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LDP Examination NCC Response Statement – Hearing Session 2

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LDP Examination NCC Response Statement – Hearing Session 2 Newport City Council Local Development Plan Hearing Session 2: Provision for Housing 10am – Wednesday 2nd April 2014 Newport City Council – Hearing Session 2: Provision for Housing 1. Housing requirement - Is there a sound rationale for the identified housing requirement of 10,350 new homes over the Plan period? (i) Does the demographic and economic-led housing forecast ( SD55 NLP Assessment of Housing Requirements Paper ) provide a robust and credible basis for setting the Plan’s housing requirement? 1.1 Newport’s housing requirement level was identified using NLP’s HEaDROOM Assessment (SD55). NLP’s HEaDROOM Assessment has been utilised in over 120 authorities throughout the UK and has been found to be robust by Inspectors. 1.2 The HEaDROOM Assessment method tested 5 core scenarios which considered both demographic and economic factors. In addition to this, a range of sensitivity tests relating to unemployment, migration and the impact of the 2011 Census were also undertaken in order to provide a clear understanding of the ways in which alternative variables might impact upon the final dwelling requirement. 1.3 The HEaDROOM Assessment drew upon the latest information available and included consideration of cross-boundary issues. To ensure consistency within the LDP’s evidence- base the HEaDROOM Assessment utilised the same Experian economic forecasting which was used in the Employment Land Review (SD65). 1.4 The LDP’s housing requirement level is based upon an economic -led scenario and seeks to achieve an alignment with Newport’s positive economic growth strategy. In essence this approach seeks to recognise the economic realities at play and will help to ensure sufficient housing is provided to meet likely demand from those working in the area. 1.5 This positive approach is consistent with Planning Policy Wales’ emphasis on promoting economic development and para 7.1.3 of PPW which states that wherever possible LPAs should align jobs and services with housing. It is also consistent with recent Ministerial Statements which seek to increase the supply of housing. Therefore it does form a robust and credible basis for setting the Plan’s housing requirement. (ii) Does the Experian Business Strategies economic growth forecast of 7,400 new jobs created in Newport between 2011 and 2026 provide a suitably reliable and authoritative basis for estimating economic growth over the Plan period? 1.6 Both the Housing and Employment Evidence bases share a common economic projection, independently prepared by Experian Business Strategies. 1.7 This common evidence base is supported in Planning Policy Wales (Edition 6), which requires a joined up approach to housing and employment evidence (P 7.1.3). PPW requires development plans to try and align economic and housing policies where possible. 1.8 With this in mind the Experian forecast was used to help evidence the proposed number of new homes (and so potential future labour force) but also the ‘base case’ employment targets. 1.9 Experian was used because the Welsh Government no longer provides up to date economic forecasts for Local Authorities. Experian are a widely respected economic forecasting house 2 Newport City Council – Hearing Session 2: Provision for Housing and commonly used in many housing and employment evidence bases. Both NLP (housing evidence) and RTP/PBA (employment evidence) subscribe to the Experian model. 1.10 Before being used, the Experian Forecast was tested to see whether it reflected a reasonable base case economic future for Newport or whether an alternative job forecast should have been promoted. The employment land evidence found that meeting the job forecast was already a ‘step change’ in the economic fortunes for Newport. 1.11 The ELR found that Newport lost jobs over the period 1997 – 2011. Table 5.1 of the ELR (SD65) showed a loss of over 5,000 jobs over the period. The forecasts suggest a reversal of this trend; with around 7,400 new jobs being added to the stock over the plan period. 1.12 Consultations suggested that reversing the decline in local jobs and delivering positive job growth was a significant challenge. Further, any positive job growth would also be hindered by a lack of market viability to bring forward new high quality sites. 1.13 So, with this in mind, a higher (potentially more aspirational) job target was discounted. However the evidence recognises that meeting this base case would be even more challenging if sufficient homes, and new labour was not promoted in the housing evidence. Hence the shared Experian evidence. 1.14 For employment land purposes the Experian forecast is only taken as a base case. The Plan promotes more land but this overprovision has been carefully tested and its continual allocation is the result of a pragmatic approach. 1.15 Most of the land in the Plan is not new and much has already been serviced to make it available. At the time the ELR was undertaken most owners had confirmed that they were still promoting their sites for development. (iii) Does the evidence constitute a rational basis for departing from the 2008-based WG population and household projections, having regard to the factors identified in PPW at paragraph 9.2.1? 1.16 The LDP’s housing requirement level of 10,350 dwellings is derived from an economic-led scenario (Scenario E in NLP’s HEaDROOM Assessment – SD55). 1.17 This level of housing provision seeks to achieve an alignment with the Plan’s positive economic growth strategy. It reflects the requirements in PPW (para 7.1.3) and aims to provide enough housing for the level of workforce required to attract (and sustain) the Plan’s positive economic growth objective. 1.18 The identified housing requirement is a deviation upwards from the policy neutral, trend- based 2008-based WG projections. Full justification for this is set out in NLP’s HEaDROOM Report (see para. 3.32 – 3.33) in accordance with the PPW para. 9.2.1. In summary, 3 Newport City Council – Hearing Session 2: Provision for Housing a) Wales Spatial Plan (WSP, Update 2008) - A deviation upwards seeks to encourage and deliver economic growth. This reflects Newport’s identification as a Key Settlement of National Significance within the WSP. b) WG latest household projections – The WG projections do not take account of specific policy objectives or future economic factors which Newport is striving for, whereas the proposed deviation does take this into account. c) Local Housing Strategies – A deviation upwards will be important in order to provide a range and choice of housing provision for all. This approach will also help to support Newport’s economy and help to ensure commuting patterns are sustainable. d) Community Strategies - A deviation upwards will be important in providing a range and choice of housing provision for all. This approach will also help to maximise the number of new affordable homes and thereby increase opportunities for community regeneration. It will also help align the LDP’s economic and housing strategies to ensure that Newport’s economy is supported and residents have the opportunity to both live and work within Newport – thereby improving the economic and sustainability profile of the City. e) The needs of the local and national economy: Achieving an alignment between housing and employment growth is important in terms of supporting the well- being of any area. The 2008 WG scenario would support less than 3,000 additional jobs – less than 40% of the number that are forecast to be created within Newport over the LDP period. Inadequate infrastructure to support these new jobs – including housing – would undermine the attractiveness of Newport and the potential to deliver future economic growth. It would also undermine the vision for the City. By contrast, the Plan’s housing requirement level draws upon an understanding of the economic future of the City and will help to ensure that sufficient workers can be accommodated to help deliver future employment growth into the City. f) Social considerations (including unmet need): LDP Policy SP10 establishes that Newport’s affordable housing requirement is 8,901 units. Pursuance of an (upward) deviation from the 2008 WG projections will help to ensure that a higher quantum of affordable housing can be delivered. g) The capacity of an area in terms of social, environmental and cultural factors to accommodate more housing : The LDP makes provision for 11,326 dwellings, of which 3,548 are presently on sites which are under construction, 2,767 are commitments and 1,172 are commitments subject to the signing of s106 agreement. This equates to a total of 7,487 units that are already committed – this is close to the level the 2008-based WG projections requirement. In addition, 1,526 dwellings are expected to come forward on allocated sites. Even allowing for the potential non-implementation of some dwellings, it is clear that there is sufficient capacity to meet the identified requirement. h) The environmental implications : The potential environmental issues are capable of being satisfactorily overcome through appropriate mitigation measures. i) The capacity of the existing or planned infrastructure: The analysis that has been undertaken by NCC has indicated that there are no infrastructure 4 Newport City Council – Hearing Session 2: Provision for Housing constraints which would impact upon the delivery of residential development across the City. 1.19 This justification forms a rational basis for departing from the WG projections. (iv) Do the latest WG projections (expected end February 2014) necessitate any adjustment of the identified Plan housing requirement? 1.20 Policy SP10 of the LDP identifies a housing requirement level of 10,350 dwellings between 2011 and 2026. This housing requirement level is a deviation upwards from both the 2008 and 2011 based WG projections and is derived from an economic-led scenario based upon an employment forecast (prepared by Experian Business Strategies).
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