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And Note (Insp019a WCED015A WREXHAM LOCAL DEVELOPMENT PLAN EXAMINATION IN PUBLIC - WREXHAM COUNTY BOROUGH COUNCIL’S RESPONSE TO THE INSPECTORS’ POST- HEARING LETTER & NOTE DATED 13th DECEMBER 2019 (INSP019 & INSP019a) INTRODUCTION This statement sets out the Council’s response to the Inspectors’ post-hearing letters (INSP0191) and note (INSP019a2) in which they expressed concern about the soundness of two aspects of the Plan – housing requirement and delivery and Gypsy and Traveller accommodation – and required the Council to answer specific queries and submit further information/evidence. The approach that the Council has taken in compiling this report has been: a) to refer the Inspectors to evidence that the Council has already submitted, such as the background papers, hearing statements and responses to post-hearing action points b) to provide further information/evidence, as required, principally drawing from the Council’s housing and Gypsy and Traveller sites databases that underpinned the decisions to allocate (or not to allocate) particular sites, but which were only summarised in the previously submitted background documents c) to infer, from the Inspectors’ letters/note what changes to the Plan or further work might be necessary in the event that the Inspectors are not convinced by a) and b), above, that the Plan is sound and to do as much of that work as possible in the time that has been available to explore the issues and identify the implications. Some changes have already been the subject of public consultation and political endorsement and were reported to the hearings in 2019 as Matter Arising Changes (MAC), but others are new and would require consultation, etc as MAC, if proposed by the Inspectors. The Council has followed this approach because it believes that there is already sufficient evidence to support the adoption of the Plan contained in the previously submitted documents and the newly published databases that underpinned them and to obviate the need for an unfruitful suspension of the Examination in Public. Delaying the adoption of the Plan any further will compound the harm already caused by speculative development in some areas and a lack of investment in others and the effect on strategic planning of ‘Planning by appeal’. In this respect, it is noteworthy that the Council has received notification from the Inspectorate that the Inspectors will be submitting their final report in May 2020. The Council would welcome the guidance and/or direction of the Inspectors to ensure that the Plan can be taken forward to adoption; particularly if the Council has not interpreted correctly what they are looking for in their letter and note. The format of the rest of this report corresponds with the subject headings, bullet points and questions/requests for information set out in the Inspectors’ note. 2. HOUSING REQUIREMENT For clarification, Policy SP1 of the Deposit Local Development Plan (‘the Plan’) makes provision for 8525 new homes in order to deliver a housing requirement of 7750 over the Plan period. 1 https://wrexham-consult.objective.co.uk/file/5570524 2 https://wrexham-consult.objective.co.uk/file/5570528 1 On a procedural point, the Preferred Strategy (PS) does not form part of the submitted documentation required under Regulation 22 of the Town and Country Planning (Local Development Plan) (Wales) Regulations, 2005, as amended3. At the pre-Inquiry meeting held on 25 June 2019, the Council confirmed that the Plan which is to be examined is the Deposit version as amended by the Proposed Focussed Changes. On the substantive point, the Plan’s housing requirement is sufficiently aspirational, but also deliverable and is founded on robust and credible evidence. The decision to reduce housing provision between PS (11,715) and Deposit (8,525) stages of the Plan is set out in BP01b4, M2.015 & INSP017R6 and is fully justified, for the following reasons: • having regard to the significant change in evidence presented by the release of the 2014-base population and household projections compared to the 2011-base projections • the continued importance of the deliverability of allocations in LDPs, as set out in national policy • an assessment of past completion rates and feedback from consultation The next official round of Welsh Government (WG) projections will use 2018 as a base year. They are due to be published at the end of February with the household projections in the spring. Projected growth levels are expected to be significantly lower than set out in the Plan. Using the 2014-base is sufficiently aspirational to support the economic ambition in the Plan, but also appropriate given fluctuations in the projections. In summary, the policy and evidence-base justification for the housing requirement is that: • it is based on the most up to date evidence, in accordance with PPW10 • it remains aspirational in support of economic growth, as advocated in the Plan Strategy and by regional evidence • it allows for job growth proportionate to the sector growth analysis undertaken in the econometric forecasting model (BP077) • it is realistic as the development industry can deliver the 517 dwellings required per year (694 in the remainder of the Plan period, given completions since 2013) • it enables the Council to allocate the most sustainable and deliverable sites • it still provides a sufficient critical mass of population to support investment in infrastructure • it will enable the Council to demonstrate a 5-year supply on adoption of the Plan, given the residual methodology calculation If the PS figures were used it would require an extra 3190 dwellings (including a 10% flexibility allowance, although the Inspectors’ query about the logic of this particular percentage is discussed later in this report). This would reverse the bullet points, above, and result in a significant misalignment between aspiration and delivery, while the level of growth proposed would have severe adverse consequences for the Plan, for sustainable development and for the people of the County Borough. In terms of deliverability, it is difficult to see how the development industry can build significantly higher numbers of housing than prior to the recession. Once completions are deducted, the average annual rate of completions over the Plan period would need to be 3 http://www.legislation.gov.uk/wsi/2005/2839/contents/made and http://www.legislation.gov.uk/wsi/2015/1598/made 4 Background Paper BP01b para 2.20. http://wrexham-consult.objective.co.uk/file/5113347 5 M2.01 WCBC Plan Strategy https://wrexham-consult.objective.co.uk/file/5468398 6 https://wrexham-consult.objective.co.uk/file/5525608 7 Background Paper BP07 Employment Land http://wrexham-consult.objective.co.uk/file/5113359 2 1,016 to deliver the PS housing requirement, 46% more than the 694 needed to deliver the Deposit Plan requirement. The former has not been achieved at any point in the past 15 years (both before and during the recession) and only once has come close (this is discussed in greater detail on Pages 14 and 15 of this report). Increasing the housing requirement would also impact on the provision of infrastructure which is fundamental to the delivery of the Plan. The Infrastructure Plan8 emerged from a process of constructive dialogue on the housing requirement with stakeholders, including organisations responsible for the provision of infrastructure, based on the Plan provision of 8525 new homes. Increasing the requirement would have infrastructure implications to the extent that it would result in a different Plan altogether. Questions/Further Information i. In arriving at a housing requirement based on the latest projections, has sufficient consideration been given to key evidence in relation to issues such as what the plan is seeking to achieve and links between homes and jobs? Yes - as set out in BP01, a core part of the population and housing projections work has been to calculate the number of jobs required to meet the projected population increase over the Plan period (the jobs density calculation). From the outset, the Council has carefully considered the relationship between housing, jobs and employment land, following an approach that has been endorsed by the Inspectorate at the Newport LDP Examination in Public9 and Cheshire West & Chester examination of their core strategy10. As stated in BP0711 and Wrexham Council Statement - Economic Growth and Enterprise (M5.0112) it should not be expected that the housing and job projections will match exactly, they being based on different data inputs, drivers of growth, assumptions about the future and methodologies. As noted in Appendix A2 of BP01b13: When looking at predicting future growth, there are three main factors which can drive projections work: demographic change, change in the number of new dwellings and change in employment provision. The three factors are all interrelated – an increase in employment in the area may lead to in- migration and thus population growth, which requires additional housing provision or lack of sufficient housing provision may cause people to move out of the area, taking their employment skills with them and discouraging employers from developing within the local economy. We try to balance these three elements of growth, but cannot always do so within the statistical exercise of producing projections, as there is always a dominant driver of growth and there is no set methodology for providing this balance. Part of the population and housing projection work has been to calculate the number
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