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Fylde Council Local Plan to 2032 Fylde Council’s response to Inspector’s Questions Stage 3 Hearings November 2017 Date: Dec 2017 Authorised by: Planning Policy Page left intentionally blank Fylde Council Local Plan Examination Stage 3 Responses to Inspector’s Questions The Council’s responses are set out below. 1. Is the OAHN range justified and supported by robust evidence Yes. The justification of the OAHN range is set out within Addendum 3 to the SHMA produced for the Council independently by the consultants Turley. This is itself informed by the AMION report Independent Assessment of the Economic Prospects of Fylde. Both of these pieces of evidence are up- to-date, independently produced studies which assess all of the relevant issues in producing recommendations. Addendum 3 follows the methodology set out in the PPG, and makes use of the most up-to-date ONS projections, the 2014-based SNHP and the 2014-based SNPP data. The Council has provided a summary of the justification in the introductory section 2 of the evidence Consultation Document (EL7.002, pages 7-11); it is not considered necessary to repeat all of the contents here. Instead, the Council will focus on the specific points raised by the Inspector. In particular: 1.a) It has been suggested that due to the affordability ratio within the borough the market uplift should be increased to 20%. Is this higher level supported by evidence? The evidence for the market signals uplift is set out in section 5 of Addendum 3 (EL7.002, pages 75-90). The affordability ratio is one of six indicators used within the market signals assessment in Addendum 3. These six indicators were also used in the same way in Addendum 2 and are the six indicators listed within the PPG. The PPG notes that an upward adjustment to planned housing numbers will be required over and above the household projections where market signals point to a worsening trend. Where an adjustment is required, it should be set at a level that is reasonable and which is consistent with the principles of sustainable development. The assessment should take account both of indicators relating to price (such as house prices, rents, affordability ratios) and quantity (such as overcrowding and rates of development). The assessment in section 5 comes to a robust and reasoned judgement for an uplift of a maximum of 10% for market signals noting that “In the context of the updated assessment of market signals it is considered reasonable to view this as an upper limit to any such adjustment to be applied to the demographic projection.” It is not considered that the scale of affordability issues supports a higher level of adjustment when set in the context of national indicators. Whilst evidence of worsening market signals is recognized within Addendum 3, this is at best modest in the context of national indicators as shown clearly in Table 5.81. 1 It is noted that the proposed standard method for calculating local housing need within the Government’s consultation document ‘Planning for the right homes in the right places’ (September 2017) proposes a 10.6% adjustment to address ‘affordability’ issues related to the latest affordability ratio in Fylde. Outside of the recommended adjustment the Addendum 3 goes on to note that “this level of need falls below the range of need concluded as being required to support the scale of job growth forecast over the plan period” and therefore that the calculated need to provide for jobs growth would boost supply “addressing the impact of any historic imbalance between supply and demand”. In fact, the Local Plan housing requirement figure of 415 would provide for the equivalent of an 18% uplift, in excess of what is shown by the evidence to be necessary to address all market signals uplift issues. 1.b) Some market signals have not been updated. Are the previous assessments for these still appropriate and based on credible evidence? Within Addendum 3 Market Signals were updated as follows: House prices was updated to integrate sales data for the latest calendar year (2016); Rents was updated to integrate the latest available data published by the Valuation Office Agency (VOA), covering the period from October 2015 to September 2016; Affordability was updated to integrate the latest data published by the Office for National Statistics (ONS), which ran up to and including the calendar year of 2016; The rate of development was updated to integrate net completions in the latest year (2015/16); Land prices was updated to reflect the latest land value estimates published by DCLG in December 2015; and Overcrowding and concealed families was not updated, with the 2011 Census continuing to provide the latest robust measure. Addendum 3 presented additional evidence on homelessness in 2015/16 The summary tables in both Addendum 2 and Addendum 3 (Table 5.8) present ‘selected market signals’ as some (namely the rate of development and land prices) cannot be directly quantified and compared in this format. The summary tables consistently present the same indicators, drawing upon updated data in Addendum 3 where this is available. Overcrowding and concealed families are therefore the only indicators that were not updated in Addendum 3, due to the absence of a comparably comprehensive measure of these signals since the 2011 Census. This is considered to represent a reasonable approach. 1.c) Some representors suggest that large employers in the area are contracting, which would result in a lower housing need. Is this the case and does the evidence support a lower jobs growth forecast? 1.c) The evidence in the Addendum 3 and AMION reports highlights the important relationship between future job growth and housing need. The forecasting of lower job growth would reduce the scale of housing need associated with this factor alone. In this context it should, however, be noted that the OAN concluded within Addendum 3 takes account of demographic and market signals evidence as well as the relationship with forecast job growth. The Addendum 3’s analysis of these factors identifies a need for a minimum of 386 homes per annum (Table 6.1) outside of the adjustment to accommodate likely job growth. With regards to the forecasting of future job growth the AMION report provides a comprehensive assessment of the likely job growth over the remainder of the plan period. The assessment makes use of the employment forecasts of three forecasting houses, producing projections based on the year-by-year average of the three forecasts, and based on a three-year moving average of the same data. The forecasts give projections to 2032, across all sectors, and reflect that there will be growth in some and decline in others. Whilst the data is in the form of projections, it is recognised that the actual process of employment change results from a series of one-off events, large and small, positive and negative, within individual sectors within the plan period. The projections reflect relative economic performance across sectors and local areas, in accordance with the methodology adopted by the respective forecasting houses. As shown by Table 3.4 of the AMION report (page 155 of EL7.002) the forecasting houses predict annual jobs decline in manufacturing of 141 (Cambridge), 71 (Experian) and 112 (Oxford). Job losses are anticipated, following the announcement by BAE Systems in November 2017 that 750 jobs will be lost across the Warton and Samlesbury sites over the next few years. Assessment has not been undertaken as to the effect that incorporating the anticipated job losses would have on the modelling were it refreshed again. However, it must be stressed that whilst there has been a particular announcement, the timing of any job losses, and the extent to which they would fall at Warton, is uncertain. Unless and until they have occurred, or at least until there is any degree of certainty, it would be inappropriate and premature to attempt to directly quantify the impact through any reassessment of likely job growth. It does, however, highlight the issues with trying to accurately forecast job growth over the long-term. Inevitably one-off events will result in job losses and gains outside of the comparatively ‘smooth’ forecast picture. This reinforces the importance of taking a ‘balanced’ view when considering growth over the plan period. The employment projections within the AMION report provide a range within which jobs growth during the plan period is likely to fall. This range, 55-91 jobs per annum, is broad, and therefore provides for fluctuations that will occur, as is evident in relation to the recent announcement referenced above. This jobs growth range in turn has informed the OAN for housing, which is also a range: 410 to 430 dpa, within which the requirement of 415 dpa has been adopted. Recognising the volatility of the jobs growth figure in the context of such recent events serves to reinforce the Council’s decision to establish its housing requirement from within the range presented. 1.d) Other representors suggest that an allowance for additional jobs growth at the Enterprise Zones should be taken into account in the assessment. Does the evidence support such an allowance? Does the Council’s economic strategy rely on growth at the Enterprise Zones? Are the economic and housing strategies aligned within the plan? The Council’s position and a consideration of this issue appears within the evidence consultation document EL7.002 on pages 8-10, drawing from the AMION report (EL7.002, specifically pages 143-145, 156-157 and 159). In summary, the evidence shows that a specific allowance for additional jobs growth at the Enterprise Zones within the assessment would not be justified.

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