St Albans Strategic Local Plan Publication 2016 Representations by DLA Town Planning On behalf of Jarvis Group Ltd Various sites DLA Ref: Various sites February 2016 0 DLA Ref: Various Sites February 2016 CONTENTS 1.0 EXECUTIVE SUMMARY ................................................................................................ 2 2.0 INTRODUCTION ........................................................................................................... 4 3.0 REPRESENTATIONS TO POLICY SLP8 ............................................................................ 5 4.0 REPRESENTATIONS TO POLICY SLP1 .......................................................................... 22 5.0 CONCLUSIONS ........................................................................................................... 27 6.0 TABLES ....................................................................................................................... 28 1 DLA Ref: Various Sites February 2016 1.0 EXECUTIVE SUMMARY 1.1 Representations made at the pre-submission stage must be based on the soundness of the SLP, as defined in para 182 of the NPPF. Taken as a whole the published SLP is manifestly Application unsound for the following reasons: Site Soundness Test 1 – Positively prepared The SLP is not sound because it is not based on a robust objective assessment of housing need. If the objectively assessed need for housing (OAN) had been properly assessed, in line with Government guidance, a significantly higher housing target would be required, which the SLP in its current form is unable to meet. The Council’s OAN assessment is: o Not up to date – demographic projections pre-date Census information and latest household representative rates. o Based on inappropriate assumptions about past trends o Unsupported by Council's own consultants o Is not adjusted for market signals There has been no consideration of how the SLP could help meet unmet needs from neighbouring authorities. o Dacorum Borough has a challenging new housing target, yet the SLP uses land on the edge of Hemel Hempstead to meet St Albans’ need; o No consideration is given to meeting unmet needs from Luton. Soundness Test 2 – Justified Policy SLP1 is not the most appropriate strategy when considered against reasonable alternatives. The strategy presents an unbalanced housing supply with too great an emphasis on large sites and not enough provision made for small-scale sites. The SLP’s supporting evidence is not up-to-date – the SHLAA dates from 2009 and was based on a previous and very different policy context. The demographic modelling was undertaken in 2013 and pre-dates the release of key Census 2011 data, the CLG Household Projections and new Household Representative Rates. The last detailed review of Green Belt boundaries was in the early 1980s. Soundness Test 3 – Effective There are deliverability doubts about the plan given the emphasis on several large sites Housing provision requires an average of 40 dwellings per hectare, considered to be difficult to deliver given density of surrounding development and scale of infrastructure needed. 2 DLA Ref: Various Sites February 2016 There are no meaningful contingency arrangements if housing provision does not proceed as expected. Soundness Test 4 – Consistent with national policy The SLP fails to significantly boost housing supply – one of Government’s top priorities Demonstrating a five-year housing land supply in a local plan is crucial – SLP cannot demonstrate a five-year housing land supply, even measured against its own constrained housing target. A summary of proposed changes 1.2 To fully respond to the challenges facing St Albans district an entirely new plan is needed and the Council should commit to starting this work immediately. However, in the meantime an interim plan is needed based on the OAN set out in the South West Hertfordshire SHMA of 705dpa. To address this need in the short-term consideration should be given to allocating additional sites from those already featured in the Council’s evidence base and to including positive policies that will deliver housing elsewhere in the district. 3 DLA Ref: Various Sites February 2016 2.0 INTRODUCTION 2.1 These representations relate to the pre-submission version of the Strategic Local Plan (SLP) for St Albans, published on 8 January 2016 under Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012. 2.2 These representations are intended for the consideration of the Planning Inspector appointed to conduct the public examination of the SLP, once it is submitted by St Albans City and District Council (SADC). However, clearly SADC will need to consider these representations before deciding whether to submit the SLP as published of whether to propose further changes to make it sound and then re-publish. 2.3 These representations highlight a number of important flaws in the published SLP, as summarised. Proposed changes are set out that could remedy some of these flaws on an interim basis, although the picture will not be complete until a full review of the local plan is produced. 4 DLA Ref: Various Sites February 2016 3.0 REPRESENTATIONS TO POLICY SLP8 Summary 3.1. Policy SLP8 is unsound for the following reasons: Soundness Test 1 – Positively prepared It is not based on a robust objective assessment of housing need. If the objectively assessed need for housing (OAN) had been properly assessed, in line with Government guidance, a significantly higher housing target would be required, which the SLP in its current form is unable to meet. The Council’s OAN assessment is: o Not up to date – demographic projections pre-date Census information and latest household representative rates. o Based on inappropriate assumptions about past trends o Unsupported by Council's own consultants o Is not adjusted for market signals There has been no consideration of how the SLP could help meet unmet needs from neighbouring authorities. o Dacorum Borough has a challenging new housing target, yet the SLP uses land on the edge of Hemel Hempstead to meet St Albans’ need; o No consideration is given to meeting unmet needs from Luton. Soundness Test 2 – Justified Policy SLP8 is not the most appropriate strategy when considered against reasonable alternatives. The strategy presents an unbalanced housing supply with too great an emphasis on large sites and not enough provision made for small-scale sites. The SLP’s supporting evidence is not up-to-date – the SHLAA dates from 2009 and was based on a previous and very different policy context. The demographic modelling was undertaken in 2013 and pre-dates the release of key Census 2011 data, the CLG Household Projections and new Household Representative Rates. Soundness Test 3 – Effective There are deliverability doubts about the plan given the emphasis on several large sites Housing provision requires an average of 40 dwellings per hectare, considered to be difficult to deliver given density of surrounding development and scale of infrastructure needed. Soundness Test 4 – Consistent with national policy The SLP fails to significantly boost housing supply – one of Government’s top priorities 5 DLA Ref: Various Sites February 2016 Demonstrating a five-year housing land supply in a local plan is crucial – SLP cannot demonstrate a five-year housing land supply, even measured against its own constrained housing target. Proposed changes summary To fully respond to the challenges facing St Albans district an entirely new plan is needed and the Council should commit to starting this work immediately. However, in the meantime an interim plan is needed based on the OAN set out in the South West Hertfordshire SHMA of 705dpa. Assessing housing need – Planning Practice Guidance 3.2. The Government’s Planning Practice Guidance (PPG) sets out a recommended approach to assessing housing needs. The “starting point estimate” for overall housing need should be the Household Projections published by the Department for Communities and Local Government (CLG) (Reference ID: 2a-015-20140306). These projections are produced at the national level so shouldn’t be accepted without critical analysis. However, any deviation from the national set of projections should be based on evidence and fully justified. The SLP proposes a housing target (436 dwellings per annum) which is more than 30% lower than the most recent (2012-based) CLG household projections (637dpa). In the SLP evidence base the most recent CLG household projections are not considered in any meaningful way and the substantial deviation is nowhere explained or justified. 3.3. The PPG goes on to explain the adjustments that may be necessary to the starting point estimate: “The household projection-based estimate of housing need may require adjustment to reflect factors affecting local demography and household formation rates which are not captured in past trends. For example, formation rates may have been suppressed historically by under-supply and worsening affordability of housing.” 3.4. Completion rates have not kept pace with projected household formation rates in St Albans for many years. This issue does not appear to have been considered in detail in the SLP evidence base. 3.5. The starting point estimate should also be considered in the light of information on a range of market signals, including land prices, house prices, rents, affordability, rate of development, overcrowding. According to the PPG a “worsening trend in any of these indicators will require upward