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REPRESENTATIONS - Hart District · 2.9 In total, only 1,591 dwellings of the committed supply...
Transcript of REPRESENTATIONS - Hart District · 2.9 In total, only 1,591 dwellings of the committed supply...
REPRESENTATIONS
Hart District Council Local Plan Main Modifications Consultation
SUBMITTED ON BEHALF OF WATES DEVELOPMENTS LIMITED
August 2019
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Contents
Introduction .......................................................................................................................... 5
Housing Need and Requirement ......................................................................................... 7
New Settlement Area of Search ........................................................................................ 10
Housing Supply ................................................................................................................. 11
Local Plan Review ............................................................................................................. 13
Sustainability Appraisal ..................................................................................................... 15
Conclusions and Recommendations ................................................................................. 18
APPENDICES
Appendix A – Wates Matter 3 Hearing Statement
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INTRODUCTION
1.1 These representations are prepared on behalf of Wates Developments Limited (‘Wates’), the promotion party
and developer relating to the potential development of up to 700 residential dwellings, site for primary school,
Suitable Alternative Natural Greenspace (SANG) and community facilities at Pale Lane, Fleet.
1.2 These representations are made following the publication of Proposed Main Modifications to the Hart Local Plan
Strategy and Sites 2016-2032 Pre-Submission Version document and supporting Sustainability Appraisal Report
Addendum.
1.3 For the emerging Local Plan, Wates has submitted duly made representations to each stage of its production.
This includes submissions to the Council’s Regulation 19 consultation on the submission draft plan, production
of Hearing Statements to the Inspector’s Issues & Matters Questions, and participation throughout the
Examination in Public (EiP). Throughout these submissions, Wates has raised significant deficiencies within the
Plan and its supporting evidence base, many of which have been reflected in the Inspector’s Post Hearing Letter,
dated 26th February 2019.
1.4 Whilst positive steps towards making a sound and legally compliant Local Plan have been made by the Council
through the proposed Main Modification, significant deficiencies remain. In summary, these representations
cover:
Support for the revised housing requirement in the context of accommodating unmet need from Surrey
Heath District Council (SHDC);
Continued evidence to demonstrate the full OAHN as in excess of that proposed within the Council’s
SHMA;
Support the removal of all references to an Area of Search for a new settlement at Murrell
Green/Winchfield, including policy SS3;
Highlight the unsound approach of failing to plan for 230 dwellings against the new housing requirement;
Support the inclusion of early review mechanisms, particularly in light of the failure to Plan for the District’s
housing requirement; and
Highlight the continued deficiencies in the Sustainability Appraisal (SA), which have not been rectified by
the SA Report Addendum.
1.5 Wates has demonstrated land at Pale Lane to be available, suitable and deliverable, testing this under the
scrutiny of a planning application and public inquiry. In light of the above continuing deficiencies, we propose a
further Main Modifications to include the Pale Lane site within the Local Plan, supported by an updated and
objective SA Addendum. This would result in the following benefits:
Meet the proposed housing requirement in full, reducing the likelihood for the need of an early review of
the Local Plan;
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Create a modest buffer of 6% to provide flexibility in meeting the housing requirement;
Provide much needed affordable housing in an area that will continue to deliver far fewer than is the
evidenced need;
Deliver sustainable development in a location that has been shown to be capable of providing appropriate
supporting infrastructure including in relation to education and SANG; and
Align with the Local Plan Vision in directing growth to Fleet, developing its role as the main service centre
in the District.
1.6 In allocating Pale Lane, the Council would rectify existing deficiencies (subject to production of an appropriate
supporting SA and on the assumption the Inspector remains unmoved on his conclusions on OAHN), allowing
the Council to adopt the Local Plan and secure up-to-date planning policies, providing greater certainty in the
direction of future growth in the District.
1.7 In accordance with the transitional arrangements of the 2019 National Planning Policy Framework (NPPF) and
as confirmed by the Inspector during the Examination, the Plan will be assessed against the policies of the 2012
NPPF. Unless specifically stated, all references to the NPPF will be in relation to the 2012 iteration.
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HOUSING NEED AND REQUIREMENT
2.1 This section addresses the proposed changes under MM10, MM19, and MM21, as well as a commentary on the
Council’s objectively assessed housing need (OAHN) and housing requirement.
OBJECTIVE ASSESSED HOUSING NEED
2.2 Wates supports a proactive and positive approach by local planning authorities in assessing, and supplying for
their future housing needs. In this context, we commend the suggested approach of the Council when assessing
the standard methodology, removing the ‘cap’ and then applying an uplift of 25% as a contingency in case of a
change in methodology or alterations to data such as household projections or affordability ratios. However, it is
clear that under the transitional arrangements of the 2019 NPPF the use of the standard methodology is not
justified. This was clearly set out within our Matter 3 Hearing Statement and accepted by the Council during the
Examination hearings.
2.3 We maintain the OAN of 382 dwellings per annum (dpa) set out in the SHMA is not robust. Full details are set
out within our Matters 3 Hearing Statement appended to these representations; however, key failings can be
summarised as:
Failing to address in any robust manner the historic under-delivery as a result of a building moratorium,
as required by PPG 2014 ID 2a-015. This means the SHMA’s analysis flowing from this (including the
market signals uplift and affordable housing) are also inherently flawed;
Failing to make an adjustment for market signals which on reasonable assumptions could be expected
to improve affordability, as required by PPG 2014 ID 2a-020. Applying a fixed percentage uplift to a flawed
starting point (as the SHMA has done) simply produces a figure which is also inherently flawed, and in
any case our analysis of comparators shows that 15% is likely to be too low. The SHMA does not consider
any other options, such as a stock growth based approach, which would not depend on the projections
but could provide a useful benchmark for what Hart might be expected to deliver if it delivered simply at
the national average rate (of 1.3%), or more given the scale of affordability pressures. A rate of 1.3%, or
507 dpa, is still well within what is ‘reasonable’, particularly given higher rates of 1.8-2% seen elsewhere
in more affordable districts;
Failing to address affordable housing needs as required by the PPG (and clarified in King’s Lynn decision)
within the OAHN itself. Instead, the Council defers this to the requirement, which does not reflect
paragraph 159 of the NPPF or the King’s Lynn decision. HOU5 shows that the Council believes a figure
in excess of 382 dpa is deliverable, and this should have formed part of the OAHN.
2.4 Correcting the flaws in the SHMA, the evidence indicates that a housing figure in the region of at least 500 dpa
would be an appropriate basis for the plan. This would:
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Reflect starting point demographic-led needs likely to be at least c.320dpa (but likely more) once
accounting for the distorting and dampening effects the housing moratorium had on the trend period from
which the household projections draw;
Reflect the significant uplift necessary to address market signals and affordability in Hart;
Would broadly match the 1.3% stock growth per annum which nationally needs to be achieved to meet
Government’s 300,000 dpa target; and
Levels above 500 dpa would address more of the significant affordable housing need in the District.
SURREY HEATH UNMET NEED
2.5 We support the conclusions of the Inspector in relation to unmet need from SHDC. It is clear that Hart represents
the optimal, and possibly only location to ensure unmet need from SHDC can be accommodated within the
housing market area.
2.6 We agree with the Inspector that unmet needs from SHDC could rise from the current levels proposed within the
Main Modifications. However, based on the evidence available at this time, a pragmatic approach is for the
proposed accommodation of 41 dpa on top of Hart’s OAHN, with a review mechanism installed should the
Examination into the SHDC Local Plan, or any additional evidence provide a clearer indication that this unmet
need is greater.
HOUSING REQUIREMENT
2.7 Taking the above into account, we support in principle an uplift to the housing requirement in line with the
suggestion of the Inspector. However, in line with our Matter 3 Hearing Statements, the proposed 423 dpa would
still reflect a significant shortfall against the full OAHN figure.
2.8 We support the recognition by the Inspector of the benefits to affordable housing delivery resulting from raising
the housing requirement. The Council’s evidence identifies a significant need for affordable housing. HOU1a
Figure 10.27 details there to be a need for 130 affordable rented homes and 180 subsidised purchase homes
per annum, or a total of 310 affordable dpa.
2.9 In total, only 1,591 dwellings of the committed supply (completions to date, sites with permission, including
Hartland Village) would come forward as affordable housing, which would represent only 27% of the total
committed supply. When including other sources (i.e. sites within boundaries etc.) this would increase to 1,695
affordable homes, or 26% of the overall housing supply. Against the affordable housing need identified over the
plan period, the Council’s supply of affordable housing would only meet 34% of this need, equating to shortfall
of 3,265 affordable homes.
2.10 Paragraph 10 of the Inspector’s letter states “I consider that to uplift the housing requirement beyond 423
dpa, to deliver additional affordable housing, would result in open market dwellings being provided when there
is no evidence of any need, which could lead to an imbalance between homes and jobs and unsustainable
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commuting patterns.” However, it is clear from the above shortfall that a failure to raise the housing requirement
beyond 423 dwellings would in fact itself cause a significant social and economic impacts, exacerbating an
already acute housing crisis problem.
2.11 The evidence shows that there is not just a failure in affordable housing delivery, but a failure to address
affordability in Hart. The SHMA started from a flawed starting point, failing to account for a development
moratorium that cumulated historic under delivery. The fixed 15% uplift is also shown to be too low when
compared to our analysis of other local authorities where a 20-30% uplift was applied to areas of better
affordability.
2.12 Furthermore, we have detailed for reference how a stock-based approach against national average would
result in a need of 507 dpa. Given that the affordability crisis within Hart greatly exceeds that of the national
average, to provide a housing requirement in excess of this figure would be in line with Government policy to
address affordability by significantly boosting the supply of housing and delivering 300,000 dpa.
2.13 It has been evidenced through the Examination, supported by the Council’s evidence that sustainable and
deliverable sites are available in Hart that would help deliver these aims. We do not support the notion that there
is no evidence of any need beyond the requirement of 423 dpa, which represents a minimalist approach to
addressing the housing crisis at both a national and local level.
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NEW SETTLEMENT AREA OF SEARCH
3.1 This section provides comment on the proposed removal of references within the Local Plan to an Area of Search
for a new settlement at Murrell Green/Winchfield, including the entirety of Policy SS3. Relevant Main
Modifications include:
MM11;
MM12;
MM19;
MM20;
MM25;
MM32;
MM75;
MM130;
MM149; and
PM02.
3.2 Wates strongly supports the removal of all references to an Area of Search for a new settlement at Murrell
Green/Winchfield. It was clear from the Examination hearings that the Council had fallen far short of
demonstrating the soundness of Policy SS3.
3.3 We agree with the assessment of the Inspector, as detailed at paragraph 18 of his letter that the policy sought to
establish the principle of a new settlement as the most appropriate growth strategy for meeting the Council’s
long-term needs. The Council sought to do this without providing a sound or legally compliant assessment to
demonstrate this as the most appropriate strategy when considered against the reasonable alternatives, as
required by paragraph 182 of the NPPF.
3.4 Whilst the Council may retain long term aspirations for the development of a new settlement at Murrell
Green/Winchfield through a review of the Local Plan, it needs to ensure that a fully evidenced and impartial
assessment is undertaken against other reasonable alternatives, including sustainable urban extensions to key
service centres.
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HOUSING SUPPLY
4.1 This section assesses the impacts of retaining a shortfall of some 230 dwellings within the Local Plan’s housing
land supply against the requirement. This is relevant to MM10, MM22, MM23, and MM142.
4.2 The revision of the Local Plan period to cover 2014-2032, alongside an uplift in the housing requirement to 423
dpa results in a total housing target of 7,614 dwellings. Table 1 of the Local Plan as detailed at MM23 details for
a total supply of 7,384, a shortfall of 230 dwellings.
4.3 We would consider it unwise for a Council not to propose a buffer within its supply beyond the total housing
requirement. However, proposing to adopt a Local Plan that does not identify sufficient sites for meeting its
housing requirement is categorically unsound.
4.4 Paragraph 13 of the Inspector’s letter states:
“The Plan would provide for specific, developable sites for 12 years following the adoption of the
Plan anticipated sometime in 2019. I consider that this would meet the requirements of Paragraph
47 of the NPPF and the shortfall of 230 dwellings during the last year of the Plan period, would
not result in the Plan being found unsound, particularly as the Plan would need to be reviewed in
5 years time in any event.”
4.5 We appreciate the Inspector’s approach in seeking a pragmatic way forward to assist the Council in adopting its
Local Plan. However Paragraph 182 is clear that to be considered ‘positive prepared’, the Local Plan should be
based on a strategy that meets housing requirements. We disagree that the Local Plan meets the requirements
of paragraph 47 of the NPPF, which states that local planning authorities should “use their evidence base to
ensure that their Local Plan meets the full”, going on to state the need to “identify a supply of specific, developable
sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15” [our emphasis].
4.6 The Council has available to it a wealth of sites that are available and deliverable to meet this need. There has
been no justification, and no justification exists why the Council cannot identify either a broad location or specific
development site that would provide for this shortfall of 230 dwellings.
4.7 Whilst we support recognition by the Inspector (paragraph 10 of his letter) that an increase in housing requirement
would result in more affordable housing, this would not actually materialised unless further sites are identified for
the supply.
4.8 The SA1 has identified that a spatial strategy including Pale Lane is most favourably higher growth option. As the
‘do-minimum’ option no longer meets the OAHN/housing requirement for the Local Plan and can therefore no
longer be considered a sound approach, a clear and evidenced route would be to adopt this Option 2 approach
1 Page 141 of the February 2018 Sustainability Appraisal Report – Summary findings and conclusions
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and allocate the Pale Lane site. This has been demonstrated as capable of delivering much needed affordable
housing in line with the recognised significant need in the District.
4.9 Deferring the identification of this supply to a potential Local Plan review in five years time runs contrary to the
principle of the plan-led system. If the Council is to only identify sufficient sites to meet its development needs up
to one year before the end of the Plan period with no justification for doing so, then there remains no reason to
provide for a Local Plan up to 2032 and the Plan period should be amended to 2014-2031.
4.10 Wates has grave concerns over the reliability of the Council to bring forward a review of the Local Plan in a
timely manner when required. The need to review Local Plan every five years has been a statutory requirement2
for over seven and a half years. The current Hart District Local Plan 1996-2006 was adopted in 2002, with saved
policies confirmed in 2009. Accordingly, the District has seen a 13 year period beyond the end that Local Plan
period where a policy vacuum for strategic planning has been left, a period that included a moratorium on house
building and housing become 50% less affordable to average households. Given the lack of justification to the
contrary, it is imperative the Plan is amended to include provision for the entirety of the housing requirement.
2 Regulation 10A of the Town and Country Planning (Local Planning) (England) Regulations 2012)
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LOCAL PLAN REVIEW
5.1 This section addresses amendments to the potential review mechanisms within the Local Plan as detailed at
MM121.
5.2 Wates strongly supports the inclusion of early review mechanisms to be incorporated into the Local Plan. In its
approach to the standard methodology, the Council had clear recognition for the need to provide flexibility to a
Local Plan given uncertainty around future housing need. Given the lack of flexibility within the proposed housing
supply, and in fact a shortfall against the housing requirement, the need incorporate clear and stringent review
mechanisms is essential.
5.3 MM121 details four scenarios in which an early review (prior to the statutory five years from adoption) of the
Local Plan will be triggered. Whilst these are supported in principle, they fail to provide specifics that give clarity
on when a review is triggered.
5.4 The first trigger states that “Results of annual monitoring on the effectiveness of the plan in line with the Plan’s
Monitoring Framework and having particular regard to the monitoring of housing delivery”. This is unclear on
what extent of failure against housing delivery objectives would actually trigger a review, is it any under delivery?
5.5 A clearer approach might be to link this trigger to the Housing Delivery Test. Should the Council fall below the
95% threshold and be required to produce an Action Plan, this could incorporate the implementation of a review
of the Local Plan. An additional approach could be to trigger a review should it be demonstrated that the Council
is failing to demonstrate a five year supply of housing, either through an Annual Position Statement or within a
section 78 appeal decision. This would provide the opportunity for the Council to get ahead of the problem before
housing delivery necessarily falls below the housing need/requirement.
5.6 The second trigger relates to significant changes in national planning policy and/or legislation. It is appreciated
that this is difficult to be specific here as some future changes are currently unknown. However, the Council is
aware of the 2019 NPPF (of which this Local Plan is not examined against), including the standard methodology,
itself to be subject to further changes.
5.7 The Council should include reference to any changes in the standard methodology identifying a Local Housing
Need for the District that would result in either a failure of the Housing Delivery Test (below 95% and the triggering
of an Action Plan in line with the above), or a failure to demonstrate a five year housing land supply. As
demonstrated in its original approach to OAHN, the Council is clearly conscious of changes to the standard
methodology and a need to create flexibility to accommodate future changes. Applying a specific trigger such as
this allows the Plan to ensure that it can still be effective throughout its lifetime.
5.8 We support a trigger linked to any further unmet need arising within the HMA. A practical approach to SHDC’s
unmet need has been proposed, based on the evidence available. As SHDC moves through to the latter stages
of producing its new Local Plan, including its Examination, more clear evidence will be produced to demonstrate
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the full extent of unmet need. Should there be any increase from that currently proposed to be accommodated
within the Hart Local Plan, a review should be triggered.
5.9 The assessment of whether a review is required should not be deferred to an annual position review in the
production of an Annual Monitoring Report. With specific triggers in place in line with the above suggestions, the
Council can clearly see a specifically the point at which a review is required and immediately report it to relevant
committees to approve.
5.10 We continue to have reservations over the effectiveness of an early review. Research3 shows that the in the
five years following the publication of 2012 NPPF, no early reviews that had been triggered within Post-NPPF
plans had been completed. Accordingly, we would support a commitment within the Local Plan that in the event
a review is triggered, the Council would submit to the Secretary of State its reviewed Local Plan within three
years of the original trigger.
3 Planned and deliver – Local Plan-making under the NPPF: A five-year progress report April 2017 (Lichfields)
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SUSTAINABILITY APPRAISAL
6.1 This section highlights the continued legal and soundness deficiencies of the SA process supporting the
emerging Local Plan.
6.2 During the Local Plan EiP, Wates raised significant issues in the soundness and legal compliance of the SA,
many of which have been identified by the Inspector, whilst others, such as the lack of consultation on the Post
Submission Interim Sustainability Appraisal Report (“August 2018 Report”), were put aside due to preceding
deficiencies that would render this immaterial.
6.3 We support the views of the Inspector that a bias was applied within the August 2018 Report in assessing the
Area of Search. The assumptions and scoring applied to the Area of Search options were unjustified, and without
support from robust evidence. This was evidently clear in the face of the assessment applied to reasonable
alternatives, such as those including an allocation for Pale Lane, which had been through the scrutiny of an
application determination process but were denied reflection that suitable mitigation was possible.
6.4 Accordingly, and as stated above, Wates supports the removal of Policy SS3 and all references to the Area of
Search within the Local Plan. We also support the removal of the Post Submission Interim Sustainability
Appraisal Report from supporting the Local Plan. However, the simple removal of these aspects has not rectified
deficiencies that remain within the February 2018 Sustainability Report and the SA as a whole, a key aspect of
which the August 2018 Report sought to rectify.
6.5 The August 2018 Report highlights the deficiencies of its February 2018 counterpart, stating its need to
supplement the work done to date in regards to SA. Paragraph 2.1.5 states:
“Indeed, the 2018 reasonable spatial strategy alternatives, as presented within Table 6.3 of the
SA Report remain suitably up-to-date other than in two respects –
Firstly, there is a need to factor-in the option of identifying a New Settlement AoS (see
discussion above, at para 1.1.3). Essentially, there is a need to add a new ‘variable’ row
to Table 6.3 of the SA Report, and in turn to assume that a New Settlement AoS will be
supported under some of the spatial strategy alternatives, and not under others.
Secondly, there is a need to reconsider the matter of reasonable higher growth options,
in light of the NPPF transitional arrangements published by Government in July 2018. In
effect, there is a need to revisit the conclusion reached at para 6.5.13 of the SA Report
that “490 dpa (Option 7) is a reasonable high growth option”.”
6.6 Paragraph 2.3.2 of the August 2018 Report expands on this second bullet, stating:
“The assumption was that supporting the higher growth option for all three variables (i.e. a spatial
strategy option involving 700 homes at Pale Lane, 700 homes at West of Hook, and 600 homes
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at non-strategic sites) would lead to an excessively large total growth quantum. However, this
conclusion was reached in light of an understanding of housing needs influenced by the standard
methodology / LHN figure of 292 dpa, more so than the higher SHMA OAHN figure of 382 dpa
(2014-2032) (albeit still mindful of the SHMA figure, see para 6.5.13). In light of the NPPF
transitional arrangements (July 2018) it is prudent to revisit this assumption and give more weight
to the OAHN figure than was afforded to it in the SA Report. Thus it is now considered reasonable
to test a new, higher growth option (Option 8) that would involve supporting the higher growth
option for all three variables listed in Table 2.1.”
6.7 Whilst we maintain that the full OAHN for Hart is far in excess of the figure derived in the SHMA, clearly the
Council felt that the February 2018 Report failed to fairly assess higher growth scenarios in the context of the
SHMA OAHN figure, concluding they would result in an excessively large total growth quantum. Accordingly, the
August 2018 Report would revisit this assessment in the context of a 382 dpa OAHN figure, adding a further
higher growth scenario that would deliver 525 dpa considered to be a reasonable alternative.
6.8 Both the Inspector and the Council have agreed a housing requirement for the Local Plan of 423 dpa, some 41
dpa greater than the figure identified by the August 2018 Report as justifying a reassessment of higher growth
options. Accordingly, the position taken by the August 2018 Report on the deficiencies of its February counterpart
are further exemplified.
6.9 The SA Report Addendum supporting the Main Modifications does consider the impacts of this increased
requirement. However, the Addendum is quick to point out that whilst the requirement has increased the supply
hasn’t, so therefore there are no sustainability effects. The Addendum reviews the assessment of the Local Plan
within the February 2018 Report in the context of the Main Modifications, concluding against all criteria that the
findings “broadly holds true”.
6.10 This raises two key issues:
The assessment of the higher growth options within the February SA 2018 is still deficient and have not
been reassessed within the Addendum; and
The conclusion the Local Plan with Main Modifications delivers significant positive effects against housing
when it fails to provide sufficient housing against the requirement cannot be considered sound.
6.11 An impartial and robust assessment of the Local Plan and alternatives to it would result in a recognition that
the preferred Spatial Strategy doesn’t fully comply with the objective to “provide all residents with the opportunity
to live in a decent home which meets their needs”. Simultaneously, it would conclude higher growth options both
meet this objective and wouldn’t represent an excessively large total growth quantum.
6.12 In accepting this position, it would be logical for the Council to follow the assessment of the February 2018
Report that concluded of the higher growth options, Option 2 – Pale Lane ranked as the most favourable.
Including Pale Lane within the Plan would provide a supply of just 6% over the housing requirement. This is
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considered a logical, even conservative buffer for Plan-making and would represent the most appropriate
strategy, in line with paragraph 182 of the NPPF.
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CONCLUSIONS AND RECOMMENDATIONS
7.1 Wates supports in principle the steps being taken by the Council through the publication of Main Modifications to
the submitted Local Plan following advice of the examining Inspector. The proposed amendments represent a
marked improvement from the submitted Local Plan. However, there are still deficiencies both within the Local
Plan and the supporting SA that go to the heart of soundness and legal compliance.
7.2 We support the conclusions of the Inspector and subsequent Main Modification to increase the housing
requirement to accommodate unmet need from SHDC. There is a clear evidenced need to do this at this time
and a failure to address this now would create a vacuum in which deteriorating affordability and access to
affordable homes would worsen. We agree with the Inspector that there is a likelihood this unmet need could
increase as SHDC progresses through its own Local Plan Examination. Accordingly, we support the provision of
a specific review trigger for this Local Plan to address any increase that is identified.
7.3 We maintain that the SHMA supporting the Local Plan contains fundamental faults and the full OAHN is actually
in excess of 500 dpa. There is a clear and agreed deficit of affordable housing in District, which would not be
addressed by the Local Plan in its current iteration. We do not agree a further increase to the housing
requirement, or an increase in the supply above the current proposed housing requirement in order to help deliver
more affordable housing would lead to unsustainable development, nor does the Council’s own evidence base
support these assertions.
7.4 Wates strongly supports the removal of Policy SS3 and supplementary references within the Local Plan. This
clearly represented a biased and unjustified commitment to a new settlement at Murrell Green/Winchfield that
sought to prejudice future growth within the District without fairly and robustly assessing the reasonable
alternatives to this.
7.5 The Main Modifications to the Local Plan would result in an unjustified housing supply deficit of 230 dwellings
against the proposed requirement. It has been demonstrated through the Examination that sustainable
development sites are available to the Council that would help meet this currently unmet need. Allocating Pale
Lane would result in a supply just 6% in excess of the requirement, a figure that would usually be considered a
conservative but pragmatic buffer. We do not agree that this would result in an excessively large and
unsustainable total growth quantum.
7.6 Given the fragility in the Local Plan, as well as the likelihood of an evolving housing need position4, we support
the inclusion of early review triggers within the Plan. We recommend amendments to those proposed triggers in
order to create clarity on when a review is to be undertaken. Furthermore, we would support a commitment from
4 Notably SHDC unmet need and Local Housing Need under the standard methodology.
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the Council that such a review would be conducted in an expedited manner, ensuring the key issues that triggered
a review are addressed.
7.7 Whilst we support the removal of the August 2018 SA Report as a supporting document to the Local Plan, this
had sought to rectify deficiencies of the February 2018 Report. The suggested removal of Policy SS3 does not
fully rectify these deficiencies and nor does the SA Addendum accompanying the Main Modifications.
7.8 The increase in housing requirement necessitates the assessment of the Local Plan Spatial Strategy, and
reasonable alternatives to it to be reassessed in the context of this higher requirement. The result of an objective
assessment would be that the current Spatial Strategy does not meet the objectives of the Local Plan, specifically
in relation to housing. The Council’s evidence points to the allocation of Pale Lane as the most sustainable of
the higher growth scenarios that would meet the objectives of the Local Plan.
7.9 Accordingly, we propose a further Main Modifications to include the Pale Lane site within the Local Plan,
supported by an updated and objective SA Addendum. This would result in the following benefits:
Meet the proposed housing requirement in full, reducing the likelihood for the need of an early review of
the Local Plan;
Create a modest buffer of 6% to provide flexibility in meeting the housing requirement;
Provide much needed affordable housing in an area that will continue to deliver far fewer than is the
evidenced need;
Deliver sustainable development in a location that has been shown to be capable of providing appropriate
supporting infrastructure including in relation to education and SANG; and
Align with the Local Plan Vision in directing growth to Fleet, developing its role as the main service centre
in the District.
7.10 In allocating Pale Lane, the Council would rectify existing deficiencies (subject to production of an appropriate
supporting SA and on the assumption the Inspector remains unmoved on his conclusions on OAHN), allowing
the Council to adopt the Local Plan and secure up-to-date planning policies, providing greater certainty in the
direction of future growth in the District.
Pg 1/7 Lichfields.uk 16656547v3
Hart Local Plan Examination 2018
Our ref
Date 25th October 2018
On behalf of
Subject Matter 3 – Housing: the objectively assessed need for housing and the housing requirement
3.1 Having regard to the transitionary arrangements contained in the
NPPF, 2018 is the use of the standard methodology for calculating housing
need justified?
1.1 The Council had concluded that the standard method would be used for the purposes of its plan,
prior to the final version of the NPPF confirming transitional arrangements. The Council’s Duty
to Co-operate Statement (CD9), published in June 2018, set out (para 17) that:
“Hart’s Plan is based on the standard methodology, having followed transitional
arrangements set out in the Government consultation ‘Planning for the right homes in the
right places’…”
1.2 However, the use of standard method is not justified. The NPPF 2018 (as published in final form
in July 2018) sets out very clear transitional arrangements at Annex 1, paragraphs 212-214. For
the purposes of plan-making, paragraph 214 is clear that:
“The policies in the previous Framework will apply for the purpose of examining plans, where
those plans are submitted on or before 24 January 2019…” (emphasis added).
1.3 As the Hart Local Plan was submitted before 24th January 2019, the plan’s housing need figure
should not derive in any way from the standard method, as the Council has done (noting that,
even then, it does not use the standard method figure without further adjustment). This was
raised in Wates’ response to the Regulation 19 Local Plan consultation (Policy SS1,
Representation ID 188). The Plan, and housing need and requirement, is to be examined and
tested against the NPPF 2012, and associated guidance.
1.4 It should also be noted that Government has stated its intention to revise the standard method,
to be consulted upon “before Christmas”. It is highly likely the standard method as it is currently
set out, will never actually apply for Plan Making purposes, so it would not be sound to place
weight upon it at this juncture. We note that precisely this point was made by the Inspector
determining one of the first s.78 appeals under the revised NPPF concerning housing needs1 (:
“Finally, Government guidance indicates that the new methodology for assessing the housing
needs is incomplete and so it would be premature to make and rely upon such an assessment.”
(APP/F2360/W/18/3198822 para 44)
1.5 The same reasoning applies with equal force in the present context. If the Council is to follow
through the logic of its decision to apply new standard method rather than an OAN assessment
pursuant to the 2012 NPPF, then the application of the standard method will necessarily be
informed by the anticipated changes to it.
1 APP/F2360/W/18/3198822, Land of Brindle Road, Bamber Bridge, Preston PR5 6YP (31 August 2018)
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3.2 Does the use of the standard methodology fulfil the requirements of the
first bullet point of paragraph 47 of the NPPF, 2012?
1.6 No, the use of the standard method does not fulfil the requirement of paragraph 47 of the NPPF
2012 – but nor does it claim to do so. There is an important distinction between the NPPF 2018
(para 60) which requires plans to be informed by an assessment of “local housing need”
conducted using the standard method and the NPPF 2012 (paras 47 and 159) which requires
authorities to identify “objectively assessed need” for housing within a SHMA in line with the
PPG 2014. They are two different constructs in national policy.
1.7 Paragraph 47 of the NPPF 2012 sets out that local authorities should use their evidence base to
ensure their Local Plan meet the full, objectively assessed need (OAN) for market and affordable
housing in the housing market area (HMA), while paragraph 159 sets out what this evidence
base should address (including migration and demographic change, all types of housing and
housing demand). The PPG accompanying the NPPF 2012 provides further information on
assessing need and identifies that an OAN should fulfil the following criteria, and these are the
bases for HOU1a (“the SHMA”):
Be proportionate and consider only future scenarios that could reasonably be expected to
occur (ID 2a-003);
Be based on facts and unbiased evidence. Constraints should not be applied to the
assessment of need (ID 2a-004);
Utilise household projections published by DCLG as the starting point (ID 2a-015);
Consider sensitivity testing, specific to local circumstances, based on alternative
demographic projections and household formation rates (ID 2a-017); and
Take account of employment trends (ID 2a-018), market signals (ID 2a-019) and affordable
housing needs (ID 2a-029).
1.8 By contrast, the standard method uses just two metrics – household growth and the
affordability ratio - to produce a minimum housing figure which becomes the starting point for
the overall housing requirement. This does not purport to represent full OAN in line with the
previous framework or guidance, which addresses the factors set out above. The PPG 2018
clarifies that the standard method:
“… uses a formula to identify the minimum number of homes expected to be planned for, in a
way which addresses projected household growth and historic under-supply. ….” (PPG 2018,
ID 2a-002)
1.9 The standard method does not account for (or claim to account f0r) several factors which inform
an OAN. Separate provisions are made within the PPG 2018 to address factors which may lead
to a higher requirement figure than the standard method (see PPG 2018 ID 2a-010), but these
are not part of the standard method for determining the minimum housing need figure. The
differences are summarised below.
Demographic-led needs
1.10 The standard method (and PPG 2018) does not allow for a departure from the official household
projections as the starting point, unless ‘exceptional circumstances’ have been demonstrated. By
contrast, the PPG 2014 at ID 2a-015 and ID 2a-017 states that plan-makers should address
factors such as past under-delivery of housing in the demographic-led assessment of need which
are not reflected in official projections. These adjustments to the demographic projections in the
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PPG 2014 are in addition to addressing market signals, which is a separate part of the
assessment, set out at ID 2a-019/020.
Market signals
1.11 A market signals uplift of sorts is present in both the PPG 2014 OAN methodology (as market
signals) and the standard method (as the affordability uplift). However, the standard method
applies a fixed percentage uplift based on the affordability ratio, whereas the PPG 2014 requires
addressing a wider range of market signals (prices, rents, affordability, land values,
homelessness/overcrowding) and provides no guidance as to what scale should be applied, only
that plan-makers should “…increase planned supply by an amount that, on reasonable
assumptions … could be expected to improve affordability…” (PPG 2014 ID 2a-020). Therefore,
an element of judgment is needed as to what scale this could be.
Employment-led needs
1.12 The PPG 2014 is clear at ID 2a-018 that plan-makers will need to consider the location of
housing where there is a mismatch between likely job growth and the supply of economically
active residents. In practice, this means making an uplift to the OAN in areas where there is
expected to be a shortfall in workers; an adjustment and consideration absent from the standard
method.
Affordable housing needs
1.13 An assessment of/uplift for affordable housing needs is also absent from the standard method
(an uplift for this may be considered, but it is separate to the standard method calculation). By
contrast, it has been clarified by the courts (see King’s Lynn2) that under the PPG 2014
methodology, affordable housing needs should have an “important influence” on the OAN:
“This [at PPG ID 2a-028] consideration of an increase to help deliver the required number of
affordable homes, rather than an instruction that the requirement be met in total, is consistent
with the policy in paragraph 159 of the Framework requiring that the SHMA “addresses” these
needs in determining the FOAN. They should have an important influence increasing the
derived FOAN since they are significant factors in providing for housing needs within an
area.” (King’s Lynn, para 33) (emphasis added)
1.14 King’s Lynn accepts that in some cases meeting affordable housing needs in full might lead to an
unrealistic figure (see King’s Lynn para 32) (indeed the PPG 2014 clarifies that OAN
assessments should not consider purely hypothetical scenarios at ID 2a-003). But where it is
necessary, possible and reasonable to make an uplift to deliver more affordable housing needs,
consideration of this should form part of the OAN in an assessment under PPG 2014.
1.15 In summary, an OAN undertaken in line with the NPPF 2012/PPG 2014 cannot simply be
substituted with the standard method (as the Council has done) because of the fundamental
differences in inputs, methodology and outputs.
2 Borough Council of Kings Lynn and West Norfolk v Secretary of State for Communities and Local Government, ELM Park Holdings Ltd [2015] EWHC 2464 (Admin)
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3.3 Is uplifting the housing requirement by some 33% above that calculated
by the standard methodology to 388 dwellings per annum justified? What
evidence are the uplifts based on?
1.16 The Council has applied an uplift of 33% to the – incorrectly used - standard method figure.
Therefore, the figure of 388 dpa is inherently flawed because it derives from a figure which
should not be used in the first place.
1.17 The uplift of 33% is the overall uplift from the original standard method figure (292 dpa) to the
final figure of 388 dpa. The 388 dpa is arrived at as set out in Appendix 2 of CD1 – based on the
standard method figure of 292 dpa, uplifted to 310 dpa (having removed the cap) and uplifting
310 dpa by a further 25%, giving 388 dpa.
1.18 The basis for uplifting by 25% appears to be arbitrary – the reference to the 25% appears in
Appendix 2 of CD1 (and TPO1 page 7) but there is no substantive reasoning for this precise
figure. We consider a large uplift is likely necessary to meet the ‘reasonably be expected to
improve affordability’ test in the PPG 2014, but there is no justification why the uplifts proposed
are the right scale to address the acute housing need issues in the District.
3.4 Does or should the housing requirement formally include any unmet
need from Surrey Heath?
1.19 The housing requirement does not include any unmet need from Surrey Heath with the
Council’s reasons set out in TOP1 (paras 4.6-4.14). However, none of these reasons withstand
basic scrutiny. The omission of any unmet need in Hart’s housing requirement was an issue
highlighted in the representations made by Wates to Policy SS1 p.6 at Regulation 19 stage.
1.20 Firstly, the housing requirement should include unmet need from Surrey Heath because the
NPPF 2012 (against which the Hart Local Plan is to be examined, as per Annex 1 of the NPPF
2018) is clear that:
“To boost significantly the supply of housing, local planning authorities should…use their
evidence base to ensure that their Local Plan meets the full, objectively assessed needs for
market and affordable housing in the housing market area…” (NPPF 2012, paragraph 47)
(emphasis added)
1.21 It is not adequate to dismiss unmet need because there is apparently no shortfall against the
standard method (as the Council currently does at para 4.8 of TOP1) – the standard method
does not currently apply for the purposes of plan-making in Hart and unmet need should be
measured against an OAN contained within a SHMA. This is another significant error in the
Council’s Duty to Co-operate Statement (CD9) which incorrectly states at paragraph 12 that the
housing numbers in the Hart Plan should be based on the standard method. In any case, the
standard method is subject to change imminently3, and it is premature to draw conclusions
about what figures it might produce in the future now; the Council should address what is
known now.
1.22 Surrey Heath’s current plan comprises the Core Strategy which contains a housing requirement
(Policy CP3) of 3,240 dwellings 2011-28, equivalent to 190 dwellings per annum. The SHMA
(HOU1) identified Surrey Heath’s OAN to be 382 dpa 2014-32 (HOU1a para 35)4. This means
3 As clarified in the Government statement accompanying the NPPF in July 2018, published as part of the 2018 PPG. 4 Rushmoor Council is currently consulting main modifications to its emerging plan which meets its OAN as set out in the SHMA. Once adopted, no unmet need against the OAN will exist from Rushmoor in the HMA.
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that since the base date of the SHMA (i.e. 2014) a backlog of need has been accruing within the
housing market area, at a rate of 198 dwellings per annum. This is not being met in Rushmoor5.
This is need which is going unmet through plans now and should be addressed in the Hart Local
Plan in order for the Council to demonstrate that the plan meets paragraph 47 of the NPPF
2012.
1.23 Notwithstanding that existing unmet need should be measured against OAN in HOU1, it also is
unjustified to not meet needs arising now on the assumption that future unmet needs may
reduce or disappear altogether because more sites may be found in Surrey Heath. The Council
cannot evidence or demonstrate with any certainty that future unmet needs will diminish, and
should prepare its plan based on evidence of need and supply now. That evidence of need should
be based on a SHMA (e.g. HOU1) and supply based on the planned housing requirements set
out in the local plans for the area. On these bases, there is unmet need in the HMA which Hart
should meet.
1.24 Furthermore, given the constraints that exist across the HMA (with Surrey Heath largely
constrained by Green Belt, Rushmoor largely urbanised and Hart relatively unconstrained) it
would not be unreasonable for Hart to provide for unmet need from Surrey Heath; that at least
should be tested through a Sustainability Appraisal addressing the HMA’s unmet need. The
Surrey Heath Final Draft Issues and Options Local Plan states (para 3.17) that Surrey Heath
Council do not consider that exceptional circumstances have been demonstrated in order to
release green belt because alternative approaches – i.e. meeting needs elsewhere in the HMA –
should be considered first.
1.25 A very similar situation has recently been explored in Waverley6 where no provision to meet
Woking’s unmet need was made citeding similar reasons to Hart Council (e.g. unmet need was
not arising until later in the plan period, Woking may be able to increase supply, etc). The
Inspector rejected those arguments, stating:
“…the NPPF states that local planning authorities should meet the objectively assessed need
within their housing market area… Waverley…is significantly less constrained…making no
allowance in Waverley for Woking’s unmet need is therefore not a sound position.
The under provision exists now and has been growing since the start of Woking’s plan period;
it needs to be addressed. It is true that any future review of Woking’s local plan will provide an
opportunity to re-examine housing opportunities and adjust its assessment of unmet need
against a new OAN calculation, but it is very clear from Woking Borough Council’s evidence…
that the town will very probably remain unable to accommodate a significant proportion of its
OAN in the future…” (Waverley Local Plan Inspectors’ Report February 2018 paras 27-30)
1.26 Similarly, the Mid Sussex Local Plan was required to increase its housing requirement to
address almost all of the unmet need from neighbouring Crawley, after the Inspector7 noted
limited opportunities in other authorities.
1.27 On the basis of the requirements of the NPPF 2012 (particularly para 47) the Hart plan is
unsound because it is not demonstrating how needs are being met across the housing market
area.
5 Rushmoor’s emerging plan is currently undergoing main modifications and is expected to be adopted soon. It plans to meet solely Rushmoor’s own needs (as per HOU1a) and does not make provision for unmet need from Surrey Heath 6 Waverley Local Plan Part 1 Inspector’s Report published February 2018 http://www.waverley.gov.uk/downloads/file/5963/waverley_local_plan_part_1_examination_inspectors_report 7 https://www.midsussex.gov.uk/media/2892/id11-inspectors-interim-letter-housing-20-feb-17.pdf
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3.5 If the use of the standard methodology for calculating housing need
was considered to be inappropriate, is the objectively assessed need figure
of 382 dwellings per annum set out within the Strategic Housing Market
Assessment (SHMA) robust?
1.28 No, the OAN of 382 dpa set out in the SHMA (HOU1a, see also HOU2a) is not robust. We
explore this in further detail in our Technical Appendix, but in summary:
1 Neither the 2012-based nor the 2014-based population/household projections are suitable
for the purposes of assessing housing need in Hart because they draw upon migration from
a period in which housebuilding was at historic lows in the District (see Technical Appendix
Figure 1). These historic lows were not due to factors which might occur again (for example,
market cycles), rather an artificial constraint which was placed on housing supply by the
Council;
2 As per PPG 2014 ID 2a-015 the assessment of need should reflect this. Whilst HOU2a
attempts to address this issue by presenting scenarios based on longer term migration
trends (10 and 15 years), these periods still encompass the years in which the moratorium
was in place, having a dampening effect on the average level of completions (and therefore
migration) (see Technical Appendix Figure 3). Therefore the basis of the OAN assessment –
the demographic-led needs – is flawed (also affecting any elements flowing from it or
applied to it, including a market signals uplift or affordable housing needs assessment).
These points regarding issues around the housing moratorium and the effect on projections
were raised in Wates’ representations Regulation 19 Local Plan consultation, see response
to Policy SS1 p.5; those representations note that prior to 2008 average completions had
been around 374 dpa.
As shown in Figure 3 of the Technical Appendix, even the 15 year scenario presented in
HOU2a (see HOU2a Figure 2) draws upon a period which includes the moratorium where
completions were much lower than this, at just 339 dwellings per annum. Therefore even
the 15 year scenario, which suggests a demographic-led need of 301-323 dpa (as shown in
Table 1 of this Technical Appendix) is below what should be considered the minimum
demographic-led projection;
3 The scale of market signals uplift applied in the SHMA is not one which, on reasonable
assumptions, could be expected to improve affordability. The method – of applying a fixed
percentage uplift to the official projections – will in any event produce an inherently flawed
number because of the fundamental problems with those projections;
Again, this issue was raised in the Wates’ representations cited above whereby an
alternative approach which was based on a percentage dwelling stock growth was
presented. This shows that at a rate of 1.3% per annum (which is the rate needed nationally
to achieve 300,000 homes per annum) would be 507 dpa for Hart (see representations p.5),
but that because Hart’s affordability ratio was worse than nationally, a greater uplift would
be needed to have an impact on affordability.
This approach is reasonable because basing the housing number on existing stock as a
starting point means the number is not affected by any flaws found in the projections (as is
the case in Hart). As set out in para 3.16 of the Technical Appendix, higher rates (of 1.3%)
would not be beyond what could be expected to occur given growth rates elsewhere, notably
Cherwell and Aylesbury Vale. There is no reason why a similarly high rate of growth is
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undeliverable in Hart – by way of example a rate of 1.5% per annum would yield 584 dpa
for Hart;
Alternatively, were the correct demographic-led projection established, it might be
appropriate to make a fixed percentage uplift in a similar way to CD1 Appendix 2 (which
makes a 33% uplift for various market signal type factors).
4 The Council has deferred affordable housing needs from the SHMA (HOU1a) to its
Affordable Housing Background Paper (HOU5), and believes they form part of the
requirement and not the OAN. King’s Lynn makes it clear that affordable housing needs
should influence the OAN, given they are an important element of meeting needs within an
area. The fact that the Council’s considers 485 dpa to be deliverable means this should
inform the OAN, not the requirement – albeit in the context of a Local Plan this is moot;
NPPF 2012 para 47 compels Local Plans to seek to meet the full OAN for market and
affordable housing.
1.29 In order to fulfil the requirements of the NPPF 2012/PPG 2014, there are several elements of
OAN which must be addressed in the Council’s evidence but currently are not; as a result the
OAN of 382 dpa is a significant under-estimate. The requirement of 485 dpa in HOU5 is
evidence that in the Council’s own view, its OAN could have been higher, but this still represents
a very modest growth rate for an area as unaffordable as Hart.
1.30 In our view, a housing figure informing the Plan of at least c.500 dpa would be a figure which
addresses past-under delivery, delivers at a rate of 1.3% of stock (507 dpa) which could be
expected to improve affordability and provides an uplift which would contribute to meeting the
District’s severe affordable housing needs (485 dpa), all the while being a level which could
reasonably be expected to occur. This level of housebuilding has been observed and exceeded
numerous times in recent years in Hart without there being a plan in place, there is no reason
why putting a plan in place could or should not increase and sustain delivery to these levels.
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Technical Appendix – Matter 3
Our ref
Date 25th October 2018
Subject Objectively Assessed Housing Need and the Housing Requirement - Hart
1.0 Introduction
1.1 This Technical Appendix has been prepared by Lichfields on behalf of Wates Developments
Limited (Wates) in the context of the emerging Hart Local Plan (PSLP). It provides further
detail on our response to Matter 3: Housing: the objectively assessed need for housing (OAN)
and the housing requirement.
1.2 As Hart’s PSLP has been submitted before 24th January 2019, it will be examined against the
NPPF 2012 (and PPG 2014), as per the transitional arrangements set out in Annex 1 (para 214)
of the NPPF 2018. Therefore we have reviewed the Council’s evidence against the requirements
of the NPPF 2012/PPG 2014, which are summarised at our response to question 3.2 in the
Matters Statement.
2.0 Summary of Council’s evidence to date
2.1 The Hart Proposed Submission Local Plan (PSLP) (CD1) covers the period 2016-32 and Policy
SS1 “Spatial Strategy and Distribution of Growth” sets out that the plan will meet the need for
6,208 homes 2016-32 (388 per annum). Table 1 of the PSLP shows a supply of 6,346, equating
to a small buffer of 2% over the requirement. The PSLP (para 101/Appendix 2) states that this
figure is based on:
1 The Standard method figure as published September 2017 – 292 dpa;
2 Removal of the cap as the Council is confident it can deliver more than 292 – giving 310
dpa; and
3 A further 25% uplift applied giving 388 dpa. Appendix 2 states that this is based on
contingency allowances, flexibility, affordable housing supply, etc.
Hart, Rushmoor and Surrey Heath SHMA 2014-32, November 2016
(HOU1a)
2.2 HOU1a (“the SHMA”) undertook the assessment of need based on the PPG 2014 for Hart,
Rushmoor and Surrey Heath (“the housing market area/HMA”). It assessed the need for Hart to
be 382 dpa (with the HMA OAN 1,200 dpa), based on:
1 A starting point based on the 2012-based population/household projections) giving 254 dpa
for Hart and 785 dpa for the HMA;
2 A market signals uplift of 15% giving 292 dpa for Hart and 903 dpa for the HMA;
3 Employment-led needs – based on growth of 1,200 jobs per annum, this generated a need
for 361 dpa Hart (1,135 dpa HMA) (this includes some allowance for headship rate uplift –
see SHMA Figure 11.17);
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4 No further uplift for affordable housing, but OAN rounded up to 1,200 dpa for HMA, giving
382 dpa for Hart.
Hart, Rushmoor and Surrey Heath SHMA – Summary and Discussion of
OAN in the light of DCLG’s proposals and updated data, December 2017
(HOU2a)
2.3 HOU2a presented alternative scenarios based on consultation responses to the SHMA, using the
2014-based projections (published in 2016), longer term migration trends and partial catch-up
headship rates. The outcomes of these scenarios for Hart and the HMA (in terms of dwellings
per annum 2014-32) are shown below.
Table 1 Summary of alternative figure (dwellings per annum) in HOU2a
Hart HMA
Dwellings per annum
Dwellings per annum
November 2016 SHMA Starting Point 254 785
DCLG 2014-based Projections 212 686
with headship rate adjustment 232 767
DCLG 2014-based Projections, updated with MYEs 218 724
with headship rate adjustment 239 805
10 Year Migration 230 710
with headship rate adjustment 251 790
15 Year Migration 301 751
with headship rate adjustment 323 833
Employment-led (1,200 jpa) 311 1,022
with headship rate adjustment 334 1,110
Source: HOU2a Figure 2
2.4 HOU2a concluded that neither the updated projections nor the alternative migration scenarios
provided a justification to amend the OAN set out in the SHMA (HOU1a), and therefore the
OAN for Hart and the HMA remained as in the previous SHMA (382 dpa for Hart, 1,200 dpa
across the HMA). HOU2a also noted that as published in September 2017, the standard method
yielded 293 dpa for Hart (939 dpa for the HMA), or 310 without the cap applied (989 for the
HMA). This is below the 382 figure (1,200 HMA) concluded in the SHMA and no changes to the
housing figures were recommended in HOU2a (this would have been premature in any case,
because the transitional arrangements for the NPPF 2018 had not yet been made clear).
Affordable Housing Background Paper, March 2017 (HOU5)
2.5 HOU5 sets out the Council’s response to affordable housing need and the additional dwellings
per annum it was seeking to provide over and above its OAN of 382 dpa. It re-iterates the
findings in HOU1a, i.e. that there is a shortfall of 306 affordable homes per year to 2032 (based
on HOU1a, see HOU5 Table 2.2)
2.6 HOU5 explores various scenarios of overall delivery and affordable housing delivery (up to 750
dpa total) and recommends an increase in the housing requirement from 382 dpa (the OAN set
out in HOU1a) to 485 dpa (representing a 27% uplift). It concludes that this could deliver 194
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affordable homes per annum in total, contributing to meeting more of the identified affordable
housing need.
2016-based Sub-National Population Projections and housing need using
the ‘Standard Method’, June 2018 (HOU8) (JGC)
2.7 A further paper – HOU8 -was prepared on behalf of the Council in June 2018 to provide an
update based on the recently published 2016-based population projections and the standard
method. As the 2016-based household projections had yet to be published, HOU8 sets out an
estimate of what the 2016-based household projections might produce by using applying the
2014-based headship rates to the 2016-based population projections. It estimates that the 2016-
based household projections would yield growth of around 200 per annum over a 10 year
period.
2.8 HOU8 notes that Hart would be subject to a 50% (uncapped) uplift under the standard method,
which when applied to a starting point of c.200 dpa would give c.300 dpa (depending on exactly
which period/household projection figure is used). When capped (at 40% uplift) the figure
derived from the standard method for Hart would be c.280-290 dpa (see Figure 12 of HOU8).
2.9 HOU8 does not set out the potential implications for OAN in Hart, potential implications for the
plan requirement or how the figure relates to previous SHMAs which have looked at OAN in the
context of current PPG (including employment, etc). HOU8 is simply a statement of fact
regarding what the new projections/standard method might produce for Hart and does not
appear to have fed into the requirement in the PSLP.
Summary
2.10 The Council had previously been advancing its plan – and has submitted evidence for
examination – based on an OAN derived from the NPPF 2012/PPG 2014. In the context of the
transitional arrangements set out at paragraph 214 of the NPPF 2018, the Council should
continue to advance its plan on this basis. However, the Council has – incorrectly – changed its
approach in the plan, to a housing figure which derives from the standard method. This is
directly contradictory to the transitional arrangements set out in NPPF 2018 Annex 2.
2.11 In any case, the Council’s current evidence which purports to follow the PPG 2014 methodology
(as set out in HOU1a/HOU2a) which concludes on an OAN of 382 dpa and a requirement of 485
dpa is not robust and is not an appropriate basis for an OAN for Hart, for the reasons set out in
Section 3.0 below.
3.0 Review of Council’s evidence (HOU1a, HOU2a and HOU5)
Demographic-led Needs
3.1 The Council’s OAN, as set out in the SHMA (HOU1a), is based on employment-led figure, which
exceeds the demographic-led needs plus a market signals uplift. However, the demographic-led
needs in Hart are inherently flawed because recent migration trends are affected by the housing
moratorium was in place (put in place to allow for a mitigation strategy for the Thames Basin
Heaths Special Protection Area to be implemented).
3.2 Figure 1 shows net completions in Hart since 1996/97. Prior to the moratorium being in place,
the lowest level of housebuilding was seen in 1998/99, when 163 dwellings were completed.
After that, completions steadily rose to a high of 642 in 2004/05. Completions fell to their
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lowest in 2009/10, when there -17 net completions, and across the three years 2008/09 to
2010/11, a total of just 105 dwellings were completed (c.35 per annum on average). Figure 1 also
shows the average number of completions in the years feeding into the 2012-based and 2014-
based population projections1 – which form the basis for Council’s evidence in HOU1a and
HOU2a. Even though the base period for the 2014-based projections included some years in
which completions were recovering, the average number of completions was still only 168 per
annum – brought down by the extremely low level of completions seen when the moratorium
was in place. This is a very low average in the context of housing delivery levels seen before (in
the early 2000s) and since (in the mid-2010s).
Figure 1 Net Completions in Hart 1996/97 to 2017/18
Source: Hart District Council AMR/Five Year Land Supply Statement
3.3 Figure 2 shows that migration trends in Hart have broadly followed trends in housing
completions, with a notable peak in the mid-2000s (when completions were at their highest),
before falling (particularly internal migration) in the late-2000s (when completions reached
their lowest). Migration in recent years has very slowly been increasing, although not in line
with the scale of completions. This could be, for example, because recent housebuilding in Hart
has been releasing pent up demand from within the District, rather than there being a
resumption of net in-migration.
3.4 However, it is evident that any demographic trend which draws upon the period where
completions were at their historic, artificial low (i.e. 2008/09 to 2010/11) will be carrying
forward levels of unusually low migration as a result.
1 ONS sub-national population projections are informed by the preceding 5 years of trends for internal migration and 6 years for international migration.
2012-based SNPP, 132
2014-based SNPP, 168
-100
0
100
200
300
400
500
600
700
800
Ne
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mp
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ons
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Figure 2 Migration (Internal, International and Total) - Hart - 2001/02 to 2016/17
Source: Lichfields based on ONS
3.5 The Council’s evidence attempts to address this issue, notably in HOU2a, which presents 10 and
15 year migration trend scenarios (drawing upon the periods 2006-16 and 2001-16 respectively).
The use of longer term trends might be appropriate when attempting to account for cyclical
factors such as market cycles, but is less useful in understanding long term trends where they
include a period in which a specific policy constraint on housing was in place. Unlike market
cycles, such an event is unlikely to occur again, therefore to assess future needs based on this
event would be an unrealistic estimate of future need.
3.6 As shown in Figure 3 the use of a 10 year trend still incorporates all of the years in which the
moratorium was in place, and completions averaged 256 per annum. The use of a 15 year period
covers a period where net completions were slightly higher (339 per annum), but again still
incorporates all of the years in which the moratorium was in place. Had the moratorium not
been in place, completions almost certainly would have not fallen to the levels observed (even
with the recession) and the average level of completions (and therefore migration) across all the
base periods would have been higher.
-400
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Figure 3 Net housing completions in Hart across various base dates
Source: Lichfields based on Hart District Council
3.7 By way of example, were the level of housing completions between 2008/09 and 2010/11
replaced with alternative figures, for example the previous low of 163 observed in 1998/99, the
15 year average would have been around 373 dwellings per annum. Even this is likely to be
conservative estimate given that completions would have been unlikely to fall to historic lows
and remain at those levels for 3 years, however it serves to demonstrate that projections based
on either the official projections or the alternatives set out in HOU2a are not appropriate
because they do no address past under-delivery of housing in Hart, thus failing to address PPG
ID 2a-015.
Summary
3.8 The SHMA (HOU1a) does not represent a robust basis for OAN for the purposes of Hart’s plan
because it has not addressed historic under-delivery associated with the moratorium and the
consequent impact of this “one off event” on the demographic projections as required by PPG
2014 ID 2a-017. Even the 15 year scenario does not robustly address the issue of the housing
moratorium, and therefore the true scale of demographic-led needs is higher than the 15-year
trend scenario (which suggests a minimum demographic-led need for 301-323 dpa for Hart).
Market Signals
3.9 The principle of a market signals uplift is not in dispute; HOU1a accepts that an uplift is needed
and applies a 15% uplift to its starting point. However, there are two fundamental flaws with the
SHMA’s approach:
1 The ‘typical’ approach (of applying a given percentage uplift to household projections) will
only produce a robust figure if the household projections themselves are reasonable in the
first place. For the reasons set out above, they are evidently not; and
2012-based SNPP, 132
2014-based SNPP, 168
15 Year - 2001-16, 339
10 Year - 2006-16, 256
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2 The scale of uplift is not one which on reasonable assumption could improve affordability,
as required by PPG 2014 ID 2a-020.
Applying a percentage uplift to demographic projections
3.10 Lower quartile house prices in Hart are currently (as of 2017) 14.4 times work-place based
earnings; a ratio which has risen significantly in the last few years. Looking at several recent
Inspector’s reports from elsewhere across the wider South East shows that the 15% market
signals uplift applied in Hart is low in comparison:
1 Waverley – Inspector’s Report dated February 20182. The Inspector noted that in Waverley
the affordability ratio had worsened from 13.1 at the start of the plan period to 15.5 and was
one of the least affordable areas outside London (IR para 20). On this basis, an uplift of
25% was applied;
2 Mid Sussex – Inspector’s Interim Findings on the housing requirement published in
February 20173. Citing worsening affordability since 2009, a ratio (as of 2015) of 12.6 and
Mid Sussex being the 22nd least affordable authority outside London, the Inspector applied
a 20% uplift (see IR p. 6);
3 Canterbury – Inspector’s Interim Findings dated August 2015. The Council’s evidence
(prepared by Lichfields) at the time was based on the affordability ratio up to 2013, which
was around 9.0 and had been fairly steady since the recession. At the time of preparing the
Council’s evidence, little precedent existed as to what scale of uplift should be applied.
Lichfields concluded that pressures in Canterbury were worse than the ‘modest’ pressures
in Eastleigh (where a 10% uplift was recommended4), and applied a 20% uplift; this was
subsequently accepted by the Inspector5;
4 Cambridge/South Cambridgeshire – Inspector’s Reports published September 2018.
The Councils’ evidence6, published in 2015 and referring to data from 2013, concluded
that the affordability situation in Cambridge was similar to that in Canterbury and
applied a 30% uplift. In 2013, the ratio in Cambridge was around 10.07. The Inspectors’
Report for Cambridge8 stated that a 30% uplift represented a ‘substantial but
reasonable’ uplift (IR para 29).
For South Cambridgeshire, the Council’s evidence concluded pressures were similar to
‘modest’ pressures in Eastleigh and Uttlesford – as of 2013, the affordability ratio in
South Cambridgeshire was just under 9.0. The Council applied a 10% uplift, which was
subsequently accepted by the Inspectors9.
3.11 The affordability ratio in Hart (in terms of lower quartile house prices to lower quartile
workplace-based earnings) has steadily risen following the recession from around 9.4 in 2009 to
over 14 now. This compares to a ratio nationally of 7.3 – which has been stable for around 10
years. Figure 4 below shows how the ratio in Hart has compared to the above areas since 2009.
2 http://www.waverley.gov.uk/downloads/file/5963/waverley_local_plan_part_1_examination_inspectors_report 3 https://www.midsussex.gov.uk/media/2892/id11-inspectors-interim-letter-housing-20-feb-17.pdf 4 The Eastleigh Local Plan in which the Inspector suggested a 10% uplift was found unsound and did not continue to adoption. 5 It is important to note that the overall uplift applied in Canterbury to reach the final OAN – once market signals, employment and affordable housing were accounted for – was 30%. However, the 20% proposed for market signals alone was accepted. 6 https://cambridge.blob.core.windows.net/public/ldf/coredocs/rd-mc-040.pdf 7 The Council’s evidence ‘Objectively Assessed Need: Further Evidence (November 2015)’ shows (Figure 3.4) a ratio of just over 10.0 as of 2013. However this was based on data published by DCLG, and ONS have since taken over the publication of affordability data, resulting in some revisions. The current ONS data shows in 2013 the ratio for Cambridge was 9.87 8 https://www.cambridge.gov.uk/media/5930/report-on-the-examination-of-the-cambridge-local-plan-2014.pdf 9 https://www.cambridge.gov.uk/media/5931/report-on-the-examination-of-the-south-cambridgeshire-local-plan.pdf para37
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Evidently, affordability has been steadily worsening across all areas, but the ratio in Hart is now
amongst the worst areas outside London. Hart now stands at a similar level to Waverley, Mid
Sussex and Cambridge where 25%, 20% and 30% uplifts respectively were applied (albeit these
uplifts were applied when affordability may have been slightly different to the current level).
However, this does indicate that – based on an appropriate demographic starting point, an
uplift in the region of 20-30% is likely to be needed in Hart. Given that a 20% uplift was applied
in Mid Sussex at a time when affordability was relatively better (at 12.6), applying an uplift at
the top of this range – i.e. 30% would better reflect the severe situation in Hart currently.
Figure 4 Comparison of affordability ratios - Hart and comparator areas
Source: ONS
3.12 It has already been established above that the official projections and the alternative presented
in HOU2a do not address previous under-delivery and therefore underestimate future
demographic-led needs in Hart. However, were the Council to correctly establish its
demographic-led needs, based on migration and housebuilding levels which are not dampened
by the moratorium, then a market signals uplift in the region of 30% (not the 15% applied in
HOU1a) is one which (based on comparators) could reasonably be expected to improve
affordability. Indeed, the Council themselves apply a 33% uplift above the standard method
figure (CD1 page 141) in order to account for many of the same issues which the NPPF 2012’s
market signals adjustment (NPPF para 17 bullet 3 and PPG 2014 ID: 2a-019) seeks to account
for (e.g. affordability, rates of delivery, the benefits of boosting housing supply).
Stock-based approach
3.13 Wates’s representations to the Regulation 19 consultation (see response to Policy SS1 p.5-6)
present a stock based approach to a market signals uplift which is a suitable approach for
benchmarking market signals uplifts in Hart because it does not depend on the official
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projections, which in the case of Hart are influenced by a period of artificially suppressed
housing delivery.
3.14 For context, the 2012-based projections which underpin HOU1a suggest a need for 254 dpa in
Hart (see HOU1a Figure 8.24). 254 dpa represents just 0.65% of the current dwelling stock in
Hart, therefore even with an apparently ‘significant’ uplift (such as 30%) this will still yield a
relatively small number which is a small percent of the current stock, and unlikely to have a
significant influence on affordability.
3.15 For context, a growth rate nationally of 1.3% is needed to achieve 300,000 homes per year; the
Government’s target at which it considers it might be able to address affordability. Hart is
significantly less affordable England overall (as shown above, as of 2017 it is in fact twice as
unaffordable), and therefore as a minimum it would be reasonable to expect Hart to deliver its
‘fair share’, i.e. 1.3% annually. Were Hart just to deliver the national average (i.e. 1.3%) this
would equate to 507 dpa. 507 dpa represents almost double the household projections (i.e. an
uplift of 100% - appearing to be very significant indeed), but in the context of a very low starting
point, 507 dpa would actually represent an average growth rate in line with the national average.
In other words, because the starting point in Hart is so low, even a 100% uplift would not
actually generate a figure which is unreasonable.
3.16 Given the significant affordability issues in Hart, it would be entirely reasonable – indeed
necessary – for Hart to see a greater rate of growth than the national average (in the same that
areas of lower demand could reasonably be expected to deliver less than 1.3% growth per year).
By way of example, a rate of 1.4% would yield 545 dpa and 1.5% would yield 584 dpa. These
rates of growth are not unreasonable in the context of growth rates in plans elsewhere in the
South East, notably Cherwell and Aylesbury Vale. Cherwell’s adopted Local Plan has a growth
rate equivalent to 1.8%, which is set to increase further when it undertakes its Local Plan Review
to accommodate its share of Oxford’s unmet needs. More recently, the Inspector into the Vale of
Aylesbury Local Plan 2013-33 has found that the Plan’s requirement should be increased to
31,500, equivalent to 1,575 dpa, or growth of 2.0% per annum. Evidently such levels of growth
have been deemed reasonable and deliverable by Inspectors, and there is no reason to conclude
that Hart could not also sustain a rate of growth of atleast 1.3%.
Summary
3.17 The approach in HOU1a to market signals is flawed because it applies a percentage uplift to a
flawed starting point, and if this approach were to be used it is imperative that the starting point
is correct. Our analysis suggests that an uplift of 15% is insufficient for Hart based on the scale of
affordability pressures and the uplifts applied elsewhere, and that (if the correct starting point
were established) an uplift in the order of around 30% would be more appropriate.
Alternatively, a stock-based approach provides a benchmark for what level might be reasonable
– at 1.3% (the national average needed for 300,000 homes per annum) the figure for Hart
would be 507 dpa. Growth rates as high as 1.8-2% have been seen elsewhere, and there is no
reason why Hart could not deliver 1.3% per annum (507 dpa), particularly given these rates have
been seen several times historically in Hart without there being a plan in place.
3.18 The PPG 2014 is clear that uplifts for market signals should be those which on reasonable
assumptions could be expected to improve affordability and that scenarios should be those
which could be expected to occur (and not purely hypothetical). From a market signals
perspective, there is clearly significant scope for Hart’s OAN to be in excess of 15% above the
starting point (as concluded in HOU1a), indeed this is necessary for there to be a prospect of
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improving affordability. At the very least, growth of 1.3% per annum (507 dpa) is needed, and
this should be treated as a minimum given the scale of affordability pressures in Hart.
Affordable Housing
3.19 The Council’s evidence identifies a significant need for affordable housing – as set out in HOU1a
Figure 10.27 there is a need for 130 affordable rented homes and 180 subsidised purchase
homes per annum in Hart.
3.20 There are two flaws in HOU1a which mean it does not properly address affordable housing
needs in line with the methodology set out in PPG 2014;
1 Its assessment of newly arising need derives from it’s demographic-led need (which is the
official projections) – as these are inherently flawed and an under-estimate of future
growth, any affordable housing needs assessment flowing from it is similarly infected by
these issues; and
2 HOU1a does not undertaken the exercise set out in PPG ID 2a-029 and consider an uplift to
the OAN where it could help meet needs (an approach which has been clarified in caselaw).
Instead, this uplift is considered by the Council in HOU5 and is (incorrectly) stated to be
part of the requirement, and not the OAN.
3.21 The PPG 2014 at ID 2a-029 states that:
“The total affordable housing need should then be considered in the context of its likely delivery
as a proportion of mixed market and affordable housing developments, given the probable
percentage of affordable housing to be delivered by market housing led developments. An
increase in the total housing figures included in the local plan should be considered where it
could help deliver the required number of affordable homes.”
3.22 HOU1a at paras 10.120-10.129 sets out how it accounts for affordable housing needs in the final
OAN, in summary it makes an uplift for the amount of concealed households. However, this
does not follow the exercise set out above, namely comparing the need to the likely rate of
delivery, and considering an uplift as appropriate.
3.23 It has been clarified by the courts (see King’s Lynn10) that under the PPG 2014 methodology,
affordable housing needs should have an “important influence” on the OAN in a given area:
“This [at PPG ID 2a-028] consideration of an increase to help deliver the required number of
affordable homes, rather than an instruction that the requirement be met in total, is consistent
with the policy in paragraph 159 of the Framework requiring that the SHMA “addresses” these
needs in determining the FOAN. They should have an important influence increasing the
derived FOAN since they are significant factors in providing for housing needs within an
area.” (King’s Lynn, para 33) (emphasis added)
3.24 King’s Lynn accepts that in some cases meeting affordable housing needs in full might lead to an
unrealistic figure (see King’s Lynn para 32) (indeed the PPG 2014 clarifies that OAN
assessments should not consider purely hypothetical scenarios at ID 2a-003). But where it is
necessary, possible and reasonable to make an uplift to deliver more affordable housing needs,
consideration of this should form part of the OAN in an assessment under PPG 2014.
10 Borough Council of Kings Lynn and West Norfolk v Secretary of State for Communities and Local Government, ELM Park Holdings Ltd [2015] EWHC 2464 (Admin)
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3.25 The Council deferred such an uplift to HOU5, which considers it to be part of the requirement.
This directly contradicts King’s Lynn, which is clear that affordable housing needs should have
an important influence on the OAN because they are significant factors for providing for
housing needs in the area, an interpretation which is consistent with paragraph 159 of the NPPF
2012. The Council’s own evidence at HOU5 considers that 485 dpa is deliverable, however we
consider that a rate of 1.3%, or 507 dpa would still be deliverable. Such a figure would clearly
help deliver more affordable housing whilst remaining within what could reasonably be
expected to occur.
4.0 Summary
4.1 There is no justification for the use of the standard method as the basis for the Hart Local Plan,
however unfortunately the Council’s evidence base which has been prepared with regard to the
PPG 2014 is also not a robust basis for determining OAN for Hart. Its key failing are as follows:
1 Failing to address in any robust manner the historic under-delivery as a result of the
moratorium, as required by PPG 2014 ID 2a-015. This means the SHMA’s analysis flowing
from this (including the market signals uplift and affordable housing) are also inherently
flawed;
2 Failing to make an adjustment for market signals which on reasonable assumptions could
be expected to improve affordability, as required by PPG 2014 ID 2a-020. Applying a fixed
percentage uplift to a flawed starting point (as the SHMA has done) simply produces a
figure which is also inherently flawed, and in any case our analysis of comparators shows
that 15% is likely to be too low. The SHMA does not consider any other options, such as a
stock growth based approach, which would not depend on the projections but could provide
a useful benchmark for what Hart might be expected to deliver if it delivered simply at the
national average rate (of 1.3%), or more given the scale of affordability pressures. A rate of
1.3%, or 507 dpa, is still well within what is ‘reasonable’, particularly given higher rates of
1.8-2% seen elsewhere;
3 Failing to address affordable housing needs as required by the PPG (and clarified in King’s
Lynn) within the OAN itself. Instead the Council defers this to the requirement, which does
not reflect the NPP 2012 (para 159) or King’s Lynn. HOU5 shows that the Council believes a
figure in excess of 382 dpa is deliverable, and this should have formed part of the OAN.
4.2 In addition to the flaws in HOU1a/HOU2a regarding Hart’s OAN, TOP1 also shows there is a
shortfall of housing need in the order of 443 dwellings across the HMA against the SHMA’s
OAN (TOP1 Table 7), although clearly the shortfall would be higher if Hart’s OAN were found to
be higher than that in the SHMA (which, for the reasons set out above, we believe is). The Hart
Local Plan should make provision for this unmet need given the requirements set out in the
NPPF 2012, namely that authorities need to meet housing needs across their HMA. The Hart
Local Plan currently omits any of this unmet need, and we set out at our response to question
3.4 in our Matter 3 Statement why this is unsound. The inclusion of unmet need from Surrey
Heath would therefore also provide an indicator that the housing figure in Harts’ Plan should be
higher.
4.3 Taking into account the flaws in the Council’s evidence base, the evidence for Hart indicates that
a housing figure in the region of at least 500 dwellings per annum would be an appropriate basis
for the plan. This would:
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1 Reflect starting point demographic-led needs likely to be at least c.320dpa (but likely more)
once accounting for the distorting and dampening effects the housing moratorium has had
on the trend period from which the household projections draw;
2 Reflect the significant uplift necessary to address market signals and affordability in Hart.
3 Would broadly match the 1.3% stock growth per annum which nationally needs to be
achieved to meet Government’s 300,000 p.a. target.
4 Levels above 500 dpa would address more of the significant affordable housing need in the
District; and
5 Contribute to meeting some of the unmet needs that exist across the Housing Market Area.