housing requirement.

This could include the release of Future Growth Land or an early review of the Local

Plan. The Council has accepted that a higher requirement is needed, however, without

further land release this need cannot be met. Completions and housing allocations

need to be carefully monitored to identity any non-delivery trends.

2.14 We refer the Council and Inspector to the recently published White Paper . This clearly

sets out in Paragraph 2.49 Bullet Point 1, the Government’s approach to the delivery

of housing. If it falls below 95% of the annual requirement the Council will be required

to publish an action plan, setting out its understanding of the key reasons for this

situation and how it will be addressed. If it drops further, they will be required to

release further housing land.

Summary

2.15 The lack of adequate buffer means that further land should be allocated within the

Plan. The Plan as drafted has no contingency plan, therefore effectiveness and

flexibility of the Plan is questionable. The Council should consider contingency

measures and mechanisms to release further land for development if required (e.g.

Future Growth Land or Action Plan (as proposed in the Housing White Paper)), or in


a worst case scenario, what level of undersupply would trigger an early review of the

Local Plan.

Penrith – Housing Distribution and Sites

3. PENRITH – HOUSING DISTRIBUTION AND SITES

Housing Requirement with Penrith

3.1 The Penrith Housing Distribution Paper seeks to reflect the Council’s proposed latest

OAN position of 242 dpa, with 50% of this growth required to be delivered within

Penrith. This equates to 2,178 dwellings.

3.2 The amended wording for Policy PEN1 states that the Council is only required to deliver

a minimum of 1,687 dwellings over the Plan period. This is the residual requirement

only, rather than the overall requirement. This approach by the Council is incorrect.

3.3 To meet the identified requirement of 1,687, the Council has included a number of

additional sites for allocation and revised the capacity in others. The Penrith Housing

Distribution paper (Table within Paragraph 7.2) states that the proposed sites are

capable of accommodating 1,715 dwellings. When compared to the Council’s identified

residual requirement of 1,687 dwellings, this equates to an oversupply of only 28

dwellings.

3.4 It is our Client’s position that this is insufficient, because it does not account for any

slippage or non-delivery of sites. A suitable buffer is therefore required in the event

of non-delivery and further land release is needed within Penrith.

3.5 It is also Story Homes position that Policies LS2 and PEN1 should be reworded, to

ensure they reflect the overall requirement of 2,178 dwellings (as a minimum if the

Inspector is minded to approve the 242 dpa figure proposed by the Council ) rather

than the residual requirement of 1,686 dwellings, to reflect the overall housing

requirement within Penrith over the Plan period. We refer the Council and Inspector

to our previous representations in relation to Policies PEN1 and LS2 accordingly,

because these policies should be consistent with the housing requirement of Penrith.

3.6 We request that the Council provides an up-to-date position of the Council’s latest

completions, dwellings under-construction and sites with extant permission. Whilst it

is noted that these have been provided, they are reliant on an evidence base of April

2015, and there are inconsistencies between the various consultation documents in

terms of the number of completions etc.


3.7 As identified within Section 2 of this Statement, we have undertaken a comparison of

the Council and our Client’s respective housing requirements based on the requirement

of 242 dpa and 277 dpa, when applying a 20% buffer.

Residual requirement Allocations Difference

242 dpa 2,123 1,715 408

277 dpa 2,501 1,715 786

Table 4 – Residual requirement comparison – Penrith

3.8 As shown in the above table, there is a clear need to release additional land within

Penrith to meet the above requirements.

Future Growth Land

3.9 No justification has been provided by the Council for the inclusion of sites as “Future

Growth Land”, nor has any guidance or policy release mechanism been provided as to

when these sites will be released. Clarification is required as to the role of a “Future

Growth” sites and what the Council’s future intention of these sites are. It is noted

that the Council has also previously used the term “reserve land”. Clarification in terms

of the differences between these terms is required.

3.10 It is our Client’s view that sufficient land should be allocated at the outset to ensure

the minimum housing requirement and buffer is met in the first instance. A release

mechanism setting out how any land designed as “Future Growth Land” will be

released is required and could form part of the Council’s contingency plan.

Site Specific Comments

3.11 We set out below our site-specific comments in response to the proposed allocations

within Penrith below.

Site N1A – Salkeld Road/Fairhill Greenfield Extension (Phase 2)

3.12 The site is included within the Submission Draft Local Plan as a “Reserved Site” and it

is now proposed for release as a potential allocation. Story Homes supports the release

of the site. We refer both the Council and Inspector to our previous comments

submitted in relation to this site in November 2015 in response to the Submission

Draft Local Plan.

3.13 We maintain our position that the site should be allocated because it is deliverable

within the Plan period and will help the Council achieve its housing needs. The site is


well related to Penrith and is within one single ownership and is deliverable. It forms

a logical extension to Story Homes’ existing site (N1) which benefits from existing

planning permission (and works have commenced on-site). The site is considered to

be suitable, available and achievable and capable of accommodating circa 350

dwellings, significantly more than the 250 dwellings identified by the Council.

3.14 It is further noted that it is the Council’s intention to release only part of the Site, and

for the remainder of the Site to be allocated as an area of “Future Growth” (please

see our previous comments in relation to this in paragraph 3.7). The entire site should

be released for residential development at the outset of the Plan.

Site N2 – White Ox Farm

3.15 Story Homes supports the proposed retention of this site within the emerging Local

Plan and the reduction in the developable site area.

Site P94 – QEGS Annexe

3.16 No comment.

Site N3 – Raiselands

3.17 Story Homes supports the proposed increase in capacity of the site for 230 dwellings.

We offer no further comments in relation to this allocation.

Site PS4 -Bellevue Farm, Salkeld Road

3.18 Story Homes supports the allocation of this site. We offer no further comments in

relation to this allocation.

Site P108 – Land at Green Lane

3.19 No comment.

Site E1 - Land Adjoining/to the north of E1 (Carleton)

3.20 Story Homes supports the allocation of this site, and considers it to be suitable,

available and deliverable within the Plan Period.

Summary

3.21 It is our Client’s position that further land release is required to be allocated within

Penrith. We consider that the Sites identified should be released, but that further land

is release is required, and the most appropriate sites would be those identified as

“Future Growth Land”.


3.22 No justification has been provided by the Council in relation to what is meant by a

“Future Growth land” or what mechanism is involved in its release.

Alston – Housing Distribution and Sites

4. ALSTON – HOUSING DISTRIBUTION AND SITES

4.1 Our Client does not support the continued inclusion of Alston as a “Market Town”. We

refer the Council and Inspector to our previous representations made to the

Submission Version, Settlement Hierarchy and Hearing Statements.

4.2 Policy AL1 of the Submission Draft Local P lan identifies land for 86 new homes within

Alston. However, the Council acknowledges within their assessment that delivery rates

within Alston are slow (Table 4.1) and in single figures per annum. There is limited

market demand for new housing within the settlement. It is also recognised within the

Alston Housing Distribution Paper that any increase in the number of houses to be

delivered within Alston would be extremely challenging and it therefore seeks to

reduce the number of dwellings proposed to 67 dwellings and reduce the distribution

target from 4% to 3%. This approach is concerning, and reiterates Story Homes ’ view

that Alston is not an appropriate location for growth, and no sound evidence has been

provided to justify this.

4.3 Of these dwellings, 62 dwellings are already “under-construction” or permitted, but

there are limited completions within the settlement, amounting to a mismatch in the

development strategy. The amount of growth within the settlement is therefore

limited.





242 dpa 93 67 26

277 dpa 115 67 48

Table 5 – Residual requirement comparison – Alston

4.5 As shown in the above table, there is a clear need to release additional land to meet

the above requirements.

4.6 Story Homes does not wish to make any further comments in relation to the proposed

allocations within Alston, but refer the Council and Inspector to our previous

representations within the Submission Version, Settlement Hierarchy and Hearing

Statement that Alston should not be a designated Market Town.

Appleby - Housing Distribution and Sites

5. APPLEBY– HOUSING DISTRIBUTION AND SITES

5.1 Appleby is designated as a Market Town within the emerging Local Plan and Story

Homes supports this. The Submission Plan proposed the delivery of a minimum of 155

new homes within Appleby, and the revised distribution strategy proposes an increase

in the residual requirement to 68 dwellings.





242 dpa 289 214 75

277 dpa 357 214 143

Table 6– Residual requirement comparison – Appleby

5.3 As shown in the above table, there is a clear need to release additional land to meet

the above requirements.

5.4 We set out our comments in response to the revised allocations below:

Site AP10 – Land to the south of Station Road

5.5 No comment.

Site AP11 – Fields Adjacent to the Cold Yard

5.6 The Council considers that the Site is suitable for release, and is capable of

accommodating 39 dwellings across the Plan period. Story Homes is supportive in

principle of this proposed allocation; however, it is their view that this should be a

minimum housing figure, rather than a maximum figure which may be permitted on-

site, particularly as the Submission Version identified that the Site is capable of

accommodating 90 dwellings. The Noise Report which accompanies the Appleby

Housing Distribution Paper is clear that any assessment would need to take account

at detailed design stage of the application, and there are various options as part of

the design process to mitigate any impact.

5.7 The Council identified within the LAA that the Site is suitable, available and achievable

and considered to be developable. Our Client support the inclusion of this Site as an

Appleby - Housing Distribution and Sites

allocation, on the basis that it is suitable for development because it forms a natural

extension to the settlement and is located close to local services and bounded by the

railway line and any identified constraints can be overcome.

5.8 The Site is therefore considered to be suitable, available and deliverable in the short

term (0 -5 years) and should be included as an allocation.

Site AP16 – Land behind Cross Croft

5.9 Story Homes supports the proposed allocation of the Site for 115 dwellings. It is our

Client’s view that the Site is suitable, available and deliverable and capable of

accommodating the number of dwellings identified by the Council. There is no reason

why the Site should not be allocated within the emerging Local Plan.

Site AP24 – Land at Westmorland Road

5.10 No comment.

Summary

5.11 We support the inclusion of Appleby as a Market Town and consider that it is capable

of accommodating the minimum level of development proposed.

Kirkby Stephen - Housing Distribution and Sites

6. KIRKBY STEPHEN - HOUSING DISTRIBUTION AND SITES

6.1 Kirkby Stephen is designated as a Market Town within the emerging Local Plan and

Story Homes supports this. The Submission Plan proposed the delivery of 252 new

homes within Kirkby Stephen, and the revised distribution strategy proposes an

increase in the minimum residual requirement to 348 dwellings. This increase takes

account of the increase in the proposed OAN figure to 242 dpa, and the additional 1%

requirement taken from Alston.





242 dpa 349 281 32

277 dpa 410 281 129

Table 7 – Residual requirement comparison – Kirkby Stephen

6.3 As shown in the above table, there is a need for additional land to meet the above

requirements.

6.4 We refer the Council and Inspector to our comments in Paragraphs 3.9 and 3.10 in

relation to “Future Housing Land”. Our comments within these paragraphs are

applicable to Kirkby Stephen, because “Future Housing Land” has been allocated here.

6.5 Story Homes have no further comments in relation to the revised distribution strategy

for Kirkby Stephen or any of the proposed allocations.

Key Hubs - Housing Distribution and Sites

7. KEY HUBS – HOUSING DISTRIBUTION AND SITES

7.1 Following the initial Hearing Sessions in May 2016 and the Inspector’s

recommendations, the Council has sought to reduce the number of Key Hubs from 28

to 12, focusing on the most sustainable locations. The approach to reduce the number

of Key Hubs is supported by Story Homes, who have advocated this approach

throughout the Local Plan process to date.

Methodology

7.2 Story Homes have concerns with the Council’s approach as drafted and in particular,

the settlements which have been selected as Key Hubs and the “scoring approach”

which has been taken in relation to their designation. We refer the Council and

Inspector to our previous representations in relation to Key Hubs.

7.3 It is Story Homes’ position that the Council’s approach in allocating additional sites or

the numbers of dwellings within each site is flawed, because no detailed assessment

has been carried out in relation to the environmental constraints or opportunities

within each site or settlement, including an update of the Sustainability Appraisal . A

full detailed assessment of the local conditions and characteristics including

employment needs and opportunities, demographic and socio-economic profile,

development constraints and opportunities has not been undertaken.

Greystoke

7.4 It is our Client’s view that Greystoke should be allocated as a Key Hub because it

fulfils the required criteria for a Key Hub. Evidence to support the designa tion of

Greystoke as a Key Hub has been previously been presented to the Inspector and

Council with regard to this matter, and we would invite the Inspector to conclude on

this matter.

Sources of Supply

7.5 The Submission Local Plan proposed to deliver 720 new dwellings within the Plan

period, but did not allocate specific sites. This position was found not be sound by the

Inspector. The Key Hubs Paper seeks to increase this to 871 dwellings, with a residual

requirement of 267 dwellings, once 30% windfall; completions; and commitments have

been deducted. We set out our comments in relation to Neighbourhood Plans and

windfall below.


Neighbourhood Plans

7.6 Story Homes does not support the Council’s continued reliance on Neighbourhood

Plans and windfall to deliver the levels of housing required and do not consider that

this approach is justified or effective. Progress on Neighbourhood Plans within Eden

is slow, and they are not considered to be a reliable source for delivery of land.

7.7 The table below provides an update on the progress of the Neighbourhood Plans to

date, which with the exception of Langwathby and Lazonby are limited.

Neighbourhood

Plan Area Status No of Dwellings Proposed

Upper Eden

[includes Brough

and Warcop]

Adopted April 2013 No set number.

Bolton Consultation on Final Draft Plan held in Summer 2016. Will be passed to Referendum if it meets all “basic conditions”.

Seeks to limit development to 40 dwellings of which 22 already have planning permission.

Langwathby Formal consultation held in Summer 2015

Seeks to limit development to 60 dwellings on the basis of an allocated site (28 dwellings) and 2 dwellings per annum with only proposals up to 7 dwellings permitted. Story Homes submitted representations to this document.

Greystoke Parish Designated NP Area– no further progress

Lazonby NP documents due to be submitted to Council in March 2017 with Examination in May 2017. Referendum due in June 2017, with adoption in July 2017.

Number of potential development sites have been identified.

Morland Designated NP Area – no further progress

Skelton Designated NP Area – no further progress

Tebay Designated NP Area – no further progress

Ainstable Parish Designated NP Area – no further progress

Alston Moor Parish

Designated NP Area – no further progress

Appleby in Westmorland

Parish

Designated NP Area– no further progress

Asby Parish Designated NP Area– no further progress

Crosby Ravensworth Parish

Designated NP Area – no further progress

Table 8 – Neighbourhood Plan Update

7.8 We refer the Council and Inspector to our previous representations in relation to

Neighbourhood Plans.


7.9 Additionally, it is Story Homes’ view that there is no certainty that those areas

designated as Neighbourhood Plans areas (Langwathby and Lazonby) will deliver the

level of dwellings required, because there is no firm commitment of what sites will be

delivered through a Neighbourhood Plan, or if this was required to be amended what

sites would be identified. It is our Client’s view that further land release is required

now, and that sites are identified for allocation.

Windfall

7.10 The NPPF sets out that windfall sites are “sites which have not been specifically

identified as available in the Local Plan process. They normally comprise

previously developed sites that have expectantly become available”. It

remains our Client’s position that the Council’s reliance on windfall is not a guaranteed

approach to development, because there is no certainty that the level of housing

required will be delivered from these sites. Windfall will not deliver the numbers

required, nor is there any evidence to suggest that relying on windfall in Key Hubs will

achieve the required levels of completions.

7.11 The Council has failed to provide robust evidence to demonstrate that they are able

to deliver the levels of windfall required within the Key Hubs. The Council has justified

30% windfall based on the number of historical small sites which have come forward.

However, within the Key Hubs, there is limited brownfield land available, and it is our

Client’s view that because the number of Key Hubs has been reduced, the number of

small sites should also decrease. The proposed housing requirement of 242 dpa is a

minimum. It is our Client’s view that any housing derived from windfall should be

additional.

7.12 It is our Client’s view that further land release is required to meet this need now,

rather than relying on an unreliable source of housing supply, which will further

exasperate the Council’s housing delivery problems in the future, when they do not

deliver the level of housing required.

7.13 Story Homes do not consider that an allowance for 30% windfall is appropriate, for

the reasons set out above. To ensure the Plan is effective and that the minimum

housing requirement is met, the reliance on windfall should be removed. Further

allocations within Key Hubs will therefore be required to help meet this requirement.


7.14 Any small sustainable sites which come forward in addition to this should be approved,

because they will help to boost significantly the supply of housing.

7.15 We have undertaken a comparison of the Council and our Client’s respective housing

requirements based on the requirement of 242 dpa and 277 dpa, when applying a

20% buffer.


242 dpa 676 267 409

277 dpa 828 267 561

Table 9 – Residual requirement comparison – Key Hubs

7.16 As shown in the above table, there is a need for additional land to be allocated to

meet the above requirements, particularly within Key Hubs, because it cannot be

guaranteed that this requirement will be met by windfall and Neighbourhood Plans.

Site Specific Comments

7.17 We set out our comments in relation to each Key Hub and its proposed allocations

within Appendix 2.

7.18 In relation to the Key Hubs, the Council has sought to allocate land for 234 dwellings

across the Key Hubs, however, when the sites are assessed against the Council’s

previous assessment within the SHLAA, only 192 dwellings are identified as capable

of being accommodated on the sites, a shortfall of 42 dwellings from the Council’s

figure of 234 dwellings. It is considered that given the constraints identified within

the Table in Appendix 2, the stated supply seems overly optimistic.

7.19 It is therefore Story Homes’ view that further land release is required within the Key

Hubs, and that the Council should not rely on windfall and Neighbourhood Plans to

bring forward housing.

7.20 An overall contingency buffer should be applied to the overall housing supply to allow

for any slippage within the delivery of dwellings within the Key Hubs.

Langwathby

7.21 It is Story Homes’ position that further land release is required within Langwathby,

because it is a Key Hub which is capable of accommodating growth, above the 28

dwellings proposed through the Neighbourhood Plan. It is sustainable settlement with


both bus and rail linkages. We refer the Council and Inspector to our previous

comments in relation to Langwathby.

Conclusion

7.22 Table 5.25 identifies a residual requirement of 267 dwellings, with 234 dwellings

proposed for allocation within the Key Hubs, equating to an oversupply of only 33

dwellings. We do not consider this to be an appropriate buffer of housing supply for

Key Hubs.

7.23 It is therefore considered that to meet the Council’s residual requirement (when

applying a 20% buffer), as identified within Table 9, land for an additional 409

dwellings is required, and when applying Barton Willmore’s residual requirement based

on 277 dpa, land for an additional 561 dwellings is required. Further land release is

therefore required.

Conclusions

8. CONCLUSIONS

8.1 Story Homes acknowledges and welcomes the Council’s proposed increase in the OAN

from 200 dpa to 242 dpa. However, they do not consider that it addresses the concerns

identified within the previous representations in relation to the OAN. We refer the

Council and Inspector to our previous Position Statement (August 2016 – Appendix

1). It remains Story Homes’ view that the full OAN for Eden is between 277 – 289

dpa.

8.2 it is our Client ’s view that the plan as drafted lacks an adequate buffer. Further land

should therefore be allocated within the Plan. The Plan as drafted in effect has no

contingency plan, and therefore effectiveness and flexibil ity of the Plan is

questionable. The Council should consider the inclusion of contingency measures and

mechanisms to release further land for development if required (e.g. Future Growth

Land or Action Plan (as proposed in the Housing White Paper)), or in a worst case

scenario, what level of undersupply would trigger an early review of the Local Plan.

8.3 In relation to Penrith, the wording of Policies PEN1 and LS2, if the Inspector is minded

to progress with the Council ’s figure of 242 dpa (if 242 dpa is accepted as housing

requirement) this should be amended to reflect the overall requirement of 2,178

dwellings rather than the residual requirement of 1,687 dwellings (50%) within Penrith

over the Plan period.

8.4 Whilst we welcome the Council’s approach to allocate additional sites within Penrith,

we do not consider that a sufficient buffer has been provided because it does not

account for any slippage or non-delivery of sites.

8.5 Additionally, justification is required by the Council in relation to “Future Growth Land”

to this, because whilst the Council proposes to allocate a number as “Future Growth

Sites”, no information been provided in relation to the release mechanism that applies.

Clarification of the Council ’s position on this is required.

8.6 In relation to Key Hubs, our Client does not support the Council’s approach to Key

Hubs, and whilst they welcome the reduction in the number of settlements proposed

as Key Hubs, they maintain that this is not based on a detailed assessment of the

constraints and opportunities of each settlement. Other sustainable Key Hubs such as

Greystoke should be designated as Key Hubs.

Conclusions

8.7 Story Homes do not support the Council’s reliance on 100% commitments plus

Neighbourhood Plans or windfall to deliver the level of housing required within the

Key Hubs. Further land release is therefore required to meet these needs and Story

Homes suggest a 20% buffer to ensure to ensure effectives.

8.8 It is Story Homes’ position that a contingency plan is required, which includes a range

of action including an early review of the Local Plan. The Council has accepted that a

higher requirement is needed, however, without further land release this need cannot

be met. Further land release is therefore required.

8.9 The Interim update and methodology is not therefore sound because it is not based

on a robust methodology, full OAN or reliable delivery mechanism.

APPENDIX 1

OAN OVERVIEW (AUGUST 2016)

POSITION STATEMENT OBJECTIVELY ASSESSED HOUSING NEED FOR EDEN DISTRICT

23955/A5/DM/kf 1 August 2016

1.0 Introduction

1.1 This paper has been produced by Barton Willmore on behalf of Story Homes in order to provide

a Position Statement in respect of the methodology for objectively assessing housing need

(OAHN) in Eden District that was submitted via representations to the May 2016 Local Plan

hearings.

1.2 Barton Willmore’s approach to assessing OAN follows the approach set out in Planning Practice

Guidance (PPG) Housing and Economic Development Needs Assessments (HEDNA) that was

originally issued in March 2014 with subsequent updates in March 2015.

1.3 This paper sets out each of the steps Barton Willmore has made in assessing housing need for

Eden District, following the PPG methodology, presenting the result of each stage of the

assessment. Where possible the Council’s assessment will be presented alongside, in order to

assist the Inspector understand where the main differences between the two assessments lie.

1.4 In presenting Barton Willmore’s approach, this paper also seeks to address the additional

questions raised by the Inspector in the July 2016 Local Plan hearings in relation to the 2014-

based Sub-National Population and Household Projections.

2.0 PPG and Barton Willmore’s methodological approach

i) Starting point estimate of need

2.1 PPG (ID 2a-015) states that the starting point for assessing overall housing need should be

the household projections published by the Department for Communities and Local

Government.

Current position - CLG 2012-based household projections

2.2 At the time of the initial May 2016 hearings the CLG 2012-based household projections were

the latest available and these were utilised by Barton Willmore to establish a starting point

estimate of housing need.

2.3 The 2012-based household projections projected growth of 110 households per annum in Eden

District over the Plan period 2014-2032. Once an allowance for vacancy and second homes

has been applied this results in growth of 122 dwellings per annum. Barton Willmore has

applied a 9.54% vacancy/ second home adjustment based on CLG Council Tax data from 2015.

Growth of 122 dwellings per annum is assumed by Barton Willmore to represent the starting

point estimate of housing need for Eden District.


23955/A5/DM/kf 2 August 2016

2.4 Eden District Council (EDC) agree that the 2012-based household projections project growth

of 110 households per annum. EDC apply an 8.9% vacancy/ second home rate based on 2011

Census data which results in growth of 120 dwellings per annum.

2.5 PPG requires local needs assessments to be informed by the latest available information (ID

2a-016). On this basis, Barton Willmore’s use of 2015 CLG data is more up to date than EDC’s

use of the 2011 Census data.

2.6 We therefore consider that the most appropriate 2012-based starting position is

therefore 122 dwellings per annum (2014-2032).

2.7 However, EDC uplift the 2012-based household projection by 10% to address market signals

issues, resulting in growth of 121 households per annum. EDC state that the 10% uplift to

address market signals is in line with Planning Advisory Service (PAS) Guidance. Barton

Willmore consider market signals later in the assessment. Nonetheless it is important to state

that the PAS Guidance has been prepared by Peter Brett Associates (PBA) in isolation. No

consultation took place and therefore the guidance represents the views of one consultant

only. Furthermore the Guidance itself states that:

“The note has no official status. It provides informal advice, which local authorities and others use at their own risk.”1

CLG 2014-based household projections

2.8 At the July 2016 hearings the Inspector raised the question as to whether the recently

published CLG 2014-based household projections should be used as the starting point? Barton

Willmore believe that they should be, given PPG states that local needs assessments should be

informed by the latest available information (ID 2a-016).

2.9 The 2014-based household projections project growth of 80 households per annum over the

Plan period (2014-2032). After an allowance for vacancy and second homes has been applied

(again 9.54% given this is the latest data available) this results in growth of 88 dwellings per

annum.

2.10 Barton Willmore therefore consider that the revised starting point for assessing housing need

in Eden District is 88 dwellings per annum (2014-2032).

1 Paragraph 1.2, page 1, PAS Technical Advice Note: Objectively Assessed Need and Housing Targets, Second Edition, July 2015


23955/A5/DM/kf 3 August 2016

2.11 We therefore consider that the most appropriate updated 2014-based starting point

is 88 dwellings per annum (2014-2032).

ii) Adjust demographic starting point estimate

2.12 PPG (ID 2a-015 and 017) allows adjustments to be made to the starting point estimate of need

to reflect factors affecting the underlying demographic projections and household formation

rates (HFRs). The starting point estimate is calculated by applying HFRs to the ONS Sub-

National Population Projections (SNPP).

2.13 Barton Willmore has given consideration to both the SNPP and the HFRs, which at the time of

the original assessment, was the 2012-based SNPP and HFRs.

Household Formation Rates (HFRs)

2.14 PPG states that the household projection-based estimate of housing need may require

adjustment if formation rates have been suppressed historically (ID 2a-015). The analysis

presented in the Barton Willmore OAN Dashboard (April 2016) compared HFRs from the 2008

projection series through to the 2012 series. The analysis identified that the 2012-based HFRs

for Eden District were lower for those people aged 25-44 years compared to the 2008-based

rates for Eden District (used as a benchmark to represent a more positive period), indicating

suppressed household formation in Eden District.

2.15 Supplementary analysis undertaken by Barton Willmore has identified that there was a 42%

increase in the number of concealed families in Eden District between the 2001 and 2011

Census periods. CLG state:

“Concealed households are family units or single adults living within other households, who may be regarded as potential separate households which may wish to form given appropriate opportunity.”2

2.16 Although the increase in concealed households in Eden District was lower than the national

average (71%), there is clearly a local issue which should be addressed.

2.17 In light of the findings, Barton Willmore consider that an adjustment to the 2012 HFRs is

required in order to address the issue household suppression in Eden District. Whilst household

suppression is not unique to Eden District, the 2012 HFRs would not be a prudent basis from

2 Paragraph 3.4, page 42, CLG (authors Glen Bramley et al), Estimating Housing Need, November 2010


23955/A5/DM/kf 4 August 2016

which to set a housing target in Local Plan preparation, as it would not be considered to be

‘positively prepared’ in the context of the NPPF (paragraph 182) or to ‘significantly boost’

housing supply.

2.18 As the Cornwall Local Plan Inspector stated in relation to the 2012-based HFRs:

“The HR 2012 may still embed some recessionary effect. It would be inconsistent with the national policy for growth to project any such effect throughout the plan period. Accordingly, the projections developed as part of this further update should show both the HR 2008 and HR 2012 and the mid-point, blended approach. On the current evidence, I consider that the most robust approach for deriving the housing requirement would be a projection using a blended HR rate”3

2.19 Following the release of the CLG 2014-based household projections, Barton Willmore has given

consideration to the more recent 2014-based HFRs in order to determine whether the 2014-

based HFRs indicate suppressed household formation, similar to the 2012-based HFRs. Figure

1.1 presents the projected HFRs from the 2008-based series through to the most recent 2014-

based series for Eden District.

2.20 Figure 1.1 illustrates that in Eden District the 2014 HFRs project lower household formation

than the 2012 HFRs which have been acknowledged as suppressing household formation

particularly for younger people. On this basis it is considered that the 2014 HFRs require a

similar adjustment to the 2012 HFRs.

3 Paragraph 3.8, Cornwall Local Plan Examination, Inspector’s preliminary findings, June 2015)


23955/A5/DM/kf 5 August 2016

Local Authority: Eden

Figure 1.1: Analysis of Household Representative (HR) Rates

Comparison of HR rates for persons aged 15+, by 10 year age band, 15 to 74 and for persons 75+ is

presented in the panels below. The HR rates shown are taken from the DCLG 2008-based (blue line), interim 2011-based

(red line), 2012-based projections (green line) and 2014-based series (purple line).

By way of explanation, a rate of 0.5 means that 50% of persons in that age group are said to represent a household, so

that a hypothetical 100 persons is assumed to represent 50 households.

0.30

0.35

0.40

0.45

0.50

0.55

0.60

1991 2001 2011 2021 2031

15+ 2008-based 15+ 2011-based

15+ 2012-based 15+ 2014-based

0.00

0.05

0.10

0.15

0.20

0.25

0.30

1991 2001 2011 2021 2031

15-24 2008-based 15-24 2011-based

15-24 2012-based 15-24 2014-based

0.30

0.35

0.40

0.45

0.50

0.55

0.60

1991 2001 2011 2021 2031

25-34 2008-based 25-34 2011-based

25-34 2012-based 25-34 2014-based

0.40

0.45

0.50

0.55

0.60

0.65

0.70

1991 2001 2011 2021 2031

35-44 2008-based 35-44 2011-based

35-44 2012-based 35-44 2014-based

0.40

0.45

0.50

0.55

0.60

0.65

0.70

1991 2001 2011 2021 2031

45-54 2008-based 45-54 2011-based

45-54 2012-based 45-54 2014-based

0.40

0.45

0.50

0.55

0.60

0.65

0.70

1991 2001 2011 2021 2031

55-64 2008-based 55-64 2011-based

55-64 2012-based 55-64 2014-based

0.40

0.45

0.50

0.55

0.60

0.65

0.70

1991 2001 2011 2021 2031

65-74 2008-based 65-74 2011-based

65-74 2012-based 65-74 2014-based

0.60

0.65

0.70

0.75

0.80

0.85

0.90

1991 2001 2011 2021 2031

75+ 2008-based 75+ 2011-based

75+ 2012-based 75+ 2014-based


23955/A5/DM/kf 6 August 2016

2.21 Given PPG does not specify how such an adjustment to HFRs should be made, Barton Willmore

sensitivity test the application of three different HFR adjustments:

a) A gradual full return to the 2008-based household formation rates for 25-44 year olds

by 2032;

b) A gradual return to the 2008-based household formation rates for 25-44 year olds, so

that by 2032 they represent 50% of the projected growth in the original 2008 rates;

c) A gradual full return to 2001 household formation rates for male and females aged 25-

34 and 35-44 years, only where the 2012 rates are projected to decline below the 2001

rates. For Eden, this required an adjustment to the male rates only for those aged 25-

34 years.

2.22 Applying the HFR sensitivities has the impact of increasing the level of housing need indicated

by the 2012-based household projections from 122 dwellings per annum to up to 131 dwellings

per annum (2014-2032). The maximum uplift is therefore only equivalent to an additional 9

dwellings per annum and is relatively small given the older age profile of Eden District and

given the HFR adjustment is only made to the rates for those aged 25-44 years.

2.23 EDC make no adjustment to address suppressed household formation.

Demographic projections

2.24 Barton Willmore has given consideration to the 2012-based SNPP and in particular the

migration trends from the period 2007-2012 they are underpinned by. Table 1.1 presents net

migration counts for Eden District since 2001.

2.25 It is evident from Table 1.1 that net migration to Eden began to decline from 2006/07 onwards

suggesting that trends from the period 2007-2012 may have been restricted due to the

economic recession. The 2012-based SNPP may therefore provide a conservative projection of

population growth in Eden.

2.26 In contrast, prior to the recession, net migration of people to Eden was considerably higher as

a result of more people migrating to Eden to live than there were people moving out of the

district. In the vast majority of Local Plan Evidence bases a 10-year migration trend

is always considered because it incorporates a period of economic buoyancy and

recession providing a more stable longer term trend. Furthermore, the recent LPEG

recommendation to Government is that consideration should be given to the latest SNPP and


23955/A5/DM/kf 7 August 2016

10-year migration trend and the higher of the two should be taken to represent demographic-

led need.4

Table 1.1: Historic components of population change for Eden District

Natural change

Net Migration

Other changes Total change Total UPC

2001/02 ‐58 461 ‐6 ‐4 397

2002/03 ‐139 743 ‐2 1 602

2003/04 ‐81 599 ‐3 ‐3 515

2004/05 ‐124 419 10 10 305

2005/06 ‐40 231 2 2 193

2006/07 ‐66 396 ‐10 ‐8 320

2007/08 ‐40 265 ‐9 0 216

2008/09 ‐58 228 ‐2 ‐1 168

2009/10 ‐75 154 4 4 83

2010/11 ‐105 ‐68 ‐3 ‐6 ‐176

2011/12 ‐88 242 0 0 154

2012/13 ‐70 19 2 0 ‐49

2013/14 ‐65 82 6 0 23

2014/15 ‐151 80 6 0 ‐65

Total 2001‐15 ‐1,160 3,851 ‐5 ‐5 2,686

Average 2001/15 ‐83 275 0 0 192

Average 2007/12 ‐73 164 ‐2 ‐1 89

Average 2009/14 ‐81 86 2 0 7

Average 2010/15 ‐96 71 2 ‐1 ‐23

Average 2005/15 ‐76 163 0 ‐1 87 Source: Office for National Statistics

2.27 The Barton Willmore OAN Dashboard (April 2016) presented the results of a 10-year migration

trend taken from the period 2004-2014 which was the latest available at the time. The effect

of using a 10-year migration trend along with the HFR adjustments described earlier is to

increase housing need from the 2012-based starting point estimate of 122 dwellings per annum

to between 148 and 157 dwellings per annum.

2.28 EDC consider that no uplift is required to address alternative migration trends. However, we

believe the above evidence clearly supports an upwards adjustment.

2.29 To summarise, Barton Willmore consider demographic-led housing need for Eden

District to be between 148 and 157 dwellings per annum based on a 10-year

migration trend (2004-2014) incorporating a HFR adjustment. EDC consider

4 Local Plans Expert Group (LPEG) Report to the Communities Secretary and to the Minister of Housing and Planning, March 2016


23955/A5/DM/kf 8 August 2016

demographic-led need to be 132 dwellings per annum based on the CLG 2012-based household

projection (unadjusted) with a 10% uplift for market signals.

2.30 The updated 2014-based starting point estimate is based on trends from the 5-year period

2009-2014. Table 1.1 illustrates that average net annual migration to Eden over this period

(86 per annum) was lower than the from the previous 5-year period (2007-2012 = 164 net

migrants per annum) on which the 2012-based starting point estimate was based. This explains

why the 2014-based starting point estimate is lower than the previous 2012-based starting

point.

2.31 The evidence therefore suggests that consideration of a 10-year migration trend is also

necessary in light of the latest 2014-based projections to compensate for the impact of recent

recession which is clearly still impacting the demographic characteristics in Eden

2.32 It is important to point out that when Barton Willmore considers alternative migration trends

we do so by applying an average of migration rates by five-year age and gender – not the total

net migration figure presented in Table 1.1 (which is for ease of illustration only). The benefit

of the rates approach is that it enables the migrant profile specific to Eden District to be taken

into account and therefore does reflect outmigration of younger people and in migration of

older people which is characteristic of Eden.

iii) Assess Labour Force Capacity

2.33 PPG requires plan makers to make an assessment of the likely change in job numbers based

on past trends and/or economic forecasts, also having regard to the growth of the working age

population. Where the working age population that is economically active is less than projected

job growth, plan makers will need to consider how the location of new housing or infrastructure

could help address these problems (ID 2a-018). The implication is that housing numbers

should be increased where this will enable labour force supply to match projected job growth.

2.34 At the July 2016 hearings the Inspector agreed that EDC’s proposed job growth number was

acceptable. EDC proposed growth of between 2,293 and 2,564 jobs in total over the period

2014-2032. This is equivalent to growth of between 127 and 142 jobs per annum – a mid-

point of which is equivalent to 135 jobs per annum.

2.35 Barton Willmore accept the Council’s job growth figure of 135 jobs per annum

(2014-2032).

2.36 Barton Willmore’s analysis (as presented in the April 2016 OAN Dashboard) indicated that the

demographic-led OAN would not support any job growth at all (-37 jobs per annum) in Eden


23955/A5/DM/kf 9 August 2016

district, thereby warranting an uplift to housing need in order to support growth of 135 jobs

per annum. EDC also consider an uplift to demographic-led housing need is required to support

growth of 135 jobs per annum.

2.37 Neither Barton Willmore’s nor EDC’s demographic assessment of need will support

growth of 135 jobs per annum. An uplift to demographic housing need is therefore

required to support economic growth of 135 jobs per annum.

2.38 The two parties disagree in respect of the number of dwellings required to support growth of

135 jobs per annum. Barton Willmore identify a need for between 277 and 289 dwellings per

annum (depending on which HFR adjustment is applied), whereas EDC consider 200 dwellings

per annum are required.

2.39 Barton Willmore’s assessment has been undertaken using the POPGROUP and Derived Forecast

(DF) model. EDC criticise the POPGROUP methodology stating that the model automatically

assumes people come into an area to do new or vacant jobs which produces an unrealistic

figure.5 Barton Willmore disagree.

2.40 POPGROUP is well-established model used by over 90 users, including academic and public

service staff in housing, planning, health, policy, research, economic development and social

services. Cumbria County Council are users of the POPGROUP model. POPGROUP provides

the UK standard for local area demographic analysis and forecasting, complementing the

approaches used by the UK statistical agencies including the Office for National Statistics

(ONS).

2.41 In a job-led forecast the POPGROUP model calculates the required population growth needed

to support the future job target, taking account of commuting patterns, unemployment rates

and economic activity rates. In this type of forecast the model forecasts the population through

the cohort component methodology but increases (or decreases) the population accordingly to

meet the set job target by altering migration levels. HFRs are applied to the generated

population forecast in order to determine a housing requirement.

2.42 With regards to commuting, Barton Willmore applies the 2011 Census commuting ratio for Eden

District of 0.95. This ratio implies that Eden is a marginal net importer of labour.

Barton Willmore hold this ratio constant throughout the entire projection. This is common

practise because PPG requires a ‘policy off’ assessment of housing need. To alter the

commuting ratio in respect of recalling commuters would naturally have an impact on

5 Page 12, Eden District Council SHMA – Objectively Assessed Need Progress Note, June 2016


23955/A5/DM/kf 10 August 2016

neighbouring authorities and any assessment of need they may have undertaken, and would

be a ‘policy-on’ judgement. The ‘policy-off’ approach to commuting assumptions has been

confirmed by the Oadby & Wigston vs Secretary of State and Bloor Homes (paragraph 31 (i))

and was recently endorsed in the section 78 appeal decision in respect of Land off Tanton

Road, Stokesley (APP/G2713/A/14/2223624). PPG is keen to ensure unsustainable commuting

patterns are prevented (ID 2a-018). The application of a 0.95 commuting ratio within the

POPGROUP model means that the model will assume that 5% of the workforce required to

support growth of 135 jobs per annum will come from people who reside outside of Eden

district. Thereby the model is not providing a dwelling in Eden for those people who live

outside of the district but work in Eden.

2.43 With regards to unemployment, Barton Willmore use modelled estimates from the Annual

Population Survey (APS) assuming that unemployment returns from the 2011 rate (3.9%) to

the pre-recession average (2.0%) by 2021 and then held constant. This is considered to be a

prudent approach.

2.44 With regards to economic activity, Barton Willmore apply economic activity rates by 5-year age

group and gender for Eden District from the 2011 Census and project these forward following

the Office for Budget Responsibility (OBR) November 2015 projection. The OBR rates are used

by the Government to plan activities for the State and are therefore considered to be a robust

source. This view has also been supported by Inspectors in S78 appeals6. Furthermore, LPEG

recommend the use of the OBR rates. The OBR rates project an increase in economic activity

amongst older people to reflect the increase to State Pension Age. The use of the OBR rates

is again, considered to be a prudent approach.

2.45 Barton Willmore’s methodology is therefore robust.

2.46 In contrast EDC’s assessment uses a method developed in-house by the Council and is based

on the application of several basic conversion ratios based on relationships at the time of the

2011 Census. Unlike POPGROUP, EDC’s methodology has not been tested through any Local

Plan Examination, neither has the Council’s methodology been subject to any consultation.

EDC’s methodology results in a level of housing need that is significantly lower than the likely

level of economic-led housing need and will not therefore meet the districts full objectively

assessed needs or boost significantly the supply of housing.

6 Appeal Decision APP/V0728/W/15/3018546 Longbank Farm, Ormesby, Middlesbrough Appeal Ref: APP/W1525/W/15/3049361 Land off Plantation Road, Boreham, Essex


23955/A5/DM/kf 11 August 2016

2.47 To summarise, Barton Willmore consider economic-led housing need for Eden District

to be between 277 and 289 dwellings per annum to support growth of 135 jobs per

annum (2014-2032) based on the application of the adjusted 2012-based HFRs. EDC consider

economic-led need to be 200 dwellings per annum.

2.48 Application of adjusted 2014-based HFRs to the economic-led assessment of need would also

result in OAN c277-289 dwellings per annum, possibly slightly higher given that the 2014-

based HFRs are lower than the 2012-based HFRs.

2.49 An updated economic-led OAN is still expected to be in the region of 277-289 dwellings per

annum despite a lower 2014-based starting point. This is because economic-led OAN will still

be based on the requirement to support growth of 135 jobs per annum. The POPGROUP model

has identified that to support growth of 135 jobs per annum, Eden’s resident labour supply will

need to increase by 109 people per annum (taking into account Eden’s commuting,

unemployment and economic activity rates). To provide a resident labour supply of 109 people

per annum, the total population will need to increase by 401 people per annum (taking into

account Eden’s age profile). This assessment in effect remains the same even with an updated

starting point. The key difference will be in the application of 2014-based HFRs rather than

2012-based HFRS to determine the housing requirement.

iv) Assess market signals

2.50 PPG requires plan makers to give consideration to six market signals indicators stating that a

worsening trend in any of these indicators will require an upward adjustment to planned

housing numbers compared to ones based solely on household projections.

2.51 Barton Willmore presented an overview of market signals within the April 2016 OAN dashboard

which identified worsening affordability.

2.52 There is no clear guidance in the PPG on how much of an uplift to OAN should be applied to

account for adverse market signals. Barton Willmore’s approach is to consider how much of

an uplift the OAN (in this instance the economic-led OAN) provides to the starting point

estimate (the household projection) and past delivery of housing in Eden. OAN of between

277 and 289 dwellings per annum provides a 73-81% uplift against past delivery. The Barker

Review (2004) stated that need should exceed past supply by 86% to improve affordability.

2.53 No uplift is therefore made by Barton Willmore for market signals given the OAN of between

277 and 289 dwellings per annum does provide an upward adjustment to the household

projection. OAN of between 277 and 289 dwellings per annum is also considered to improve

affordability in Eden.


23955/A5/DM/kf 12 August 2016

2.54 EDC make a 10% market signals uplift to the household projection but this exercise is purely

academic given EDC’s final OAN of 200 dwellings per annum is economic-led and therefore

exceeds the demographic-led OAN (household projection plus 10% uplift).

v) Bringing the evidence together - Conclusion

2.55 Barton Willmore and EDC reach a different conclusion with regards to the demographic-led

OAN for Eden District. EDC calculate demographic need from the 2012-based ONS SNPP/ CLG

household projection (unadjusted) with a 10% uplift for market signals. This generates a need

for 132 dwellings per annum (2014-2032).

2.56 Barton Willmore consider the 2012-based ONS SNPP require adjustment in Eden District to

reflect a more stable migration trend on which to assess future need. Furthermore, the CLG

2012-based HFR have been found to suppress household formation for younger people in Eden

District which is not a prudent basis on which to plan. For this reason, Barton Willmore

calculate demographic need for Eden District using a 10-year migration trend (2004-2014) with

adjusted HFRs. This generates a need for between 148-157 dwellings per annum. Table 1.2

(at the end of this section) summarises the differences between the two assessments.

2.57 Despite the different conclusion in respect of demographic need, both parties agree

that demographic-led OAN will not support projected employment growth of 135

jobs per annum and that a further uplift to housing need is required.

2.58 Therefore both parties agree that full OAN for Eden district is an economic-led OAN. However,

Barton Willmore consider (based on the application of adjusted 2012-based HFRs) full OAN for

Eden district to be between 277 and 289 dwellings per annum and EDC consider full OAN to

be 200 dwellings per annum.

2.59 The main area of disagreement therefore is in respect of how each party calculates the number

of people required to support growth of 135 jobs per annum and in turn the number of

dwellings required to support these people. Barton Willmore has used the well-established

POPGROUP and DF model which is a sophisticated tool designed specifically to forecast

population, households and labour force and the relationship between them. In contrast, EDC

has applied a series of basic ratios from the 2011 Census which is considered to significantly

underestimate the full objectively assessed need for housing in Eden District as required by

PPG. EDC’s methodology is not robust, has not been consulted upon and has not been tested

through the Examination process. On this basis, it is considered Barton Willmore’s

methodology should be preferred and full OAN for Eden District should be taken to


23955/A5/DM/kf 13 August 2016

be between 277 and 289 dwellings per annum (2014-2032) based on the application

of adjusted 2012 HFRs.

2.60 Both Barton Willmore’s and EDC’s assessments of housing need were undertaken before the

release of the 2014-based SNPP and household projections. Barton Willmore are of the view

that this latest data release should be taken into account in accordance with PPG. However,

the new projections will only have an impact on the assessment of demographic-led housing

need. It is apparent from initial consideration of the published data that the 2014-based

projections project lower population and household growth than the 2012-based equivalents,

therefore resulting in a lower starting point estimate of need. However, Barton Willmore are

of the view that consideration of a 10-year migration trend remains necessary in light of the

2014-based release.

2.61 Given demographic need based on the 2012-based projections would not support growth of

135 jobs per annum, it can be concluded that neither will an updated demographic need based

on the 2014-based projections given they are lower. Therefore, it is anticipated that an uplift

to housing need would still be required to support EDC’s job target of 135 jobs per annum.

2.62 Full OAN for Eden District is therefore anticipated to remain in the region of between 277 and

289 dwellings per annum, even in light of the 2014-based population and household

projections. However, given the 2014-based HFRs have been found to suppress household

formation more greatly than the 2012-based HFRs (Figure 1.1 of this report), if the 2014-based

HFRs were utilised and the same HFR adjustments applied, housing need could potentially

increase above 277-289 dwellings.


23955/A5/DM/kf 14 August 2016

Table 1.2: Comparison of Barton Willmore and EDC’s OAN assessment (2014-2032)

SHMA (final) - Sept 2015

Starting point: 2012-based 110 households per annum equivalent to 120 dpa

2014-based n/a

2011 Census8.90%

1. Demographic OAN 132 dpa

Population projection(ID2a 016, 017). Sensitivity testing of local migration and population change, taking account of the most recent demographic evidence from ONS

2012-based SNPP

Household Formation Rates (HFRs)(ID2a 015, 016) may have been supressed historically by undersupply and worsening affordability of housing. As a result, the CLG 2012-based household formation rate projections may also be suppressed. If so they must be adjusted upwards so that the suppression is removed.

CLG 2012-based household formation rates (all age groups)

Other Uplift of 10% applied to household projection to address market signals

2. Economic OAN 194-206 dpa

Total growth of between 2,293 and 2,564 jobs (equivalent to between 127 and 142 jobs per annum)2,293 derived by applying ratio of 0.94 workers per household to 2012-based household projection.2,564 derived by applying growth rate of 9.16% (uncertain of source) to 2011 Census count of resident workforce plus in-commuters.

Economic activity rates2011 Census economic activity rates for males and females aged 16-74 years held constant

Unemployment ratesn/aSHMA's Jobs to Dwellings Calculator doesn't apply unemployment rate directly

Commuting ration/aSHMA's Jobs to Dwellings Calculator doesn't apply commuting ratio directly

3. Market signals uplift 0

Worsening Market Signals observed?(ID2a 019, 020) of undersupply relative to demand that are worsening trigger an upward adjustment to planned housing numbers that are based solely on household projections. The more significant the affordability constraints, the larger the additional supply response should be

Yes10% uplift applied to starting point to derive

demographic OAN

Full OAN compared to average annual past completions (03/04 to 14/15)

25%

Full OAN compared to starting point 66%

Full OAN 200 dpa

Job Forecast(ID2a 018) based on past trends and or projections should be taken into account. The OAN must be capable of accommodating the supply of working age population that is economically active (labour force supply), if it does not them it should be adjusted upwards.

Vacancy/ second homes rate

80 households per annum equivalent to 88 dpa

110 households per annum equivalent to 122 dpa

BARTON WILLMORE

YesHowever, no specific uplift applied for market

signals because economic OAN provides a significant uplift to starting point and past delivery. Barker Review suggested 86%

increase in housing supply would improve affordability

CLG 2012-based household formation rates adjusted for 25-44 year olds using three sensitivity tests (full return to 2008 rates for males and females, 50% return to 2008 rates for males and females and return to 2001 rates for males only)

Long term migration trend (2004-2014) and 2012-based SNPP

277-289 dpa

Growth of 135 jobs per annum

Mid-point of job growth presented in SHMA (Table 21, page 53)

2011 Census rates by 5 year age group and sex for Eden projected following OBR Nov 15 national projection which assumes increased 3.9% (2011) returning to pre-recession average of 2.0% by 2021 based on ONS data from APS for Eden2011 Census value of 0.95 fixed over the forecast period (assumes Eden is net importer of labour)

0

131-141%

277-289 dpa

148-157 dpa

9.54%CLG 2014

73-81%

APPENDIX 2

KEY HUBS OVERVIEW OF SITES [STORY HOMES]

Appendix 2 – Key Hubs Site Assessment (Story Homes) April 2017

Site Reference Site Name LPA Capacity SHLAA Capacity

Armathwaite

LAR3a Land to the north east of Armathwaite 15 SHLAA - 17

• Access and landscape constraints identified

• No footpath along the highway

• Within a national speed limit area

• Availability in 2014 – no application submitted

• Deemed by LPA to be “uncertain” in terms of suitability

Brough and Church Brough

LBR1 Rowan House 10 SHLAA – 10

• Site has been allocated for housing since the 1996 Local Plan with planning permission obtained for 6

dwellings (outline) in 1989 (89/0334) which was renewed in 1995 but has expired (95/0009). Since this

time, the Site has failed to come forward for delivery.

• Mitigation is required in relation to noise due to A66

• Landowner unknown and no developer interest in site

• Visibility/access constraints

• Availability and Achievability unknown

-

LBR2 Castle View 6 SHLAA - 13

• Site has been allocated for housing since the 1996 Local Plan but has not been delivered

• Cap on development by Upper Eden NP (3.48 dpa)

• Considered that due to this cap, no further development can come forward until the later years of the

plan

• Noise impact, mitigation required

• Flood risk

• PROW restricts the deliverability of the site and requires diversion

• Application for 6 dwellings withdrawn in 2014 (14/0434)


Culgaith (no allocations proposed*) 1

LCU1 Land at Rose Bank Farm 14 SHLAA - 14

• Bat activity on site

• Listed building on site

• Potential contamination

• Planning permission for barn conversions has expired

• Redevelopment would require the conversion and reuse of traditional buildings.

LCU3 Land at Lime Tree Farm 18 SHLAA - 18

• Bat activity on site

• Potential visual impact and impact on visual character

• Potential contamination

• PROW ion western edge

• Site promotion in 2007, no further information available in relation to the development of the site

LCU6 Land adjacent to Loaning Head Courtyard 5 SHLAA - 5

• Landscape and visual impact

• Access constraints due to location on a bend

• History of refusal on site for residential development – 4 applications refused

Hesket

LHH2 Land adjacent to Elm Close 15 SHLAA – 0

• Discounted as a site within the SHLAA due to unconfirmed availability

• Significant constraints in terms of highway capacity due to existing and committed developments

Kirkby Thore

LKT1 Land opposite the Primary School 45 SHLAA - 18

• Surface flooding


• Archaeological potential – proximity to Kirkby Thore Roman Fort Scheduled Ancient Monument

1 Discounted from overall Key Hubs Allocations


• Visibility constraints due to access on a bend

• Traffic calming measures would be required

• Site has been allocated since 1996 with no intention to progress with its development

Langwathby

• No allocations proposed – 28 dwellings to be delivered through NP at Langwathby Hall Farm

• This site is identified as suitable for 14 dwellings only


• No planning history

• Not an efficient use of land

SHLAA - 14

Lazonby

• No allocations proposed to be delivered through NP

Nenthead

LNE1 Moredun Garage 5 SHLAA - 6

• Promoted through SHLAA

• Contamination and flooding issues

• AONB

• Surface water flooding

• Currently leased to blacksmith

• SHLAA identifies it as unviable in short -term

• Net loss of local employment land

LNE3 Wright Brothers Garage 13 SHLAA - 13

• Brownfield

• Planning permission for a new bus depot (12/0599)

• Unviable for residential without additional funding

Plumpton

LPL2 Land adjacent to Byrnes Close 28 SHLAA – 30


Shap

LSH1 West Lane 8 SHLAA – 8

• Part of 1996 LP designation

• Flooding and drainage issues

• PROW

• Outline pp for affordable dwellings (6) was submitted and withdrawn

LSH5 Land behind Woodville Terrace 14 SHLAA - 14

• Noise impact

• Flooding issues

• Heritage considerations

• Access constraints

• No immediate intention from landowner to develop site

LSH13 Land behind Carl Lofts 15 SHLAA - 15

• No vehicle access

• Noise impact from railway

• Identified as being only of long-term potential

LSH14 Land adjacent to library 5 SHLAA - 5

• Residential amenity issues

LSH16 Former Food Factory 15 SHLAA - 15

• Contamination

• Visual impact

Stainton

LST8 Land to west of Lakeland Free Range Egg Company 20 SHLAA – 10

• Greater new eastern approach to village

• Incorrect reference – should be LST9



Tebay

LTE5a Land adjacent to Cross Keys Inn 12 SHLAA – 9

• Planning permission but s106 isn’t signed since 2014

LTE5 Land adjacent to Church Rise 9 SHLAA – 9

• Reference should be LST6

• FROW

• Existing uses on site

• Topo constraints

• Visual and landscape impact

• Highway improvements

• PP for 4 dwellings

Overall supply [excluding italics] 234 192

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