East Riding Local Housing Study Addendum Note
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ReportReportReport GVA Norfolk House 7 Norfolk Street Manchester M2 1DW East Riding Local Housing Study Addendum Note August 2014 gva.co.uk East Riding of Yorkshire Council LHS Addendum Note Contents Summary ................................................................................................................................. 1 1. Introduction ................................................................................................................ 3 2. Consideration of alternative assumptions .............................................................. 5 3. Consideration of latest strategy context .............................................................. 16 4. Updated household modelling.............................................................................. 21 5. Consideration of market signals ............................................................................ 36 6. Conclusions .............................................................................................................. 47 List of Acronyms .................................................................................................................... 50 Prepared By: Nicola Rigby ..................... Status: Director .................... Date August 2014 .................... Reviewed By : .......................................... ............. Status: ..................... Date ........................................... For and on behalf of GVA August 2014 I gva.co.uk East Riding of Yorkshire Council LHS Addendum Note Summary This Addendum Note has been prepared by GVA on behalf of East Riding of Yorkshire Council. It reflects updates to information that have been made available since the publication of the Local Housing Study in January 2014, which are relevant to be considered as part of the East Riding Local Plan Examination. The Addendum also considers representations received as part of the Local Plan process, and in response to evidence prepared by both ERYC and NLP as part of the Melton Planning Inquiry. The note is not intended to repeat or replace the LHS, but rather sensitivity test areas of the analysis on the basis of new information where relevant. The key information which has been updated since the publication of the LHS has included: • 2012-based Sub-National Population Projections; • Census 2011 data on key assumptions including economic activity rates; and • Emerging case law of relevance to the calculation of Objectively Assessed Housing Need and defining a Local Plan housing requirement. In addition, the Addendum takes into account the announcement made on 25 th March by Siemens and Associated British Ports that they jointly will invest £310m into Hull and the East Riding to deliver wind turbine production and installation facilities at two sites in Hull and East Yorkshire, and the updated policy and strategy position including the Hull SHMA, Joint Planning Statement (JPS) between East Riding of Yorkshire Council and Hull City Council, and the Humber Local Enterprise Partnership and York, North Yorkshire and East Riding Local Enterprise Partnership Strategic Economic Plans – all published since publication of the LHS. The original LHS identified a housing requirement for the East Riding alone of 1,933 (2011 headship rates) to 2,229 (2008 headship rates) dwellings per annum 2012 – 2029 for the plan period. As part of this Addendum exercise this figure reduced as summarised in the bullet points below: • Adjustment to reflect a reduced unemployment rate as part of the Melton Appeal: reducing the figures to 1,827 per annum (2011 headship rates), and 2,119 per annum (2008 headship rates); • Adjustment to reflect the latest PopGroup methodology: changing the figures to 1,888 per annum (2011 headship rates), and 2,165 per annum (2008 headship August 2014 I gva.co.uk 1 East Riding of Yorkshire Council LHS Addendum Note rates) (NB: these figures do not assume the lower unemployment rates identified during the Melton Appeal); and • Finally, the adjustment to reflect the latest PopGroup methodology and the latest assumptions as set out in this document: reducing the figures to 1,624 per annum (2011 headship rates), and 1,896 per annum (2008 headship rates). However, it is still considered appropriate to plan for higher levels of housing growth across the housing market area, as set out in the JPS. This would contribute to the delivery of the NPPF, which requires Local Plans to: • Meet objectively assessed needs, with sufficient flexibility to adapt to rapid change; and • Boost significantly the supply of housing. The decision in the case of Gallagher Homes Ltd / Lioncourt Homes Ltd vs Solihull MBC concluded that the final appropriate step in establishing an appropriate housing requirement is to apply any policy considerations to that figure (i.e. identifying a figure which, on policy grounds, is lower or higher than the full objectively assessed figure for housing need in that area). This is based on co-operating with adjoining or other near-by local planning authorities on the strategic matter of meeting housing requirements across the housing market area. This supports the view of considering the East Riding dwelling requirement alongside that of Hull City Council, as outlined in the Hull SHMA, and highlighted through the recently endorsed JPS. The JPS recognises the context of housing requirements and strategy aspirations across the joint housing market area spanning the East Riding and Hull, as established through the latest evidence base and strategy documents in place across the sub-region, and consistent with the requirements of NPPF. August 2014 I gva.co.uk 2 East Riding of Yorkshire Council LHS Addendum Note 1. Introduction 1.1 This Addendum Note to the January 2014 East Riding Local Housing Study (LHS) has been prepared by GVA with Edge Analytics on behalf of East Riding of Yorkshire Council. 1.2 The Addendum is required in response to the issuing of new data, and a new PopGroup model (v4) (PG4) which changes the population projection method for improved alignment with ONS methods and introduces a revised approach for modelling in-migration rates to individual areas, since the undertaking of the original study, including the consideration of the following: • the release (on 29 th May 2014) of the 2012-based Sub-National Population Projections (SNPP) which supersede the Interim 2011-based SNPP (which only projected forward to 2021); • economic activity rates from the 2011 Census which provide the latest profile of age-specific activity, which are used directly in the jobs-led scenario in conjunction with an updated commuting ratio from the 2011 Census and the latest unemployment rate statistics. 1.3 The Addendum note is also required to address the additional household modelling undertaken as part of the preparation of evidence to inform the Melton Planning Appeal 1 (documented within the proof of evidence of Richard Wood as part of that appeal by St Modwen). Structure of Note 1.4 The Addendum note is structured as follows: • Section 2: Consideration of alternative assumptions: review of alternative assumptions following review of representations put forward to the Local Plan and as part of the Melton Planning Appeal; • Section 3: Consideration of latest strategic context: review of relevant policy and strategy released since the undertaking of the Local Housing Study; • Section 4: Updated household modelling : summary of additional modelling undertaken since the January 2014 LHS, including explanation of why the model 1 Appeal A reference APP/E2001/A/13/2200981, Appeal B reference APP/E2001/A/14/2213944 August 2014 I gva.co.uk 3 East Riding of Yorkshire Council LHS Addendum Note has been run, the assumptions applied, and the implications in terms of household projections; • Section 5: Consideration of market signals : analysis of available data to document relevant market signals to be taken into account when considering potential requirement for additional allowance, in line with Planning Practice Guidance (PPG); and • Section 6 : Conclusions: drawing together the implications of the proceeding sections. August 2014 I gva.co.uk 4 East Riding of Yorkshire Council LHS Addendum Note 2. Consideration of alternative assumptions Response to representations 2.1 Detailed representations have been received relating to the household requirements put forward in the Local Plan by seven separate parties. The representations received and a summary of their main objections are listed below. • Pioneer Property Services (on behalf of a client): Requirement put forward by ERYC is too low; Requirement derived qualitatively not quantitatively; Requirement is below the upper range identified in the Local Housing Study; • Peter Brett Associates (on behalf of a client): As for Pioneer Property Services, plus: Concern regarding re-basing of the plan period to 2012; Concern about unmet need from wider area; Requirement is skewed by historic constraints (i.e. past delivery); • Spawforths (on behalf of a client): As for Pioneer Property Services; • Home Builders Federation: As for Pioneer Property Services, plus: Concerned with alignment with 2011 household projections (considered ‘recessionary’); Requirement should consider backlog; • Barton Wilmore (on behalf of various clients): As for Pioneer Property Services; • Nathaniel Lichfield and Partners (on behalf of a client): As for Pioneer Property Services, plus: Concern that evidence does not take into account market signals; Concern that LHS is too heavily based