Section 4 of the DaSA Local Plan, which relates to housing, is not sound as it has not been positively prepared, is not effective and is not consistent with national policy.
1.2 The fundamental issue with the DaSA is that it forms Part 2 of the Core Strategy and has been prepared to be in conformity with it, yet the Core Strategy was adopted four years ago and is based on evidence that is now over six years old and it is no longer compliant with national policy.
1.3 The DaSA should have represented an opportunity for the Council to provide a review of the Core Strategy and update the elements that are out of date, such as the housing requirement.
1.4 These points will be explained in more detailed below.
Core Strategy Background
1.5 The Objectively Assessed Need (OAN) that informed the housing requirement was based on 2011-based household projections. This produced an annual housing
requirement of 338 dwellings per annum (Policy OSSS1) over the 17-year plan period.
1.6 The Planning Inspector assessing the soundness of the Core Strategy stated in
paragraph 36 that:
36. By comparison, the SHMA 2013 notes that the 2008-based projections as used in the 'How Many Homes' model suggests an annual increase in households of 584 in Rother, compared to 338 households per annum for the 2011-based revised
projection. This is an indication that if the economy improves significantly, it may lead to higher levels of housing need and the Council will need to keep this under review to ensure that the CS is kept up to-date. However, I am satisfied that the SHMA 2013 is an acceptable assessment of housing need to inform the strategy at the present time, albeit that the figure of 13,041 across the HMA may represent the lower end of a range of potential outcomes.
1.7 The Planning Inspector clearly felt that based on the evidence available, the 338 figure represented the OAN at that time, but was also clear that a precautionary approach was required to ensure that the Core Strategy remained up to date. This would involve regularly reviewing the OAN for the District.
1.8 To date, the most recently produced SHMA or OAN is still the 2013 SHMA considered by the Planning Inspector assessing the Core Strategy. This evidence is inherently out of date as it is based on 2011-based household projections and the lack of an update version also runs contrary to the advice provided by the Planning Inspector.
National Planning Policy
1.9 Paragraph 31 of the NPPF states that the preparation and review of all policies should be underpinned by relevant and up-to-date evidence. It states that this should be adequate and proportionate, focused tightly on supporting and justifying the policies concerned, and take into account relevant market signals.
1.10 Paragraph 33 of the NPF states that policies in local plans and spatial development strategies should be reviewed to assess whether they need updating at least once every five years, noting that reviews should be completed no later than five years from the adoption date of a plan, and should take into account changing circumstances affecting the area, or any relevant changes in national policy. It also states that strategic policies will need updating at least once every five years if their applicable local housing need figure has changed significantly.
1.11 Regulation 10A of the Town and Country Planning (Local Planning) (England)
Regulations 2012, makes it a requirement to review all local plans every five years.
Critically, the review should not commence at the five-year mark, but be completed by then.
1.12 The Core Strategy was adopted four years ago and to date there is no evidence that the Council has undertaken a review of its strategic housing policies, as they have not updated any of the housing evidence that underpinned by the Core Strategy.
1.13 The Council's absence of an up to date evidence base and lack of a Core Strategy review runs contrary to national policy. It is not realistic that they will have completed this exercise within the 12 months.
The Standard Method
1.14 Paragraph 60 of the NPPF states that to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance.
1.15 The PPG states:
When should strategic policy-making authorities assess their housing need figure for
policy-making purposes?
Strategic plan-making authorities will need to calculate their local housing need figure at the start of the plan-making process. This number should be kept under review and revised where appropriate.
The housing need figure generated using the standard method may change when
National Household projections and affordability ratios are updated by the Office of
National Statistics and this should be taken into consideration by strategic policy making authorities.
Paragraph: 008 Reference ID: 2a-008-20180913
1.16 It also states:
For how long can an estimate of local housing need be relied upon once a plan is
submitted to the Planning Inspectorate?
Local housing need calculated using the standard method may be relied upon for a
period of 2 years from the time that a plan is submitted to the Planning Inspectorate
for examination.
Paragraph: 016 Reference ID: 2a-016-20180913
1.17 Using the standard method calculation for Rother District, it is clear that the District requires a significant uplift in housing provision to meet the OAN.
- Using 2016-based household projections for England, Rother District
has a requirement for 4,962 dwellings or 496.2 per annum (43,297 in
2018 and 48,259 in 2028).
- The authority's workplace-based affordability ratio is 11.04
- The adjustment factor is 0.44
- Minimum annual local housing need figure = (1 + adjustment factor) x
projected household growth
- Minimum annual local housing need figure = (1 + 0.44) x 4,692
- The resulting figure is 6756.48 or 675.7 per annum
1.18 The 675.7 minimum housing need figure is double the Core Strategy figure and in itself should trigger a review of the Core Strategy, which would have implications for the spatial strategy for the District as a whole.
Planning Implications
1.19 Whilst we accept that the Council needs to deliver strategic sites to meet the housing growth, the sites within DaSA do not go far enough to meet the OAN and there is a need for significantly greater growth than set out.
1.20 Rather than pursue the DaSA as Part 2 of the Core Strategy, the Council needs to undertake a full review of its Core Strategy and set out all sites required to deliver it full OAN.