Michael Young has kindly provided a post-examination summary of the situation regarding Uttlesford’s housing target. Michael spoke at the Local Plan examination arguing that the OAN (objectively assessed need) for the district is too high. This commentary reveals a systemic over-provision among some Conservative-controlled councils.
The Uttlesford examination
At the public examination I argued that the ORS figures for Uttlesford prepared by ORS (Opinion Research Services) are wrong and too high. I am sure I am right. ORS (Opinion Research Services) was commissioned jointly by Uttlesford/Harlow/East Herts/Epping Forest councils.
I asked, yet again, why ONS (Office for National Statistics) projections have Epping 20% – 25% greater than Uttlesford yet every ORS working has Uttlesford higher. For the first time I got a response. According to ORS Epping has more constraints. I have no idea what these are. It can’t be green belt because we are talking about housing need, not the ability to deliver it.
But my more important point concerned the use of the 2016-based household projections issued by the ONS in September 2018. These showed lower figures for most districts including Uttlesford. I believe it could bring the Uttlesford figure down to around 11,575 to 12,100). Last October I argued at a UDC council meeting that these latest projections should be used. UDC’s response was that there was insufficient time to change. I thought that was the end of it until I discovered the outcome of the Guildford Local Plan examination.
Guildford’s local Plan was submitted in December 2017. Like the UDC plan it was under the old NPPF that states that up-to-date figures should be used.
As the examination continued they recalculated their housing need based on latest government figures (published during the course of the examination), and the Inspector accepted this. The Inspector’s final report was issued in March 2019.
Guildford’s Local Plan originally had a housing need figure of 12,426 (over 19 years). The Inspector agreed that using the latest “2016” based projections (issued in 2018) this figure could be reduced to 10,678.
But Guildford is actually now aiming to supply some 14,600 (almost 4,000 more than the apparent need). One parish council has already applied for a judicial review (having raised £30,000 from local residents) and two more are lining up.
Guildford’s Local Plan was adopted just a week before the local elections when the Conservatives lost control. Their’s was the third largest loss by a ruling Conservative group. Uttlesford was first and Vale of White Horse second. All three have major housing issues.
This plan, covering 20 years, is currently nearing the end of public examination. From what I can make out the Inspector must have asked the council about the effects of the 2016-based household formation projections published by ONS.. The council produced a paper showing that it would reduce the housing requirement from 13,800 to 11,000.
Interestingly the 13,800 figure was calculated by ORS, the same organization used by Uttlesford. However, the council’s report argues strongly that the housing need figure should not be reduced quoting national needs and that, if the figures were reduced, an early review would be required, which, under the latest standard method, would simply bring the figure back up again.
The Inspector has written back in fairly candid terms on a number of different issues. With regard to a possible reduction in the numbers he states that he has to determine whether the reduction amounts to a ‘meaningful change’ and at face value he thinks it does. Since he considers this vital to the soundness of the Local Plan it is unfair to participants to proceed without a new hearing.
Despite an originally assessed need of 13,800 the North Herts Local Plan actually envisages a supply of a massive 15,950 new houses including intrusions into the green belt.
North Herts is controlled by the Conservatives. They hold elections in thirds. This year the Conservatives lost 7 of the 14 seats they were defending.
Post script by StopNUtown
• It is interesting how these three examples of what were then Conservative-controlled councils adopted high estimates of housing need only for the Inspector in the case of Guildford and North Herts to suggest they should be lower. Will the Inspector come to the same conclusion for Uttlesford?
• We still await a plausible explanation for deciding UDC’s housing need on the basis of a “strategic market” assessment based on an area surrounding the south of the district and then putting 30% of the resulting housing requirement in the north of the district adjoining a different market area.