LOCAL AUTHORITY SHMA CONSULTATION RESPONSE FORM - OCTOBER 2009
Section 6 - Carlisle Responses
Respondent Cumbria Housing Group Responses Action taken ID 18 Name Steven O'Keefe Agency Policy & Performance Team Address Carlisle City Council, Civic Centre, Carlisle, Cumbria, CA3 8QG LOCAL AUTHORITY SHMA CONSULTATION RESPONSE FORM
General Black & Minority Ethnic Groups: updated information at District level available Noted the updated information provided New table of Mid 2007 Estimates to be added to the Strategic Housing Market Assessments Comment
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ID (1 was 32 a test) Name Andrea McCallum (Clerk to Council) Agency Stanwix Rural Parish Council Address 21 Cawflands, Durdar, Carlisle, CA2 4UT
Q1 Rural Carlisle East Q2 Yes Comment noted No Action required Q2A Q3 No Comment noted No Action required Q4 Yes, it identifies need (particularly for affordable housing in rural areas) and is Comment noted No Action required, very supportive of the Strategic Housing Market Assessment for Stanwix consistent with areas of high priority identified in Stanwx Rural Parish Council's Rural East Parish Plan. Q5 No comment Q6 Yes Comment noted No Action Required Q7 N/A Q8 Left Blank
ID 33 Name Cllr. Prof. J. D. Hendry (Yewdale ward Agency Councillor for Carlisle City Council Address 12 Ash Lea, Brampton, Cumbria, CA8 1TD
Q1 Carlisle Urban, Carlisle Rural East and Carlisle Rural West Q2 Q2A Q3 Q4 I am fully supportive of the proposals, and as a Centre for Growth I would hope that Comments noted No Action required both Riverside Carlisle, Carlisle City Council and the County Council can work together to provide more Social Housing for rent in Carlisle. This is bably needed
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ID 23 Name Audrey Taylor Agency Cumbria Tourism Address Windermere Road, Staveley, Kendal, Cumbria, LA8 9PL
General Job Creation/Economic Development Opportunities ; potential for job creation Comments noted Text to be added to appropriate SHMA's documents (Carlisle Rural West and Carlisle Rural Comment (Tourism Strategy for Cumbria 2008 -2018) in Carlisle at Carlisle Airport (200 East) jobs) and Hadrian Wall product investment (100 jobs).
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ID 22 Name Fiona Goldie (Housing Coordinator for Action for Blind People) Agency Action for Blind People Address Suite 2, 2nd Floor English Gate Plaza, Botchergate, Carlisle, CA1 1RP
Q1 Relates to all the SHMA's Q2 Q2A Q3 Q4 Q5 Q6 Q7 With regard to Cumbria, two particular issues are recurring themes among Action's Comments Noted Matter to be looked into further, possibility of writing a letter to Action for Blind People housing clients: difficulty for persons who require care assistance and possibly a explaining the aims of the SHMA's. need for a second bedroom, to obtain their first homes from Social Landlords / Housing Associations. On many occasions Housing Associations only offer 1 bed accommodation to a 'single individual.' Another, is the issue of payment of the rent, if the individual is not working, as sometimes the Housing Benefit doesn't cover the cost of the rent, forcing the individual to make up the difference by other means. In addition, visually impaired clients suffer from an inability to self identify issues effecting them due to the impact of theie visual impairment such as hazards, disrepair. There is also a need to educate housing providers in terms of adaptations and minor works, issues such as contrasting colours, Changes to lighting, layout and finishes that would be less central to other clients are important to their independence. Typical issues when using contractors - such as home security, cost, concerns about disruption are also exacerbated. Assistive Technology plays a unique role in achieving greater independence.
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ID Name Agency Address
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ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 1. Estimates of Current dwellings in terms of size, type, condition and tenure: Noted. Updated with reference to HIP (HSSA) data - although this doesn't differentiate between open Whilst the draft SHMA identifies at 2.1 the census position as at 2001 it does not market and PRS housing attempt to provide an update despite references to significant losses from right to buy and various demolition programmes.
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ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 2. Similarly the view on page 45 that the level of the private rented sector is likely to Noted Additional text included to expand on this issue - Private Sector Housing Team provided be considerably understated suggests this section requires further evidence information re: potential underestimate of Private Rented Sector (PRS) based on the fact before conclusions can be drawn students don't pay council tax, landlords pay Council Tax on HMOs, and there are 250 un- inspected multi-occupancy properties - some run by businesses, so Council Tax Records don't give a full picture. Also, a report by Clobrix, quoted by the BBC News in March 2009, setting out the significant increase in the PRS, stated the biggest national increase had been in Carlisle (quoted p.45)
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ID Name Agency Address
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ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 3. Furthermore, commentary on condition of property is limited in scope and an Noted Unfortunately, this data will not be available in time for the SHMA deadline. A survey is acknowledged gap in data given the need for a bespoke condition assessment. On currently being put in place to take place across Cumbria using a consistant methodology this basis the provisions of this part of the guidance are only partially satisfied during 2010. It is anticipated the report will be available around September 2010. Text revised added accordingly, p.40 Q8
ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 4. Analysis of past and current housing market trends, etc. The analysis of the Noted Unfortunately, the Rent Office was only able to provide data at a district level - it is indeed the market is mixed with a collection of data some of which is some 3 years old. In light case that there will be significant variations in private rents across the district/HMAs of the recent market conditions considerable effort should be placed on obtaining compared to RSL rents, where there is very little variation. Since the introduction of LHA in the best data available and particularly ensure this is reflective of the differing April 2008, the PRS has actually seen an actual reduction in average rents as the market has situations across the different parts of the housing market area. Currently, for become saturated, due to the recession. Additional text added, p. 43. example, private rent data is collected only on a district wide basis and is based on data to March 2008. It is likely that significant variations occur across the market area and the market price pressures in this sector over the last 18 months should be considered. On this basis the provisions of this part of the guidance are only partially satisfied.
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ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 5. Estimate of total future households, broken down by age and type where Noted At the present time, POPGROUP is unable to breakdown the household estimates to this possible. Whilst section 4 of the SHMA uses the POPGROUP population software detail - our intention is to refine the data that POPGROUP is able to deliver along these lines to predict potential future scenarios there is no attempt to depict these results by for future work (addition clarification included in text p.51). age and type. On this basis it is problematic to draw conclusions about what sort of accommodation types these emerging and in-migrating households may require. On this basis this part of the guidance is not addressed by the SHMA.
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ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 6. Estimate of current number of households in need. The SHMA proposes at Noted Similar to the previous point - POPGROUP is currently unable to break down the projected table 57 an 'updated housing demand' position which suggests this resolves the no. of units required to include the affordable housing element of that total. We have had to requirement of part 4 of the guidance. However, it appears, in light of the content use the need figures based on the 2006 HNS alongside the POPGROUP scenarios. It is of the subsequent paragraph to be an incomplete picture of demand given the intended that a more sophisticated methodology will be used in future work (additional POPGROUP software results excludes those in unsuitable housing. On this basis explanatory text included p.69). it appears the results from the Housing Need Suirvey 2006 (HNS2006) have been simply increased based on a population estimate. This will not reflect the current housing demand position and the balance between market and affordable need because income parameters and affordability have not been updated. On this basis this part of the guidance is only partially met.
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ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 7. Estimate of households that will require affordable housing. The SHMA attempts Noted 7. Not sure where the figures comes from re: falling waiting lists? Presumably any fall would to extrapolate the conclusions of the HNS 2006 taking into account affordable only be because of RSL's not maintaining a traditional waiting list since implementation of supply since that date, to derive a current position. This process simplistically CBL? Section 7 (p.85) certainly refers to "long social housing waiting lists?" No action taken assumes that any shortfall between need identified by the HNS2006 and affordable as unsure of source? 7A. This table was also intended to highlight the inability to deliver the supply since that date has resulted in an additional backlog of need. This will not be need identified by the HNS at each HMA level - particularly in rural areas - through the the case particularly given the market conditions which have prevailed since 2006 planning system (S106) and HCA funding route. Additional text added explaining function of and that an estimate of need is not necessarily a reflection of a precise number of table in light of these comments (p.75). people waiting for accommodation. In simple terms the fact that the numbers on the housing waiting list has fallen since 2006 (??) lends support to the arguement that this approach to backlog is potentially flawed. 7A. In reaching the revised conclusions on affordable housing need it is not apparent that affordability parameters have been re-assessed and or a realistic new backlog position identified. On this basis the SHMA's position on this appears to fall short of a robust conclusion.
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ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 8. Estimate of households that will require market housing. The SHMA only Noted See note 7:- as previously stated we are not entirely clear on what basis this suggestion is derives this as a residual to its derivation of affordable need. Given the approach made? Despite comments above (see 7A) we do not accept need has diminished - and we identified above in relation to the number of households who require affordable do feel there is a backlog, as we haven't been able to deliver the affordable housing numbers housing has shortcomings it is possible that the conclusions regarding market identified in the HNS. Therefore no action required/taken housing are understated. On this basis the Shma's position on this appears to fall short of a robust conclusion. Q8
ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 9. Estimate the size of affordable housing required The SHMA does not attempt to Noted Breakdown of affordables by size/tenure actually already included at P68. Additional text draw conclusions on this issue and therefore does not meet this part of the included p.70 for cross reference purposes. guidance.
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ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 10. Estimate of household groups who have particular housing requirements. Noted Details of the new Extra Care scheme (started on site August 2009); Gypsy and Traveller site Section 6 of the SHMA considers this but the analysis is generally a commentary (started on site September 2009); Centre of Excellence (due to start on site early 2010); on existing available accommodation rather than an estimate of future also, proposals for replacement family hostel and new foyer project included in this section? requirements. On this basis this part of the guidance is only partially met. However, additional detail will now be included in this section based on consultation information from Action for Blind People, and regarding impact of providing support to an ageing population - particularly in rural areas.
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ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 11. Approach to identifying housing Market area(s) is consistant with other Noted Updated text added re derivation of HMAs and relationship to regional SHMA included p.22 approaches to identifying housing market areas within the region. This aspect is briefly covered on page 22 but the SHMA would benefit from a fuller explaination of the derivation of the housing market area for the purposes of the SHMA and how this relates to the Regional position. This would ensure that consistency of position exists in light of the above requirement.
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ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 12. Housing Market conditions are assessed within the context of the housing Comments Noted Analysis of price fluctuations within each HMA by 4 digit postcode sectors included and market area. This has been alluded to the above in respect of the current housing further reference to PRS p.46. market trends 'core outputs.' The position remains relevant in this context, the period of rapid market change which is currently occurring means more up-to-date inputs need to be considered particularly in light of the Private Rented Sector (PRS) and the sub regional house price fluctuations alongside evidence about particular price pressures within the current stock.
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ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 13. Involves key stakeholders. The SHMA would be improved where the appendix Noted Additional information to be added in Appendix 3 3 is updated to chart the membership of the SHMA housing market partnership and the progress of consultation to date.
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ID 20 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 14. Contains a full technical explanation of the methods employed, with any Noted Table 57 is actually based on HNS data - no action taken. limitations noted. The SHMA would benefit from additional detail particularly in respect of section 4 and the assumption behind each of the population projections and how these interlink with previous sections of the report and fundamentally how they derive table 57 and its conclusions.
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ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 15. Assumptions, Judgements and findings are fully justified and presented in an Noted It is considered that the summary comments included in each section have been analyzed open and transparent manner. This closely links to the last item on the process and summarised in the final section. This is in relation to key areas of the conclusions, such checklist and the SHMA would benefit from additional clarity on how the various as the ageing population, impact of the recession on the PRS, radical change in the mortgage sections of the report combine to produce conclusions. In particular as drafted it is market since the 'credit crunch', and the slow down in the mortgage market leading to even not apparent how the observations and findings identified and considered in greater polarisation - with only the better off (or those with better off parents) readily able to sections 1 - 4 combine in section 5 to produce the overall conclusions. access the owner occupation market.
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ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 16. Uses and reports upon effective quality control mechanisms. The Shma does Noted Comments noted - the Research & Information Group has been jointly managed between not report on how this matter has been managed. The methods employed to Cumbria County Council/ the 6 District Councils/ Lake District National Park Authority/ satisfy this requirement should therefore be incorporated within the document. Cumbria Vision & other partners (such as Cumbria Rural Housing Trust) to ensure the SHMA process has been effectively managed in line with CLG guidance. The process has been regularly reviewed & monitored through Research & Info Group meetings (additional explanatory text added in Appendix 3)
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ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 17. Explains how the assessment findings have been monitored and updated. This Noted The SHMA Guidance recommends that partnerships undertake a comprehensive aspect is considered variously above insofar as certain data sets appear dated in assessment no more than every five years but that trends and activities in the market areas light of the changing market conditions. The SHMA would benefit from added should be monitored regularly against policy aims. In addition the information contained in the clarity on what methods or approaches will be employed by the Council to keep the SHMAs should be updated. This will be carried out in conjunction with Planning evidence up to date once the final SHMA has been introduced. This is particularly departments/authorities. To achieve this aim and provide a framework for updating SHMAs a relevant given the fundamental base data from the HNS2006 will be near the end of set of indicators have been developed listed in appendices 2, 3 & 4. A comprehensive its useful life at the end of 2010 on the basis of it being 5 years old at that time. assessment and updated housing needs survey is planned for 2010/11.
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ID 34 Name Hugh Lacey of RPS Planning Agency RPS on behalf of the Church Commissioners Address RPS Planning, 1st Floor West, Cottons Centre, Cottons Lane, London, SE1 2QG
Q1 Carlisle Urban Q2 Q2A Q3 Q4 Q5 Q6 Q7 18. In conclusion the draft SHMA, in its current form, falls short of complying with Comments Noted It is considered that the amendments above address this issue as far as possible. Aspects the requirements of the process checklist and core outputs set out in the of the SHMA will be previewed in due course. SHMAPGv2. On this basis its use as a robust and credible evidence base for policy making and implementation is questioned. Further supplementary work as identified in the above analysis would improve the data quality and potentially allow the Council advance the SHMA as a robust and credible evidence base as required by both PPS3 and PPS12.
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