Matter 7 WHBC Response

Examination of the Welwyn Hatfield Local Plan Council’s Hearing Statement for Matter 2 Overarching Strategy: Q7 Targets for Growth 9 October 2017 (For Hearing Session 24-26 October 2017) 1 7. Targets for growth - are they appropriate? i) Employment Welwyn Hatfield Response 7.1. As previously noted in the Council’s response to the Inspectors preliminary Q32 in document EX11, the overall level of employment floorspace provision proposed in the submitted Local Plan is appropriate and justified by the evidence at the time the Plan was prepared. The Plan identifies 294ha of employment land to support and maintain a sufficient supply of jobs in the Borough during the Plan period. 7.2. Policy SP2 of the Local Plan supports a level of growth consistent with the vision and objectives of the strategy and the principles of sustainable development, and it proposes provision of 116,400sqm of new employment floorspace between 2013 and 2032 from designated employment areas and mixed-use sites. This level of provision should support growth of 16,900 jobs over the plan period1, which the evidence base recommends is required in the area. 7.3. The Welwyn Hatfield Economy Study undertaken by Atkins (July 2014) (ECO/5), which has been reviewed and partially updated (December 2015 – ECO/7; and February 2017 – ECO/9) has informed policy formulation. Part of the 2015 Study considered how much growth would be appropriate for the borough for the plan period and considered two economic forecasts; Experian and the East of England Forecasting Model (EEFM). Both of these forecasts are highly respected and widely used, though as with all economic forecasts they do vary over time. Both forecasts gave broadly similar overall figures for employment growth in the Borough, although the way that these overall figures was made up was different. 7.4. As noted in the Council’s response to the Q27 in Document EX11, the 2015 Economy Study Update (ECO/7) considered four scenarios for jobs growth. The Study concluded that it was difficult to determine which of the two economic forecasts (Experian/EEFM) would be the most accurate, and that a trend based scenario appeared to be unrealistic, particularly around B2 and B8 demand. Therefore it recommended that most appropriate scenario was a hybrid one, and that this should be used to inform the supply / demand balance assessment, hence the decision to make provision for sufficient land to support 16,900 jobs across the plan period. 7.5. This proposed provision was also compared to historic performance in the period 2000 – 2013 (Council’s response Q29 in document EX11) where forecast growth in Welwyn Hatfield was compared to neighbouring authorities, using figures from the EEFM. This analysis also showed that the proposed provision in Welwyn Hatfield would give annual employment growth of 1.1% compared to a historic performance of just over 2% over that period. 1 Paragraph 5.5 of the Plan 2 7.6. As well as considering economic forecasts, and then taking a hybrid of two forecasts, the analysis also uses assumptions about jobs density and plot ratios, using the published Employment Densities Guide (Second Edition 2010) from the Homes and Communities Agency in order to convert these employment forecasts to floorspace requirements to inform the Plan. This guidance is a recognised and widely used standard. 7.7. Whilst the capacities of the sites proposed for allocation are indicative, and clearly may vary upwards or downwards when planning applications are received, they are considered to be sufficiently robust at this stage and proportionate to inform the Local Plan. 7.8. Representations: Representations suggested that the proposed provision for employment was inappropriate. Changes sought either an increase in provision - as there was insufficient provision to meet needs over the plan period; or a decrease in provision - as there is already sufficient provision. Further that exceptional circumstances did not exist to justify the loss of Green Belt land to provide new employment areas, as existing (the loss of existing employment land to other uses should be stemmed). 7.9. Why the plan is sound: The Draft Plan is positively prepared, helping to create the right conditions for the local economy to grow sustainably alongside housing growth and ensuring that as far as possible, the borough is an attractive place for investment. However, a recent assessment of employment floorspace indicates that supply has fallen. Whilst it remains possible to achieve the forecasted jobs growth from the hybrid without the provision of additional land, this would require a number of circumstances to align (job densities, home working etc.). It is therefore accepted that employment growth of 15,600 jobs is more likely to be achievable than the 16,900 figure indicated in the Plan. However, given the volatility of economic forecasts, it is considered appropriate to review the need for additional floorspace through future Plan reviews (by which time, the Council will have introduced Article 4 Directions to help stem the loss of further employment floorspace). What are the ramifications of the loss of employment floorspace to dwellings for future levels of employment? Welwyn Hatfield Response 7.10. As previously referred to in the Council’s response to Q31 in document EX11, it is relatively easy to change employment land to residential. This is mainly due to B1 offices to residential permitted development rights (introduced in 2013 for a temporary period but now permanent); and the NPPF2 advising against the long-term protection of employment sites in light of market signals. 2 Paragraph 22 of the NPPF 3 7.11. Resultant losses of employment floorspace reduces the choice of available stock for businesses wishing to locate in the area, new businesses wishing to start, or existing businesses wishing to expand. The losses of floorspace through permitted development has not been limited to vacant premises, and the Council is aware of instances of current tenants not having their leases renewed so that landlords could pursue residential development. 7.12. Between 1st April 2013 and 31st March 2017, the borough lost a net 9,632 sq m of B class floorspace. Whilst provision is made within the employment floorspace trajectory for losses (alongside windfall gains in dwellings), the losses have exceeded that anticipated at this point of the plan period. This resulted in the conclusion that employment growth of 15,600 jobs is more likely to be achievable than the 16,900 figure indicated in the Plan. 7.13. However, this would still provide a significant level of jobs growth for the economically active population, so it is not considered that there will be an adverse effect on achieving sustainable development. 7.14. Further, jobs will also be available in other non-B sectors and it is generally acknowledge that economic forecasting is not an exact science and is liable to be influenced by multiple factors, which may not always be predictable. 7.15. However, over time, further losses of employment floorspace could negatively affect the type and choice of premises available to businesses within the borough. This could restrict job and economic growth, meaning that future housing growth may not be as in line with employment growth as would be desirable. This will need to be monitored and reviewed over the plan period. An Article 4 Direction is considered necessary as soon as possible in order to protect the borough’s supply of office floorspace. For this, an adopted Local Plan. Is required. ii) Housing Welwyn Hatfield Response 7.16 Yes, as noted in examination document EX11, the Council considers that the target for housing growth is appropriate. The target is the sum of the capacity from all sources as set out in Table 2 of the Plan – Distribution of housing growth. The total capacity is just over 12,000 dwellings. 7.17 A proportionate evidence base, relating to the windfall allowance and the selection of sites informs the target. The Housing and Economic Land Availability Assessment 2016 (HELAA) (HOU/19), assessed whether sites were suitable, available and achievable, with deliverability estimates in light of the information available at that time. The Housing Sites Selection Background Paper 2016 (HOU/20/20a) drew the results of the HELAA together with key outputs from the Green Belt Sites Review, the implications for defining a new Green Belt boundary, the Sustainability Appraisal, the sequential test (flood risk management) and any strategic advantages or disadvantages. 4 7.18 The capacity of infrastructure to support potential levels of growth was also considered in the Background Paper highlighting matters of concern and the implications for allocating sites. 7.19 A shortfall against the OAN has arisen. No authority within the wider WH HMA can assist in meeting the shortfall between Welwyn Hatfield’s housing target and its OAN at the current time. Our response (EX04) to Q16 of the Inspector’s preliminary questions on Matter 1 - The Duty to Cooperate, sets out a number of steps that the Council is taking to explore the options and solutions for meeting longer-term housing needs. The Council has also committed to an early plan review in order to address the infrastructure constraints required to support additional levels of growth. 7.20 This strategy has a number of parallels with the Luton Local Plan, which has recently reported3. The Plan was found sound (subject to a number of modifications). 7.21 Similar to Luton, Welwyn Hatfield has a District Plan adopted over a decade ago (in 2005) covering a period to 2011. It is therefore important that a plan is put in place as soon as possible which brings forward a supply of land for housing and other uses to provide a more robust basis for development management decisions and providing greater certainty for developers, local people and other parties, including those making decisions on infrastructure4.

Load more