What Are the Objectively Assessed Needs for …parties before any further hearing sessions resume. On 14 October 2014, a technical workshop was held in the Council Chamber, Ebley Mill,

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What Are the Objectively Assessed Needs for Housing in Stroud District?

Statement of Common Ground: Summary of Questionnair e Results

Background

The Stroud District Local Plan was submitted to the Planning Inspectorate in December 2013. Examination hearing sessions dealing with housing requirements were held in April 2014. The Inspector’s Stage 1 initial conclusions were published in June 2014. The Inspector concluded that further work was necessary to ensure that a soundly based objective assessment of housing requirements has been undertaken.

The District Council commissioned Neil McDonald (NMSS) in July 2014 to undertake a study of the objectively assessed needs for housing in Stroud from first principles.

In response to a query from a hearing participant, the Inspector asked the Council to consider holding a technical workshop with representors who challenged the objective assessment of housing need, in order to try to narrow the issues in dispute and prepare a Statement of Common Ground identifying areas of agreement and disagreement. This may assist in establishing the respective positions of the various parties before any further hearing sessions resume.

On 14 October 2014, a technical workshop was held in the Council Chamber, Ebley Mill, Stroud. A draft Executive Summary and presentation slides were circulated in advance of the workshop on 10 October 2014. Participants asked questions and gave views during the workshop and were given until 24 October 2014 to write in with further comments and queries. Five responses were received.

Following the workshop, Neil McDonald completed his final report taking into account views expressed during and after the workshop. The final report was sent to representors on 5 November 2014.

Statement of Common Ground

The District Council prepared a focused questionnaire which was sent to representors on 5 November 2014 for completion and return by 26 November 2014.

The intention has been to compile a factual Statement of Common Ground between the Council and representors, identifying the areas of agreement and disagreement.

The following sections set out the questions asked and a factual summary of the responses received. Appendix 1 sets out the responses received in their entirety.

It will be for the Inspector to seek clarification of positions through the future hearing session on housing requirements scheduled for 29 January 2015.

Stroud District Council, 12 December 2014

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Summary of Questionnaire Responses

A. Population Forecasts:

The report takes as its starting point the populati on estimates from the interim 2011 based sub national population projections for England (2011 SNPP) and the 2012 sub national population projections for En gland (2012 SNPP). The report concludes that the 2012 SNPP, with due allow ances, should generally be adopted as the more reliable projection.

Do you agree with this approach? Yes/No

Yes Conditional Yes No No Comments Bruton Knowles on behalf of the Pullen Family - Rep 44

Aspect360 on behalf of the Hardwicke Court Estate - Rep 125

DLP Planning on behalf of Hallam Land Management (DLP) - Rep 75

Origin3 on behalf of Taylor Wimpey - Rep 59

Dursley Town Council (Dursley TC) - Rep 121

RPS on behalf of Redrow Homes Ltd – Rep 125

Don’t Strangle Stroud, Eastington Parish Council in association with Strategic Planning Alliance (DSS/EPC) - Rep110

Home Builders Federation (HBF) - Rep 50

Keep Eastington Rural (KER) - Rep 144

Pegasus Group on behalf of Robert Hitchins Ltd - Rep 109

Regeneris

Consulting on behalf of Gladman Developments - Rep 64

Reason for Conditional Agreement:

• Concern is expressed at the subjective wording of the statement for inclusion in a Statement of Common Ground but the 2012 SNPP are accepted as the starting point for determining the Objectively Assessed Need (OAN) for Stroud. [Aspect360, RPS]

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Reasons for disagreement:

• Agree the 2012 SNPP is the appropriate starting point, but disagree with the ‘due allowances’ and therefore the outcome. [DLP]

• The ‘due allowances’ are not valid. [DSS/EPC, KER]

B. Components of Change:

The report examines data relating to various compon ents of change - Births, Deaths, UK inflow, UK outflow, International migrat ion in and international migration out.

Births:

The report concludes that the 2012 based projectio ns are a better basis for forecasting future births than the 2011 based proje ctions.


Yes Conditional Yes No Comment Bruton Knowles Aspect360 Origin3 DLP RPS

DSS/EPC Dursley TC HBF KER Pegasus Regeneris

Reasons for Conditional Agreement:

• It is queried whether the population profile has been used directly, or whether the fertility rates have been used and applied to a base population profile? [Aspect360, RPS]

• It is suggested that age specific fertility rates are integral to establishing revised population projections, to that of the baseline 2012 SNPP. [Aspect360, RPS]

Deaths:

The report concludes that there is no reason to que stion this aspect of the 2012 based projections.


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Yes Conditional Yes No Comment Bruton Knowles Aspect360 Origin3 DLP RPS

DSS/EPC Dursley TC HBF KER Pegasus Regeneris

Reason for Conditional Agreement:

• It is queried whether actual projection data or age specific mortality rates have been used? [Aspect360, RPS]

UK Inflows and UK Outflows

The report adjusts UK inflows and outflows based on the ratio of the average annual flows over a 10 year period 2002 – 2012 to t he flows over the period 2007- 2012, rather than the 2012 based projections which reflect a 5 year trend 2007-2012.


Yes No No Comment Aspect360 DLP Origin3 Bruton Knowles DSS/EPC Dursley TC KER HBF Pegasus RPS Regeneris

Reasons for disagreement/ suggested alternative app roach:

• Suggested approach - Model the level of total net in migration as being 1,100 to 1,400 persons a year based on the outputs of the accepted Chelmer Model meeting the growth in labour force for the period 2014 – 2031 of between 2444 and 4403 persons (CE and OE projections page 76).[DLP]

• Returning to trend, a lower population projection should be used, deflating the housing requirement, and reducing the OAHN by 50 houses.[ DSS/EPC, KER]

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International Migration Flows

The report concludes that there is no reason to que stion this aspect of the 2012 based projections.


Yes No No Comment Bruton Knowles Aspect360 Origin3 DLP RPS DSS/EPC Dursley TC HBF KER Pegasus Regeneris


• The 2012 SNPP is considerably underestimating the level of international migration. [Aspect360, RPS]

• A sensitivity test of increasing international migration proportionally to reflect recent net migration should be incorporated. [Aspect360, RPS]

Unattributable Population Change (UPC)

The report includes the UPC for Stroud (for the per iod 2001-2011) in the calculation.


Yes No No Comment Aspect360 DLP Origin3 Bruton Knowles DSS/EPC Dursley TC KER HBF Pegasus RPS Regeneris


• The use of the 2012 SNPP does not require any adjustment for UPC. [DLP, DSS&E, KER]

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• Removing the UPC for Stroud from the calculation reduces the OAHN by 200 houses. [DSS/EPC, KER]

C. Estimate Population

The report estimates an increase of 14,100 people i n Stroud in the period 2011-2031 (or 16,700 people in Stroud in the period 2006 -2031).

Do you agree with these figures? Yes/No

Yes No No Comment Bruton Knowles Aspect360 Origin3 Dursley TC DLP HBF DSS/EPC Pegasus KER Regeneris RPS


• Unable to agree a figure without clarification of the above issues. [Aspect360, RPS]

• Based on the outputs of the Chelmer Model using the 2012 SNPP, the employment projections of an increase in jobs of between 2,444 and 4,403 jobs would require a population growth of between 19,338 and 22,452 persons. [DLP]

• There is no evidence for increasing the ONS projected figure of 13,600. [DSS/EPC, KER]

D. Household Formation Rates

The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are half way between the 2008 an d 2011 based rates. Thereafter household formation rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups. Do you agree with this approach? Yes/No

Yes No Bruton Knowles Aspect360 Dursley TC DLP DSS/EPC HBF KER Origin3

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Yes No Pegasus RPS Regeneris


• This is a significant issue and the approach requires further consideration and discussion amongst the interested parties and with the Inspector. [Aspect360, RPS]

• HFR for all age groups should be modelled to improve affordability and accessibility, and increase opportunities for home ownership. [DLP]

• The approach overestimates the OAHN by 250 houses. [DSS/EPC, KER] • Further sensitivity testing should be undertaken for assumptions on:-

i) A full return to trend, ii) A blended rather than mid-point approach. [HBF]

• A greater alignment with the 2008 headship rates should be used, until more reliable data becomes available which references a longer term trend. [Origin3]

• As a minimum, a consistent full return to trend (rebased to take account of the 2011 Census) should be used for all age groups in order that the negative trends experienced during the recession are not planned for. [Pegasus]

• As a minimum, the approach should assume full return to trends for those aged 25 to 34 in Stroud. Applying full return to trends for this age group would increase the OAN purely on a demographic basis by around 30 dpa to 460 dpa.[Regeneris]

E. Empty and Second Homes

The report includes an allowance of 3.96% for empty and second homes

Do you agree with this figure? Yes/No

Yes No Reasonable Aspect360 DSS/EPC Origin3 Bruton Knowles KER DLP Dursley TC HBF Pegasus RPS Regeneris

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Reason for disagreement/ suggested alternative appr oach:

• The 3.2% figure previously presented by Stroud District Council is informed by more up to date information.[DSS/EPC, KER]

F. Housing Needed from Demographic Calculations

The report states that 8,700 additional homes will be needed 2011-2031 (10,400 additional homes for 2006-2031) based on demographi c based calculations


Yes No Bruton Knowles Aspect360 Dursley TC DLP DSS/EPC HBF KER Origin3 Pegasus RPS Regeneris


• The assumptions that have been used in arriving at the demographic OAN are not fully agreed. In particular Headship Rates. [Aspect360, HBF, Origin3, Pegasus, RPS]

• The Chelmer Model based on the 2012 SNPP suggests a slightly lower requirement of 8,500 dwelling or 425 dwellings a year. This does not model the higher levels of migration over the 5 year period or the increase due to the unattributed population change. [DLP]

• The correct (ONS – advised) demographic based calculation would be -8,200 [DSS/EPC, KER]

• As a minimum, suggest that for those aged 25 to 34 there should be full return to trends by 2031, adding 20 to 30 dpa to the base demographic OAN. [Regeneris]

G. Market Signals

The report states that there is no strong case for additional housing on this ground

Do you agree? Yes/No

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Yes No Bruton Knowles Aspect360 DSS/EPC DLP Dursley TC HBF KER Origin3 Pegasus RPS Regeneris


• The 2014 Strategic Housing Market Assessment (SHMA) published by Stroud District, indicates that the scale of key housing market gaps in Stroud is significant, and that housing market signals justify uplift. [Aspect360, RPS]

• There has been persistent under provision against actual need since the 1990s.[DLP]

• The market signals on house prices and rents in Cotswolds and on affordability in Forest of Dean suggest that an upward adjustment to OAHN is required. [HBF]

• The evidence suggests that there should be some recognition of market signals within the OAN.[Origin3, Pegasus]

• Argue strongly for the use of “undiluted” 2008 long term trend household formation rates. [Regeneris]

H. Under Supply



Yes No No Comment DSS/EPC Aspect360 Origin3 Dursley TC Bruton Knowles KER DLP HBF Pegasus RPS Regeneris

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• The evidence available to the Inspector, reference appeal decision APP/C1625/A/11/2165671, demonstrates that the Council has persistently under-delivered against local housing need, and this component of market signals justifies uplift. [Aspect360, RPS]

• The housing figures need to be increased by at least 5% in the first five years. [Bruton Knowles]

• When considering future levels of provision, including those higher levels required to meet economic projections, historic undersupply adds considerable weight to the higher of these projections. [DLP]

• At least a further 400 homes should be provided to address the unmet need arising from previous under-supply in Stroud. [Pegasus]

I. Concealed Families



Yes No No Comment Bruton Knowles Aspect360 Origin3 DSS/EPC DLP Dursley TC HBF KER Pegasus Regeneris RPS


• Uplift is required to the base demographic scenario on the basis of all affordability components, including Concealed Families. [Aspect360, RPS, Pegasus]

• Draw attention to the need to address the considerable growth in the number of unrelated adults sharing accommodation as a consequence of the long term worsening affordability over the past two decades. [DLP]

J. Overcrowding



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Yes No No Comment Bruton Knowles Aspect360 Origin3 DSS/EPC DLP Dursley TC HBF KER RPS

Pegasus Regeneris

Reason for disagreement/ suggested alternative appr oach:

• Uplift is required to the base demographic scenario on the basis of all affordability components, including Overcrowding. [Aspect360, DLP, RPS,]

K. Affordable Housing



Yes No DSS/EPC Aspect360 Dursley TC Bruton Knowles KER DLP HBF Origin3 Pegasus RPS Regeneris


• Uplift is required to the base demographic scenario on the basis of all affordability components, including Affordable Housing. [Aspect360, RPS]

• The extent of the affordable housing requirement is so substantial that there is a case for extending the overall requirement to allow for new sources of supply to bring forward additional affordable homes.[Bruton Knowles, Regeneris]

• The latest SHMA suggests a requirement of 477 affordable dwellings a year (Table A5.1 Housing needs assessment model for Stroud) and has to be a consideration in determining the overall level of housing need in the District. [DLP]

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• The SHMA should make some allowance for structural change in the housing market, including increasing the supply of affordable housing and the effect this will have on the demographic based estimate.[Origin3]

• An up-to-date assessment of the objectively assessed need for affordable housing is required. However, the affordable need identified in the now out-of-date SHMA could be met by providing for a minimum of 10,700 homes (plus historic unmet needs of approximately 400 dwellings needs) assuming 30% of delivery is affordable. This will increase once the required assessment is undertaken, but provides a useful indication for now. [Pegasus]

L. Supporting Economic Growth

Economic Forecasts

The report uses the latest 2014 economic projection s from two forecasters – Cambridge Econometrics and Oxford Economics.


Yes Parti al Yes No Bruton Knowles Regeneris Aspect360 Dursley TC DLP Origin3 DSS/EPC HBF KER Pegasus RPS

Reason for partial agreement:

• Concerned with how the forecasts have been used and interpreted with regard to reviewing past trends and focusing on the downsides of the employment forecasts rather than providing a balanced assessment. [Regeneris]


• Economic scenarios should also use Nomis, for past evidence, and the Strategic Economic Plan (SEP) of the Gloucestershire Local Economic Partnership ( LEP). [Aspect360, RPS]

• Future employment growth should also utilise employment forecasts produced by Experian. [DLP]

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• Question how the South West regional data from CE has been ‘normalised’ for Stroud and why the more accurate, Stroud specific data from OE has not been used. [DSS/EPC, KER]

• Consideration should also be given to the inter-relationship between OAHN and the Gloucestershire LEP SEP. [HBF, Pegasus]

Economic Activity Rates

The report suggests that in estimating the labour f orce and hence housing implications of the econometric projections, econom ic activity rate assumptions consistent with the projections being i nterpreted should be used.


Yes No Bruton Knowles Aspect360 Dursley TC DLP Pegasus DSS/EPC HBF KER Origin3 RPS Regeneris


• The Council should set out what it considers are realistic economic activity rates across all age cohorts of its population projections and use those consistently in all sensitivity scenarios. [Aspect360, RPS)

• Include a table of proposed changes to activity rates, as a better reflection of the long term levels of activity as a result of pension age changes. [DLP]

• The approach ignores Stroud specific data. { DSS/EPC] • Inadequate explanation of the methodology behind this approach. [KER] • Request clarification of the economic activity rates used for the over 60’s.

[HBF] • Using the Gloucestershire figure of 6.1% - 6.2% appears a more reliable and

consistent approach. [Origin3] • A more robust approach is to apply plausible increases in economic activity

rates (based on national view of increases by age group) to the forecasts population in Stroud, to see what for a given population rise is the likely future workforce. This can then be compared to plausible employment forecasts to see what the implications for housing are. [Regeneris]

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Jobs Assessment Period

The report assesses how many homes will be needed t o support projected increases in jobs for the period 2014-2031.


Yes No No Comment Bruton Knowles Aspect360 Origin3 Dursley TC DLP DSS/EPC HBF KER Pegasus RPS Regeneris


• The period for job forecasts to inform local plan housing need should be based upon the Plan period from 2011. [Aspect360, RPS]

• The projections should also embrace the higher employment led forecasts for the period 2011 to 2031. [DLP]

• It is inappropriate to project economic growth over such a long timescale. A review date should be planned now, following the next census. [DSS/EPC, KER]

• Query why the jobs assessment period is different to the period for the assessment of OAHN? [HBF]

• Considering job growth from 2011 – 2014 may have demonstrated an additional need for housing. [Pegasus]

• Ignoring the jobs rise 2011 – 2014 would be a serious flaw: performance in 2011 to 2014 and subsequently is intimately linked. [Regeneris]

Interpreting the Economic Forecasts

The report suggests that a reasonable allowance for additional housing to support economic growth would be for Stroud, Cotswo ld and Forest of Dean to provide between them for half the additional hom es which the CE analysis suggests might be needed across Gloucestershire i.e . 2,700. If these are allocated in line with the relative housing numbers suggested by the CE analysis Stroud would provide 800 additional housin g (rounded).


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Yes No Bruton Knowles Aspect360 Dursley TC DLP DSS/EPC HBF KER Origin3 Pegasus RPS Regeneris


• The full CE evidence should be used from the year 2011 and a “policy off” position adopted in the assessment of OAHN: assumptions in respect of accommodating only half of the CE projection based upon the LEP position is a ‘policy on’ based assumption. [Aspect 360, RPS]

• The approach adopted by the report applies a policy decision not to meet the higher levels of housing growth required to meet the higher economic projections contrary to the Framework and OAN which requires the OAN to reflect the needs of the economy in terms of the policy off position. The level of dwellings that would actually be required to meet the projected level of employment growth is shown by the Chelmer Model. [DLP]

• The approach ignores the OE analysis for Stroud, fails to provide evidence for the number of jobs proposed and has not been endorsed through the Duty to Cooperate. The approach is also in direct conflict with the draft plan policy to reduce out commuting. [DSS/EPC, KER]

• The proposal to use only half the additional homes identified from the CE analysis is an arbitrary choice. [HBF]

• In the case of uncertainty, a precautionary approach should be taken to plan for the full objectively assessed level of growth. There is a realistic prospect that CE’s assessment of needing significantly more housing is correct and in the context of a growth agenda this should be taken as the starting point for planning purposes. [Origin3]

• The suggested revised distribution of OAN within the HMA to support economic growth would need explicit agreement from the JCS authorities that the JCS area would deliver an additional 2,700 homes to respond to the displaced economic needs of Stroud, Cotswold and the Forest of Dean.[Pegasus]

• Unclear how and why the authors have arrived at the 800 adjustment for Stroud: Based on the CE forecasts the adjustment should have been1,800 or increasing the 20 year OAN to 525 dpa - The Report needs to clarify: i) Exactly how the authors have calculated the extra housing need for “surplus” jobs over what the base labour requirement is for Stroud (Figure 40)

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ii) The assumed relationship between extra jobs and extra labour force, population and houses. [Regeneris]

M. Other Matters

Other factors which should be taken into account in identifying an OAHN for Stroud:-

• It would seem prudent to reflect the need to remedy poor past performance, affordable needs and windfall reductions by adding 20% to the first 5 years of the overall current projected requirement of 11,200 i.e. to increase to the total to 11,650, effectively adding one year’s requirement as flexibility. [Bruton Knowles]

• On the current evidence base we would suggest that the full objectively assessed need for housing taking into account improvements to the economy and changes to the pension age would require a dwelling provision of between 11,218 and 12,393 (2011 to 2031) or 561 to 620 dwellings a year. [DLP]

• The elderly population should be taken into account with respect to C2 housing: This amounts to 328 fewer houses, and 722 additional care home beds. [DSS/EPC, KER]

• The OAHN should also give consideration to the distribution of housing needs across the Gloucestershire HMA so that no unmet needs arise because an individual LPA is proposing a housing requirement in its plan below OAHN. [HBF]

• There is no objective assessment of need from 2006 to 2011 (the base date of the national household projections). [Pegasus]

• Setting an OAN from 2006, which is now 8 years ago, does not make sense: 2011 (as the JCS) is a more sensible starting point. [Regeneris]

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APPENDICES - Responses Received

Page Appendix 1: Aspect360 on behalf of the Hardwicke Court Estate

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Appendix 2: Bruton Knowles on behalf of the Pullen Family

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Appendix 3: DLP Planning on behalf of Hallam Land Management

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Appendix 4: Don’t Strangle Stroud and Eastington Parish Council in association with Strategic Planning Alliance

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Appendix 5: Dursley Town Council

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Appendix 6: Home Builders Federation

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Appendix 7: Keep Eastington Rural

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Appendix 8: Origin 3 on behalf of Taylor Wimpey

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Appendix 9: Pegasus Group on behalf of Robert Hitchins Ltd

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Appendix 10: RPS on behalf of Redrow Homes Ltd

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Appendix 11: Regeneris Consulting on behalf of Gladman Developments

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Appendix 1: Aspect360 on behalf of the Hardwicke Co urt Estate

What are the objectively assessed needs for housing in Stroud District?

Statement of Common Ground Questionnaire

Response by Aspect360 on behalf of the Hardwicke Court Estate

Background

The Stroud District Local Plan was submitted to the Planning Inspectorate in

December 2013. Examination hearing sessions dealing with housing requirements

were held in April 2014. The Inspector’s Stage 1 initial conclusions were published in

June 2014. The Inspector concluded that further work was necessary to ensure that

a soundly based objective assessment of housing requirements had been

undertaken.

The District Council commissioned Neil McDonald (NMSS) in July 2014 to undertake

a study of the objectively assessed needs for housing in Stroud from first principles.

In response to a query from a hearing participant, the Inspector asked the Council to

consider holding a technical workshop with representors who have challenged the

objective assessment of housing need in order to try to narrow the issues in dispute

and prepare a Statement of Common Ground identifying areas of agreement and

disagreement. This may assist in establishing the respective positions of the various

parties before any further hearing sessions resume.

On 14 October 2014 a technical workshop was held in the Council Chamber, Ebley

Mill, Stroud. A draft Executive Summary and presentation slides were circulated in

advance of the workshop. Participants asked questions and gave views during the

workshop and were given until 24 October 2014 to write in with further comments

and queries. Five responses were received by the District Council.

Following the workshop, Neil McDonald has now completed his final report taking

into account views expressed during and after the workshop. The full report has now

been published.


The District Council has prepared this focused questionnaire which will be used to

compile a factual Statement of Common Ground between the Council and

representors, identifying the areas of agreement and disagreement.

Representors are requested to fill in this questionnaire and to return it to Helen

Johnstone [email protected] at the District Council by 26 November

2014.

Please answer the questions set out in the questionnaire and the questionnaire

responses will be reported to the Inspector. It will be for the Inspector to seek

mailto:[email protected]

clarification of positions through any future hearing session on housing requirements,

once the examination is reopened.

Stroud District Council 5 November 2014

QUESTIONNAIRE

Instructions for completing questionnaire.

Please respond to the questions by highlighting Yes/No and provide a brief text

response where asked summarising your position. Please do not attach further

supporting information at this stage as this will not be reported to the

Inspector.

Population Forecasts

The report takes as its starting point the population estimates from the interim 2011

based subnational population projections for England (2011 SNPP) and the 2012

subnational population projections for England (2012 SNPP). The report concludes

that the 2012 SNPP, with due allowances, should generally be adopted as the more

reliable projection.

Do you agree with this approach? Conditional Yes/No (please highlight as

appropriate)

Response: The Hardwicke Court Estate does not consider that this is an acceptable

statement to include within a Statement of Common Ground given the subjective

nature of the phraseology used. The Estate will, however, agree that the evidence

contained within the 2012 SNPP is the starting point for determining the Objectively

Assessed Need for Stroud District on the basis that it represents the latest available

information in the context of paragraph 016 of the Planning Practice Guidance

(PPG).

If No, what population estimates should be the starting point for the report?

Components of Change

The report examines data relating to various components of change - Births, Deaths,

UK inflow, UK outflow, International migration in and international migration out.

Births

The report concludes that the 2012 based projections are a better basis for

forecasting future births than the 2011 based projections.

Do you agree with this approach? Conditional Yes /No

If No, what should the forecast of future births be based upon?

Response: While the Estate agrees that the 2012 based projections birth evidence

is appropriate for projecting future births associated with population projections, it is

not clear from the report or statement above on the manner in which the evidence

has been used. The report sets out at paragraph 43 that the 2012 projections for

births appear to be plausible projections, however, it is not clear from the report

whether the population profile has been used directly, or whether the fertility rates

have been used and applied to a base population profile.

This distinction is important in appraising alternative scenarios such as economic

scenarios, as it is important that age specific fertility rates are integral to establishing

revised population projections, to that of the baseline 2012 SNPP.

Further clarity is therefore required and the Estate is happy to engage further to

reach agreement on this.

Deaths

The report concludes that there is no reason to question this aspect of the 2012

based projections.


If No, what should the forecast of future deaths be based upon?

Response: The Estate agrees that the 2012 based projections are a better basis for

forecasting future deaths, however, similarly to the birth statement above, it is not

clear whether actual projection data or age specific mortality rates have been used.

Further clarity is therefore required and the Estate is happy to engage further to

reach agreement on this.

UK inflows and UK outflows

The report adjusts UK inflows and outflows based on the ratio of the average annual

flows over a 10 year period 2002 – 2012 to the flows over the period 2007-12, rather

than the 2012 based projections which reflect a 5 year trend 2007-2012.


Response: The Estate concurs that the use of a ten year observation period is more

robust in respect of internal migration trends.

If No, what should UK inflows and outflows be based upon?

International migration flows


based projections.


If No, what should the forecast of international migration be based upon?

Response: The 2012 SPPP International Migration trends are constrained at a UK

level as set out in paragraph 30 of the Council’s Report. This is currently 154,000

people per annum. However it is already observed that the national constraint has

been exceeded in 2012, 2013 and 2014, with net migration in those years

comprising 184,000, 212,000 and 243,000 respectively. This amounts to an

additional 177,000 people over the ONS constraint cap in just three years. This

accounts for more than a single year of the ONS cap in itself within the three year

period. It is therefore clear that the Governments ONS cap of 154,000 has already

been exceeded substantially.

The 2012 SNPP is therefore considerably underestimating the level of international

migration. The exceedance of the Government’s constraint is therefore a serious and

significant factor to be considered. It is also observed that the constraint of 154,000

has only been achieved once since 2004. The Council should therefore incorporate a

sensitivity test of increasing international migration proportionally as observed.

A self-imposed Government constraint is no mechanism for forward forecasts.

Unattributable population change (UPC)

The report includes the UPC for Stroud (for the period 2001-2011) in the calculation.

Do you agree with this approach? Yes/ No objection

If No, should the UPC be excluded or some other adjustment made?

Response: The Estate raises no objection to the approach used with respect to UPC

Estimate Population

The report estimates an increase of 14,100 people in Stroud in the period 2011-2031

(or 16,700 people in Stroud in the period 2006-2031).


Response: The Estate cannot at this time agree to this position as it seeks

clarification on a number of points above.

Household Formation Rates

The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are half way between the 2008 and 2011 based rates. Thereafter household formation rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups. Do you agree with this approach? Yes/No

If No, what assumptions regarding household formation rates should be used?

The Council’s Report contains a detailed review of recent changes in actual,

estimated and projected headship rates for Stroud (pp 29-35).

The most up to date official household projections are CLG’s 2011-based Interim

projections. The Council’s Report explains that the rates used in these projections

were derived from the 2011 Census. This identified household formation rates which

differed from those used in the previous (2008-based) CLG household projections.

The Council’s Report initially sets out (paragraph 46 refers) that the 2008-based

projections were based on trends which predated the economic downturn and which

could be taken as broadly indicative of previous longer term trends. However the

report subsequently suggests that as the 2008-projections failed to pick up some

trends which were apparent even before the downturn, the household formation

rates used in those projections are inappropriate as they stand and proposes a

partial return to these rates (paragraph 54 refers).

The difference between household formation rates in the two sets of projections

varies by age group. It is greatest for the 25-34 and over 60 age groups, but the

rates differ throughout the age spectrum.

For the 25-34 age group, the 2011-based projections suggest that the household

formation rates are lower than the 2008-based rates in 2011 and will continue to

diverge further over the 2011-2021 projection period.

The divergence for this age group from longer term trends is attributed in the

Council’s evidence to two factors. Firstly, significant international in-migration after

2001 reduced household representative rates because new in-migrants are more

likely to live in larger multi-person households than the rest of the population in this

age group, at least in the early years of residence. Research by Holmans1 attributes

around half of the reduction in household formation in the 25-34 age group nationally

to this cause. But as international migration levels in Stroud were less significant

than in many other areas, the report notes that the local impact might have been

less.

The second factor reducing the rate of household formation would have been an

increase in the tendency of people aged 25-34 to live together in shared houses/flats

or to remain living with parents.

ONS research2 using national data broadly supports this hypothesis. The Council’s

report sets out that this second element of change in household formation will mainly

1 Alan Holmans (2013) The Town & Country Planning Tomorrow Series Paper 16, New estimates of housing demand and need in England, 2011 to 2031, TCPA/CCHPR. 2 ONS (2012) Young Adults Living With Parents in the UK, 2011, available at http://www.ons.gov.uk/ons/dcp171776_266357.pdf and ONS (2013) Families and Households in England and Wales 2011, available at http://www.ons.gov.uk/ons/dcp171776_296986.pdf

http://www.ons.gov.uk/ons/dcp171776_266357.pdf


have been brought about by the worsening economic situation after 2007, the

collapse in housing supply, and the difficulty in obtaining mortgages. This suggests a

return towards previous trends if economic conditions improve, together with some

elimination of ‘suppressed’ household formation. However, it also argues that the

changes in household formation started before 2007 as a result of the deteriorating

affordability of housing arising from rapid increases in house prices and rents. These

causes may be more enduring, for example if mortgage finance remains more

difficult to obtain than in 2006-07. It is also suggested that welfare benefit reforms

will have a permanent impact. This would support an argument for not returning to

2008 formation rates as these may not have reflected the pre-2007 trends.

The report’s discussion of the potential causes of reduced household formation in

the 25-34 age group is interesting, but does not provide a definitive basis for

determining what might happen to household representative rates in the future. The

report itself accepts that this is a matter of ‘judgement, not science’ (paragraph 55

refers). It considers that a return to the 2008-based projection household formation

rates is unlikely to occur because of the continuing impact of international migration,

and because an improvement in the affordability of housing would be needed on top

of a general improvement in economic circumstances. It opts instead for rates

gradually moving back to the mid-point between those used in the 2008-based

projections and in the 2011-based projections over the period from 2015-2025, after

which the ‘gap’ would remain constant.

There are clear anomalies in this approach which the report itself illustrates

unintentionally through the example in the chart in para 64. This shows an assumed

increase in rates over the period 2015-2025, followed by a fall in rates thereafter. No

clear reasoning is offered either for the ten year timescale for the recovery in rates

(2015-25) or for the threshold point at which convergence with the 2008-based

projections ceases. Most strangely, the decline in rates which follows is not justified

by reference to any demographic factors and it is hard to conceive what factors

might justify this. The decline is merely brought about mechanically by the extended

linear projection of the 2011-based projection household representative rates.

Nowhere in these projections do CLG make any claim to suggest that these rates

can reasonably be projected onward beyond 2021 and the report provides no

explanation for how this has been carried out.

The Council’s evidence shows less interest in household formation amongst other

age groups because these are ‘less clear’ (paragraph 57 refers) and proposes no

amendments to the 2011-based projection headship rates. The Estate consider that

the processes affecting housing demand arising from deteriorating affordability, and

from the specific impacts of the post 2007 economic downturn, are likely to have had

impacts on all age groups, and these need to be taken into account in the report. For

example, it would certainly be expected that many of the impacts identified for the

25-34 group to affect the 15-24 age group, perhaps to a greater extent, yet they are

not apparent from comparing the 2008-based and 2011-based rates. This is not a

case for ignoring the difference but rather suggests that we need to examine both

sets of rates more closely and carefully. It seems to that if there is a case for

modifying the 2011-based formation rates for 25-34 year olds, this must by definition

apply to other age groups because these groups were subject to the same

pressures. If looking at particular age groups, the scale of modification needs to be

argued group by group and applied consistently.

Other approaches to the resolution of differences in household formation rates have

been taken elsewhere. In South Worcestershire for example, the Inspector’s Interim

conclusions following the EIP of the Draft Local Plan recommended an approach

which adopted 2011-based rates until 2021, and then applied factors to the 2021

rates for the remainder of the plan period which were derived from the 2008-based

rates for that period. This was called an ‘index’ approach. This approach has the

advantage of modelling the resumption of long term trends in household formation,

rather than an unexplained further decline after 2025 caused by the extension of

2011-based rate trends. The processes of declining household size have been

established over a long period in the UK. They reflect the desire for the consumption

of more space and for a greater degree of independent living, processes which can

be expected to persist unless permanently extinguished by economic circumstances

over a long period. The level of housing supply will of course also in itself play a part

in determining outcomes, and it seems more appropriate to plan for the resumption

of long term trends than to accept the impact of deteriorating affordability (in part

caused by a supply shortfall) as a permanent feature of household formation. The

Estate does not necessarily advocate the use of the South Worcestershire approach

in the case of Stroud – there is for example a case for considering the resumption of

long term trends before 2021 – but an approach of this kind seems more

appropriately to reflect household aspirations and longer term household formation

processes.

It is not the Estate’s aim in this response to provide a definitive suggestion as to the

appropriate household formation rates to be used in the plan, but rather to

demonstrate that this is a significant issue which requires further consideration and

discussion amongst the interested parties and with the Inspector, rather than being a

matter where common ground has been established.

Empty and second homes



If No, what should the figure be?

Response: The Estate agrees that an allowance for vacant and second homes is

appropriate and that 3.9% is based upon a reasonable planning judgement.

Housing needed from demographic calculations

The report states that 8,700 additional homes will be needed 2011-2031 (10,400

additional homes for 2006-2031) based on demographic based calculations



Response: The Estate does not consider that the demographic baseline is sound at

8,700 dwellings. There are considerable issues in respect of the Headship Rate

assumptions that need to be rectified before the Estate can consider the baseline

demographic scenario as soundly based.

Market signals



If No, what additional level of housing for the period 2011-2031 (2006-2031) should

be added to the housing requirement to take into account this factor?

Response: The Estate does not agree with the conclusion that there is no strong

case for additional housing on the basis of market signals evidence. The evidence

presented is selective in its data sources to seek to justify no uplift.

The report uses lower quartile house prices rather than the median house price

which is typically used. The Estate object to the use of lower quartile house prices

and affordability ratios without an equitable assessment of median house prices. The

report suggests that the lower quartile data is more appropriate as it better

represents those that are seeking to enter the housing market for the first time

(paragraph 76 refers). However, the housing market is far wider than first time byers

and market signals should be considered across the entire housing market range

which is why the median data is more appropriate.

The above evidence indicates a significant variation across a more representative

indicator of the housing market. It also illustrates the wide variances in the market

data including the significant influence of the ratio for the Cotswold District. It is noted

from the above, that while the ratio for Stroud District generally follows a

Gloucestershire profile, this county profile is highly distorted by the influence of

Cotswold District. It is also not statistically appropriate to rely on the County as a

single comparator as the County average is itself a derivative of the individual district

data, and as such will always follow the profile of the districts themselves. The

comparator is therefore weak when considered in isolation like this and need wider

objective assessment.

The Estate has therefore referred to the 2014 Strategic Housing Market Assessment

(SHMA) published by Stroud District, which undertakes a more robust assessment of

the housing market area. The SHMA sets out (paragraph 5.9 refers) that while the

housing market based upon median house prices has remained relatively stable over

the last eight years, it acknowledges that this is not representative of the

Gloucestershire housing market and states (paragraph 5.10 refers) that to fully

understand the housing market it is necessary to undertake further detailed

assessment. The Estate concurs that a single approach as advocated in the

Council’s most recent report is not an in depth assessment and uses relatively

simple data sets to arrive at its conclusion. The 2014 SHMA, however, undertakes

further detailed assessment of the Housing Market Area and arrives at different

conclusions. It also does this on the basis of sub-housing market areas.

0.00

2.00

4.00

6.00

8.00

10.00

12.00

14.00

Median Affordability Ratios

Gloucestershire

Cheltenham

Cotswold

Forest of Dean

Gloucester

Stroud

Tewkesbury

In table 5.3 it appraises the price change in entry level house prices across the

County. This indicates as set out in paragraph 5.16 that entry level prices have

increased most in Gloucester and Stroud Valley (sub-housing market), both of which

are significant.

In concluding, the Council’s own evidence contained within the 2014 SHMA indicates

that the scale of key housing market gaps in Stroud is significant, particularly in

respect of the gap in the housing market. Table 5.6 of the SHMA sets out that Stroud

Valley has the second highest housing market gap in all of Gloucestershire in one

and two bedroom properties and is one of the highest recorded through three and

four bedroom properties.

The Council’s own SHMA evidence therefore illustrates that there housing market

signals justify uplift in respect to house prices and the evidence presented in the

latest technical evidence produced by the Council is not as in-depth or robust as the

SHMA prepared under paragraph 159 of the NPPF.

Under supply





Response: The Estate does not agree that there is no strong case for additional

housing on the basis of this limited assessment. The assessment is over simplistic

and does not appropriately reflect the guidance contained within the PAS Technical

Guidance on establishing Objectively Assessed Need. The note seeks to use a

single indicator of comparing an indexed approach of past completions to that of

national completions.

It infers from this that there is no deviation from the national trend and on this basis

there has been no undersupply of housing in the District. This is not accepted by the

Estate.

It is already established that the Government has acknowledged that there is a

national shortfall in the delivery of homes historically and there is a need to boost

house building. Therefore comparing a trend in Stroud District to a national trend,

that the Government states has resulted in a lack of housing, and concluding that

given Stroud is comparable there is no undersupply is an inaccurate interpretation. In

fact the converse is true, that if Stroud District has followed the profile of national

supply, then the conclusion of the nation undersupplying housing is also concluded

similarly for Stroud District. Therefore on this basis alone Stroud District has

contributed to under supply.

The Estate refers specifically to the PAS Technical Guidance that refers to the

correct interpretation of undersupply. This is where supply has fallen below housing

need, and not necessarily below previous targets. The Council’s Report does

acknowledge this positon in paragraph 80, but does not then follow the PAS

guidance through in the context of paragraph 5.34 of the guidance. This sets out that

under-supply needs to be considered against the need for housing, not necessarily

targets, unless those targets are representative of need at the time. In this context,

the Estate refers to the recent planning appeal [APP/C1625/A/11/2165671] in

January 2013 within Stroud District. The Inspector in determining this appeal

considered past supply and whether the Council had performed sufficiently to justify

a 5% NPPF buffer or whether it had persistently undersupplied to justify a 20%

NPPF buffer. In doing so, the Inspector will have had to therefore consider supply of

housing within Stroud District against the need for housing, and not housing targets

set out within a Plan as the PAS guidance indicates is necessary for assessing this

particular market signal. The inspector undertook this process and stated that the

authority had undersupplied against housing need and that this justified a 20%

buffer.

More pertinently, however, at paragraph 38 of the Inspector’s Report, it states that it

was common ground between the main parties (one of which was Stroud District

Council) that there has been a historic shortfall in meeting housing targets. The

report then explores the relationship between housing targets and the need for

housing for the purposes of measuring under supply. It concludes that against the

Council’s own assessment of housing need the Council has under supplied since the

year 2006 and that the level of need established in the period from 2006 was agreed

by all parties as the level of housing need. Therefore the Inspector concluded that

the Council had undersupplied against housing need.

In the context of the above and the guidance contained within the PAS guidance, the

Council has clearly undersupplied against local housing need and this has been

established through independent consideration by the Planning Inspectorate.

The evidence available to the Inspector therefore demonstrates that the Council has

persistently under-delivered and this component of market signals justifies uplift.

There is no justification otherwise.

Concealed Families


Do you agree? Yes/ No



Response: The Estate does not agree with the Council’s approach - see affordable

housing for justification.

Overcrowding



Response: The Estate does not agree with the Council’s approach - see affordable


Affordable housing





Response: The Estate does not support the conclusion that there is no justification

for uplift in respect of affordability, concealed households or overcrowding. The

report is overly dismissive of the affordability evidence presented through the 2014

SHMA that illustrates affordability is a key component of the Gloucestershire housing

market. The SHMA sets out that there is 10,787 households living in unsuitable

accommodation with no solution (paragraph 7.14 refers). The SHMA indicates that

overcrowding is the biggest contributor to housing need across all districts in the

housing market area (Figure 7.1 refers) and that concealed homes are a driver of

local need.

The approach advocated within the recent Council evidence is one that identifies that

the PAS guidance suggests a degree of pragmatism in determining the affordable

housing component of housing need. However, the interpretation of pragmatism by

the Council is to have no regard to the need for affordable housing. The evidence

illustrated in the SHMA clearly indicates that uplift is required on the basis of

overcrowding and concealed households and that the annual need for affordable

housing in Stroud District is 492 dwellings per annum (Table A5.2) of the SHMA.

This is a considerable factor to take into account in setting the OAN. The approach

taken by the Council is, however, dismissive of this and the ability to deliver this level

of affordable housing due to lack of potential funding from developers (paragraph 8.7

refers). However, on the same token the Council has published a Core Strategy

setting out that at least 30% affordable housing will be provided (Policy CP9 refers)

and that is entirely viable according to its Local Plan Viability Assessment evidence.

The Council’s housing need evidence therefore has no regard to the Council’s own

evidence through Policy CP9, the 2014 SHMA evidence on the considerable need

for affordable housing to address concealed households and overcrowding, nor its

own viability evidence.

The Estate considers that uplift is required to the base demographic scenario on the

basis of all affordability components and for the Council to consider that absolutely

no uplift is required is invalid and unsound.

Supporting economic growth

Economic forecasts

The report uses the latest 2014 economic projections from two forecasters –

Cambridge Econometrics and Oxford Economics.


If No, what alternative or additional economic forecasts / considerations should be

used?

Response: While the Estate supports the use of the latest 2014 economic forecasts

from Cambridge Econometrics (CE) and Oxford Economics, it does not consider that

these should be the only considerations with regard to the economic potential of the

area. The authority should also have regard to the Gloucestershire Local Economic

Partnership (LEP) Strategic Economic Plan that identifies that growth is set at 4.8%

GVA per annum. Significantly it should have regard to the statement in the LEP’

Strategic Economic Plan that states at page 14 that 3.2% of this GVA is already

included within emerging local authority plans. The Council should therefore have

regard to the LEP Strategy Economic Plan in considering future economic

performance.

The PPG also states that the OAN assessment should consider past economic

trends and while the Estate acknowledges that the two sources of CE and Oxford

provide past data, the PAS guidance also refers to the Government’s Official Labour

Force Statistics at Nomis as a source of economic data. This should also be

considered.

The Estate notes that the Council’s report sets out past job growth from Nomis on

page 76 and records job growth from 2001 to 2011, which illustrates a job growth of

12,000 jobs over that 10 year period. This equates to 1,200 jobs per annum.

However, for some reason, the most recent job figure from the year 2012 is omitted

from the Council’s evidence. This additional year demonstrates significantly higher

job provision historically. If one takes the full data range to the most recent year

available (in the context of paragraph 016 of the PPG stating to use the most up to

date evidence), one observes a job growth of 1,250 jobs per annum historically.

The Estate therefore does not understand why when the Council’s report at page 76

refers to past Nomis job growth the report then continues to makes no reference to

past job growth from the Government’s official statistics. It only refers to the CE and

Oxford Economics figures. The Estate would expect the Council to benchmark

forward forecasts against official statistics, rather than benchmark CE and Oxford

data against themselves, as has been done. When benchmarking Ce and Oxford

forecasts to past provision, as is required by the PPG, it is observed that the

forecasts from both forecasting houses are relatively conservative.

A straight extrapolation of past trends of 1,250 jobs per annum would indicate 25,000

jobs over the plan period. This compares to the forecasts of 4,800 from Oxford and

8,900 from CE. This therefore demonstrates that for all the criticisms of economic

forecasts being too high and unreliable set out in the Council’s report, the

comparison of them to past job growth demonstrates another picture, where they are

relatively conservative.

The Estate therefore considers that the economic scenarios should also use

evidence on past jobs and the forward plans of the LEP.

Economic activity rates

The report suggests that in estimating the labour force and hence housing

implications of the econometric projections, economic activity rate assumptions

consistent with the projections being interpreted should be used.


If No, what alternative approach should be used?

Response: The Estate does not concur that the economic activity rates should be

used as per projection. The Council is responsible for undertaking an objective

assessment of housing need. Within this it is required to establish its own view on

economic growth informed by economic projections and this includes assumptions

on economic activity rates. It must then justify its decisions as sound at examination.

By deferring this issue to the factors used within each forecast, it potentially uses two

assumptions, those contained within CE and those contained within Oxford

Economics as each will have different assumptions regarding the activity rates of the

population in the future. Equally, from the evidence presented, it is not possible to

establish what those rates are or how they relate to specific age cohort evidence

within the Council’s demographic evidence. The Council should therefore be more

definitive and set out what it considers are realistic economic activity rates across all

age cohorts of its population projections and use those consistently in all sensitivity

scenarios.

Jobs assessment period

The report assesses how many homes will be needed to support projected increases

in jobs for the period 2014-2031.


If No, what period should the assessment cover?

Response: The Estate does not concur that this is an appropriate approach. The

report seeks to over complicate the issue and avoids addressing housing need

across the full plan period. It is a simple attempt to reduce the housing need

associated with the projected employment growth over the plan period. This is not

acceptable or sound.

The plan period is from 2011 to 2031 and job growth over that period is projected to

be between 7,800 and 8,600 jobs from Oxford and CE respectively. By seeking to

align job forecasts from 2014, the Council seek to remove the implication of job

growth over the three year period of 2011 to 2014 which is 3,000 jobs and 3,700 jobs

for Oxford and Cambridge projections respectively. The Council’s report states that

this is a period of economic flux (paragraph 124 refers), however, from the evidence

it appears that there is no flux and that both projections are relatively consistent in

their estimation of job growth over this period. Equally when one considers this level

of job growth compared to past trends of some 1,250 jobs per annum, which would

suggest a growth of 3,750 jobs over that same period, the forecasts are entirely

consistent with past trends.

The period for job forecasts to inform local plan housing need should be based upon

the Plan period from 2011. There is no sound reason not to do so and the approach

to move to 2014 is simply an attempt to reduce the need for new homes. Such an

approach is unsound.

Interpreting the economic forecasts

The report suggests that a reasonable allowance for additional housing to support

economic growth would be for Stroud, Cotswold and Forest of Dean to provide

between them for half the additional homes which the CE analysis suggests might be

needed across Gloucestershire i.e. 2,700. If these are allocated in line with the

relative housing numbers suggested by the CE analysis Stroud would provide 800

additional housing (rounded).



Response: The Estate supports the use of the economic forecasts from Cambridge

Econometrics but it does not support the use of this evidence from the year 2014. In

this context, it cannot agree to the specific requirement above as it is unsound.

The approach of the Council is also unsound in respect of its assumptions in respect

of accommodating only half of the CE projection based upon the LEP position. This

is a ‘policy on’ based assumption where the OAN should be based upon a ‘policy off’

position. To introduce ‘policy on’ assumptions into OAN is unlawful.

The assumptions in respect of government services and job growth are also taken

outside of any assessment by the LEP into sectors where it will promote economic

growth. This may also be interpreted as a ‘policy on’ consideration and care needs to

be expressed in relation to such adjustments. Therefore one should not assess the

reduction of any economic sectors unless an objective assessment is taken on all

sectors in light of the LEP proposals and its Sector Group proposals of the Strategic

Economic Plan. In this context, it is clear that this adjustment to the CE data is not an

objective assessment, outside of seeking to reduce the housing need.

It is also noted that the LEP has set out that it is an ambitious plan to achieve 4.8%

and that 3.2% of this is already set out in Local Plans. These economic aspirations of

the LEP are therefore in addition to the baseline projections forecast by CE and a

reduction in the economic growth on this basis for Stroud is not consistent with the

requirements for OAN. Furthermore, the Inspector has set out that Stroud has a

clear relationship with Gloucester City and this is one of the key locations for growth

within the LEP Strategic Plan and as such will support the economic potential of

Stroud.

The Estate only supports the use of lawful policy off assumptions in respect of

establishing the OAN for homes, as such the full CE evidence should be used.

Other matters

Please provide brief details of any other factors which should be taken into account

in identifying an OAHN for Stroud.

Response: In the interests of the examination, the Estate has sought to agree with

the Council on as many factors as possible, however, unfortunately it believes that

the additional work undertaken to establish the housing need for the authorities of

Stroud, Cotswold and Forest of Dean is not an objective assessment of housing

need. The Estate will provide further evidence on any of the matters presented within

the Report.

Contact Details

Please provide contact details so that we can ensure that your comments can be

reflected in the Statement of Common Ground.

Name: Jayne Harding

Organisation: Aspect360 Ltd

Contact phone / email: 0117 973 8662 / [email protected]

19

Appendix 2: Bruton Knowles on behalf of the Pullen Family



Background

The Stroud District Local Plan was submitted to the Planning Inspectorate in December 2013. Examination hearing sessions dealing with housing requirements were held in April 2014. The Inspector’s Stage 1 initial conclusions were published in June 2014. The Inspector concluded that further work was necessary to ensure that a soundly based objective assessment of housing requirements had been undertaken.


In response to a query from a hearing participant, the Inspector asked the Council to consider holding a technical workshop with representors who have challenged the objective assessment of housing need in order to try to narrow the issues in dispute and prepare a Statement of Common Ground identifying areas of agreement and disagreement. This may assist in establishing the respective positions of the various parties before any further hearing sessions resume.

On 14 October 2014 a technical workshop was held in the Council Chamber, Ebley Mill, Stroud. A draft Executive Summary and presentation slides were circulated in advance of the workshop. Participants asked questions and gave views during the workshop and were given until 24 October 2014 to write in with further comments and queries. Five responses were received by the District Council.

Following the workshop, Neil McDonald has now completed his final report taking into account views expressed during and after the workshop. The full report has now been published.


The District Council has prepared this focused questionnaire which will be used to compile a factual Statement of Common Ground between the Council and representors, identifying the areas of agreement and disagreement.

Representors are requested to fill in this questionnaire and to return it to Helen Johnstone [email protected] at the District Council by 26 November 2014.

Please answer the questions set out in the questionnaire and the questionnaire responses will be reported to the Inspector. It will be for the Inspector to seek clarification of positions through any future hearing session on housing requirements, once the examination is reopened.


QUESTIONNAIRE


Please respond to the questions by highlighting Yes/No and provide a brief text response where asked summarising your position. Please do not attach further supporting information at this stage as this will n ot be reported to the Inspector.


The report takes as its starting point the population estimates from the interim 2011 based subnational population projections for England (2011 SNPP) and the 2012 subnational population projections for England (2012 SNPP). The report concludes that the 2012 SNPP, with due allowances, should generally be adopted as the more reliable projection.

Do you agree with this approach? Yes/No (please highlight as appropriate)



The report examines data relating to various components of change - Births, Deaths, UK inflow, UK outflow, International migration in and international migration out.

Births

The report concludes that the 2012 based projections are a better basis for forecasting future births than the 2011 based projections.



Deaths

The report concludes that there is no reason to question this aspect of the 2012 based projections.




The report adjusts UK inflows and outflows based on the ratio of the average annual flows over a 10 year period 2002 – 2012 to the flows over the period 2007-12, rather than the 2012 based projections which reflect a 5 year trend 2007-2012.











Estimate Population

The report estimates an increase of 14,100 people in Stroud in the period 2011-2031 (or 16,700 people in Stroud in the period 2006-2031).


If No, what should the figures be?


The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are half way between the 2008 and 2011 based rates. Thereafter household formation

rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups.








The report states that 8,700 additional homes will be needed 2011-2031 (10,400 additional homes for 2006-2031) based on demographic based calculations



Market signals



If No, what additional level of housing for the period 2011-2031 (2006-2031) should be added to the housing requirement to take into account this factor?

Under supply




The housing figures need to be increased by at leas t 5% in the first five years in line with the Inspector’s preliminary conclusion s.

Concealed Families




Overcrowding




Affordable housing




The extent of the affordable housing requirement is so substantial that there is a case for extending the overall requirement to all ow for new sources of supply to bring forward additional affordable homes .


Economic forecasts

The report uses the latest 2014 economic projections from two forecasters – Cambridge Econometrics and Oxford Economics.


If No, what alternative or additional economic forecasts / considerations should be used?


The report suggests that in estimating the labour force and hence housing implications of the econometric projections, economic activity rate assumptions consistent with the projections being interpreted should be used.




The report assesses how many homes will be needed to support projected increases in jobs for the period 2014-2031.




The report suggests that a reasonable allowance for additional housing to support economic growth would be for Stroud, Cotswold and Forest of Dean to provide between them for half the additional homes which the CE analysis suggests might be needed across Gloucestershire i.e. 2,700. If these are allocated in line with the relative housing numbers suggested by the CE analysis Stroud would provide 800 additional housing (rounded).



Other matters

Please provide brief details of any other factors which should be taken into account in identifying an OAHN for Stroud.

The Council has not published an updated 5 year hou sing land supply at the time of writing this response. There is therefore t he question of windfalls still to consider. An additional allowance may therefore be required to give some added flexibility on this matter.

Overall, it would seem prudent to reflect the need to remedy poor past performance, affordable needs and windfall reductio ns by adding 20% to the first 5 years of the overall current projected requ irement of 11200 dw. i.e. to increase to the total to 11650 dw., effectively add ing one years requirement as flexibility.

Contact Details

Please provide contact details so that we can ensure that your comments can be reflected in the Statement of Common Ground.

Name: W.W.Strachan

Organisation: Bruton Knowles (on behalf of the Pull en Family)

Contact phone / email: 01242236755 ( 07771966604)

strachan988@ btinternet.com

20

Appendix 3: DLP Planning on behalf of Hallam Land M anagement



Background











QUESTIONNAIRE







The Planning Practice Guidance states that the popu lation projections are the starting point. It is therefore agreed that these p rovide the appropriate starting point but the final conclusions is dependants upon the due allowances”. These are not agreed and therefore the final outcom e is not agreed



Births




Deaths








The report is correct in that it is required in the context of the PPG the review of the past migration rates and question as to weht er they are likely to continue.

We would also agree that the impact of the recessio n is that the levels of internal migration as fallen.

We would however add that there are a number of oth er factors likely to impact on the future level of migration into the District. These are as follows:

• Impact of known under provision of housing in Londo n (a shortfall of at least 7,000 dwellings a year according to the FALP) .

• Impact of known under delivery in Birmingham • The impact of future level of employment growth and the requirement of

the NPG to integrate economic and housing strategie s

Considering the above we have modelled the level of total net in migration as being 1,100 to 1,400 persons a year. This is based on the outputs of the accepted Chelmer Model meeting the growth in labour force for the period 2014 – 2031 of between 2444 and 4403 persons (CE na d OE projections page 76).









The use of the 2012 SNPP does not require any adjus tment for UPC

Estimate Population




Using the employment projections of an increase in jobs of between 2,444 and 4,403 jobs would require a population growth of bet ween 19,338 and 22,452 persons (This is based on the outputs of the Chelme r Model using the 2012 SNPP).


The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are half way between the 2008 and 2011 based rates. Thereafter household formation rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups.



This approach is contrary to the PPG which requires a plan to increase opportunities for home ownership. It actually conti nues the implications of not only the recent recession but also the long term un dersupply of homes since the 1990’s.

The Household Formations rates for all should be mo delled to improve so as to reflect the aspirations of the government. Simpl y using recent past trends do nothing to increase opportunities for home owner ship or address affordability.

As a starting point we would suggest the use of the HRR on the following page. Although it is recognised that these in thems elves will not bring about the required changes to affordability and accessibi lity that is required by the Framework and the NPG.

Single Couple Previously married

Males

2001-06 2006-11 2011-16 2016-21 2021-26 2026-31 2031-36

Males

2001-06 2006-11 2011-16 2016-21 2021-26 2026-31 2031-36

Males

2001-06 2006-11 2011-16 2016-21 2021-26 2026-31 2031-36

0-4 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0-4 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0-4 0.000 0.000 0.000 0.000 0.000 0.000 0.000

5-9 0.000 0.000 0.000 0.000 0.000 0.000 0.000 5-9 0.000 0.000 0.000 0.000 0.000 0.000 0.000 5-9 0.000 0.000 0.000 0.000 0.000 0.000 0.000

10-14 0.000 0.000 0.000 0.000 0.000 0.000 0.000 10-14 0.000 0.000 0.000 0.000 0.000 0.000 0.000 10-14 0.000 0.000 0.000 0.000 0.000 0.000 0.000

15-19 0.011 0.009 0.009 0.009 0.009 0.009 0.009 15-19 0.013 0.012 0.011 0.011 0.011 0.011 0.011 15-19 0.000 0.000 0.000 0.000 0.000 0.000 0.000

20-24 0.071 0.068 0.067 0.067 0.068 0.068 0.068 20-24 0.167 0.153 0.148 0.149 0.150 0.150 0.150 20-24 0.002 0.001 0.001 0.001 0.001 0.001 0.001

25-29 0.160 0.160 0.172 0.163 0.154 0.145 0.145 25-29 0.447 0.394 0.370 0.378 0.385 0.393 0.393 25-29 0.010 0.007 0.005 0.006 0.007 0.007 0.007

30-34 0.139 0.140 0.165 0.157 0.149 0.141 0.141 30-34 0.649 0.580 0.537 0.552 0.567 0.583 0.583 30-34 0.036 0.032 0.027 0.029 0.030 0.032 0.032

35-39 0.112 0.120 0.140 0.132 0.123 0.114 0.114 35-39 0.734 0.697 0.677 0.681 0.686 0.690 0.690 35-39 0.053 0.045 0.039 0.042 0.045 0.047 0.047

40-44 0.076 0.079 0.090 0.087 0.084 0.081 0.081 40-44 0.774 0.769 0.766 0.767 0.768 0.770 0.770 40-44 0.084 0.078 0.070 0.071 0.072 0.073 0.073

45-49 0.067 0.076 0.083 0.078 0.074 0.069 0.069 45-49 0.760 0.752 0.755 0.758 0.761 0.764 0.764 45-49 0.108 0.100 0.090 0.093 0.095 0.098 0.098

50-54 0.051 0.061 0.074 0.069 0.065 0.061 0.061 50-54 0.798 0.772 0.759 0.762 0.765 0.768 0.768 50-54 0.113 0.117 0.116 0.117 0.117 0.118 0.118

55-59 0.049 0.056 0.068 0.065 0.062 0.059 0.059 55-59 0.804 0.778 0.759 0.769 0.778 0.787 0.787 55-59 0.123 0.126 0.129 0.126 0.122 0.119 0.119

60-64 0.044 0.047 0.056 0.054 0.051 0.049 0.049 60-64 0.831 0.812 0.790 0.797 0.804 0.811 0.811 60-64 0.106 0.110 0.117 0.115 0.112 0.110 0.110

65-69 0.036 0.038 0.044 0.043 0.043 0.042 0.042 65-69 0.838 0.828 0.816 0.815 0.815 0.815 0.815 65-69 0.112 0.113 0.119 0.120 0.120 0.121 0.121

70-74 0.047 0.044 0.048 0.046 0.045 0.043 0.043 70-74 0.798 0.782 0.773 0.776 0.780 0.783 0.783 70-74 0.141 0.139 0.143 0.143 0.142 0.141 0.141

75-79 0.041 0.037 0.036 0.038 0.039 0.041 0.041 75-79 0.774 0.779 0.784 0.775 0.765 0.756 0.756 75-79 0.180 0.163 0.160 0.166 0.171 0.177 0.177

80-84 0.040 0.047 0.044 0.044 0.045 0.045 0.045 80-84 0.655 0.655 0.671 0.669 0.668 0.667 0.667 80-84 0.269 0.253 0.246 0.247 0.248 0.249 0.249

85+ 0.047 0.050 0.050 0.051 0.051 0.052 0.052 85+ 0.520 0.481 0.502 0.496 0.490 0.485 0.485 85+ 0.377 0.344 0.327 0.332 0.337 0.341 0.341

Single Couple Previously married

Females Females Females

0-4 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0-4 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0-4 0.000 0.000 0.000 0.000 0.000 0.000 0.000

5-9 0.000 0.000 0.000 0.000 0.000 0.000 0.000 5-9 0.000 0.000 0.000 0.000 0.000 0.000 0.000 5-9 0.000 0.000 0.000 0.000 0.000 0.000 0.000

10-14 0.000 0.000 0.000 0.000 0.000 0.000 0.000 10-14 0.000 0.000 0.000 0.000 0.000 0.000 0.000 10-14 0.000 0.000 0.000 0.000 0.000 0.000 0.000

15-19 0.015 0.012 0.012 0.012 0.011 0.011 0.011 15-19 0.000 0.000 0.000 0.000 0.000 0.000 0.000 15-19 0.000 0.000 0.000 0.000 0.000 0.001 0.001

20-24 0.101 0.105 0.110 0.108 0.106 0.104 0.104 20-24 0.000 0.000 0.000 0.000 0.000 0.000 0.000 20-24 0.008 0.006 0.005 0.005 0.005 0.005 0.005

25-29 0.154 0.160 0.175 0.166 0.158 0.150 0.150 25-29 0.000 0.000 0.000 0.000 0.000 0.000 0.000 25-29 0.028 0.020 0.015 0.018 0.020 0.022 0.022

30-34 0.130 0.142 0.166 0.155 0.144 0.134 0.134 30-34 0.000 0.000 0.000 0.000 0.000 0.000 0.000 30-34 0.062 0.055 0.047 0.050 0.052 0.055 0.055

35-39 0.089 0.099 0.116 0.109 0.101 0.093 0.093 35-39 0.000 0.000 0.000 0.000 0.000 0.000 0.000 35-39 0.113 0.095 0.083 0.086 0.090 0.093 0.093

40-44 0.062 0.069 0.086 0.080 0.074 0.068 0.068 40-44 0.000 0.000 0.000 0.000 0.000 0.000 0.000 40-44 0.126 0.114 0.100 0.106 0.112 0.118 0.118

45-49 0.045 0.055 0.065 0.059 0.054 0.049 0.049 45-49 0.000 0.000 0.000 0.000 0.000 0.000 0.000 45-49 0.155 0.147 0.132 0.134 0.136 0.137 0.137

50-54 0.038 0.050 0.068 0.059 0.050 0.042 0.042 50-54 0.000 0.000 0.000 0.000 0.000 0.000 0.000 50-54 0.168 0.165 0.162 0.160 0.157 0.155 0.155

55-59 0.028 0.036 0.052 0.046 0.039 0.033 0.033 55-59 0.000 0.000 0.000 0.000 0.000 0.000 0.000 55-59 0.165 0.161 0.164 0.161 0.159 0.156 0.156

60-64 0.021 0.023 0.031 0.029 0.027 0.026 0.026 60-64 0.000 0.000 0.000 0.000 0.000 0.000 0.000 60-64 0.183 0.179 0.183 0.178 0.174 0.169 0.169

65-69 0.030 0.029 0.034 0.032 0.029 0.027 0.027 65-69 0.000 0.000 0.000 0.000 0.000 0.000 0.000 65-69 0.254 0.239 0.236 0.235 0.235 0.235 0.235

70-74 0.041 0.034 0.033 0.032 0.032 0.031 0.031 70-74 0.000 0.000 0.000 0.000 0.000 0.000 0.000 70-74 0.333 0.302 0.289 0.295 0.301 0.308 0.308

75-79 0.035 0.030 0.025 0.028 0.031 0.033 0.033 75-79 0.000 0.000 0.000 0.000 0.000 0.000 0.000 75-79 0.478 0.430 0.407 0.412 0.417 0.421 0.421

80-84 0.050 0.046 0.040 0.041 0.042 0.043 0.043 80-84 0.000 0.000 0.000 0.000 0.000 0.000 0.000 80-84 0.599 0.557 0.525 0.538 0.550 0.563 0.563

85+ 0.055 0.044 0.039 0.040 0.042 0.043 0.043 85+ 0.000 0.000 0.000 0.000 0.000 0.000 0.000 85+ 0.735 0.622 0.616 0.614 0.613 0.611 0.611









Our Demographic projection from the Chelmer Model b ased on the 2012 SNPP suggests a slightly lower requirement of 8,500 dwel ling or 425 dwellings a year. This does not model the higher levels of migr ation over the 5 year period or the increase due to the unattributed population change.

Market signals




The approach of using indexed rates and only lookin g back to 2001 substantially underplays the issue of affordability . It presupposes that at 2001 the market was in equilibrium and that the levels o f affordability across the country and the districts were acceptable. This is not considered to be the case it is our view that the current housing crisis ’s has been building slowly since the 1990’s as our research illustrates that t here has been persistent under provision against actual need for these two d ecades.

Looking at the longer term as appendix 1 of DLP’s s ubmission on matter 2 in February 2 it is clear that by 2001 there were alre ady significant issues in affordability since 1993 Mean House prices have tri pled and affordability (lower Quartile prices v Lower Quartile Earning) ha s increased from 4 to over 6. If only the comparative changes are considered t hen future policy will just plan for a level of housing provision to maintain t he current market status and present levels of affordability rather than improve these. This we would argue is contrary to the Framework which requires to meet need and demand as well

as to increase the opportunities for home ownership this cannot be achieved by simply matching present levels of affordability on a regional or national scale.

Under supply




It is noted that the build rate in figure 24 is wel l below the DCLG projections of need for Stroud to meet the 2004 based projections would have required sufficient housing for 500 households a year.

2004 Sub National Household projections (2004)

Households ,000’s

2004 2006 2011 2016 2021 2026 2029

Gloucestershire 244 249 260 273 285 296 301 Cheltenham 49 50 52 55 57 59 60 Cotswold 36 36 38 41 43 45 46 Forest of Dean 33 34 35 37 38 39 40 Gloucester 47 48 50 52 54 56 57 Stroud 46 47 49 51 53 55 56 Tewkesbury 33 34 36 38 40 42 43

It is considered that the district has undersupplie d against actual levels of demand and need. This is a common occurrence across the country and is a contributory factor of the worsening affordability nationally. Albeit small levels of under provision combine to especially over the l ong term to create a constrained market.

The question refers to the additional level of hou sing required, in our view these is no direct mathematical equation that can t ransfer the past level of under provision to additional dwellings just that w hen considering future levels of provision including those higher levels r equired to meet the economic projections such a finding adds considerab le weight to the higher of these projections.

Concealed Families




There has been a considerable growth in the number of unrelated adults sharing accommodation. This is a separate category and it is assumed that none of these persons are actually potential househ olds which are making a sub optimal choice of sharing accommodation rather than remaining in the parental home.

It is accepted that these are not what may be tradi tional referred to as hidden households but they are a consequence of the long t erms worsening affordability over the past two decades and does re quire to be addressed. It is noted that the Report does provide for a little rel ief in one of the age groups which are most likely to form this type of househol d however this is considered to be an inadequate response.

Overcrowding




It is accepted that the traditional measure of over crowding suggests that there is not a particular problem with the area although the more intensive use of the stock by adults sharing and HMO’s is oon our view i ndicators that the housing market is not currently operating in a way that is fully meeting all demand and need as required b the framework and the PPG.

Affordable housing




It is noted that in paragraph 88 the report argues that past levels of provision will have constrained household formation rates and that this is likely to continue.

The requirement for affordable housing is an indica tor as to the nature of the current market the fact that the latest SHMA sugges ts a requirement of 477 affordable dwellings a year (Table A5.1 Housing nee ds assessment model for

Stroud) has to be consideration in determining the overall level of housing need in the district.


Economic forecasts




It is noted that these two economic projections ten d to be the more pessimistic employment forecasts than those produce d by Experian. Other Authorities encouraged by inspectors have use all t hree to triangulate the likely level of future employment growth.

As these have already been presented in evidence to the examination it is both surprising and disappointing that the councils cons ultants have not sought to utilise this element of the evidence base.

This evidence also supports the fact that employmen t growth is likely to be towards the higher end of the tow projections in th e report.

Extract of Experian Projection (February 2014)

Stroud 2011 2031

Change 2011 to 2031

Total FTE employment (Thousands) 37660 41460 3,800

Workforce jobs (Thousands) 54550 60370 5,820

Working age population (Thousands) 64840 67160 2,320

Total population (Thousands) 112130 121840 9,710

LFS unemployment (Thousands) 3280 1910 -1,370

LFS employment (Thousands) 56460 68210 11,750





Economic activity rates are an output of economic m odels in that they are adjusted within the model in order to resolve the o utputs from the model with regard to population. The same is the case with com muting. Growth in jobs is also constrained to available labour after taking a ccount to modelled changes in activity rates and commuting. Hence using the ou tput activity rates from the model one must be conscious that these do not refle ct past patters or trends but have been generated internally by the model.

Our analysis of long term trends in economic activi ty rates highlight that these can be very flexible and therefore assumptions base d on short term changes should be treated with extreme caution.

These very modest long terms trends do not suggest that it would be wise to model in substantial long term changes in the econo mic activity rates. This position has been supported by the comments of insp ectors at South Worcestershire, Aylesbury Vale and Doncaster examin ations.

The approach adopted by SPRU in their modelling is an approach that has been favoured by Senior inspector Mr Clews at the S outh Worcestershire Examination which is to increase activity rates to reflect future changes of activity rates based upon the impact of the changes to the pension age.

These have been summarised in our previous submissi ons and for the sake of brevity are not repeated here.

The longer term trends and the volatility of activi ty rates are demonstrated in the two charts below:

It is suggested that the economic activity rates below be used as a better reflection of the long term levels of activity reflecting pension age changes

Proposed changes to economic activity rates.

2001-06 2006-11 2011-16 2016-21 2021-26 2026-31 2031-36

Males

0-4 0.000 0.000 0.000 0.000 0.000 0.000 0.000

5-9 0.000 0.000 0.000 0.000 0.000 0.000 0.000

10-14 0.000 0.000 0.000 0.000 0.000 0.000 0.000

15-19 0.411 0.497 0.497 0.497 0.497 0.497 0.497

20-24 1.000 0.667 0.667 0.667 0.667 0.667 0.667

25-29 0.926 0.994 0.994 0.994 0.994 0.994 0.994

30-34 0.936 1.000 1.000 1.000 1.000 1.000 1.000

35-39 0.975 0.972 0.972 0.972 0.972 0.972 0.972

40-44 0.990 0.986 0.986 0.986 0.986 0.986 0.986

45-49 0.971 0.967 0.967 0.967 0.967 0.967 0.967

50-54 0.883 0.922 0.922 0.922 0.922 0.922 0.922

55-59 0.794 0.829 0.829 0.829 0.829 0.829 0.829

60-64 0.612 0.639 0.655 0.671 0.671 0.671 0.671

65-69 0.437 0.554 0.582 0.611 0.611 0.611 0.611

70-74 0.249 0.316 0.316 0.316 0.316 0.316 0.316

75-79 0.000 0.000 0.000 0.000 0.000 0.000 0.000

80-84 0.000 0.000 0.000 0.000 0.000 0.000 0.000

85+ 0.000 0.000 0.000 0.000 0.000 0.000 0.000

Females

0-4 0.000 0.000 0.000 0.000 0.000 0.000 0.000

5-9 0.000 0.000 0.000 0.000 0.000 0.000 0.000

10-14 0.000 0.000 0.000 0.000 0.000 0.000 0.000

15-19 0.315 0.350 0.350 0.350 0.350 0.350 0.350

20-24 1.000 0.865 0.865 0.865 0.865 0.865 0.865

25-29 0.852 0.802 0.802 0.802 0.802 0.802 0.802

30-34 0.809 0.761 0.761 0.761 0.761 0.761 0.761

35-39 0.726 0.810 0.810 0.810 0.810 0.810 0.810

40-44 0.761 0.850 0.850 0.850 0.850 0.850 0.850

45-49 0.771 0.861 0.861 0.861 0.861 0.861 0.861

50-54 0.890 1.000 1.000 1.000 1.000 1.000 1.000

55-59 0.718 0.807 0.807 0.807 0.807 0.807 0.807

60-64 0.345 0.388 0.398 0.408 0.408 0.408 0.408

65-69 0.145 0.070 0.073 0.077 0.077 0.077 0.077

70-74 0.049 0.023 0.023 0.023 0.023 0.023 0.023

75-79 0.000 0.000 0.000 0.000 0.000 0.000 0.000

80-84 0.000 0.000 0.000 0.000 0.000 0.000 0.000

85+ 0.000 0.000 0.000 0.000 0.000 0.000 0.000





There is a mismatch in the approach as the largest element of the growth appears to have already occurred in the 2011 to 201 4 period. To achieve this will have required changes to commuting and activit y rates yet the approach taken by the report is that activity rates will imp rove on an average annual rate (i.e. smoothing out what are known to be highly vol atile rates in the short term.)

Our analysis of long term trends in (above) show th at short term fluctuations tend to average out over the longer period. In orde r to accommodate this it is considered that the projections should also embrace the higher employment led forecasts fo the period 2011 to 2031. These wil l be higher than the projections that have presently been run by SPRU in response to this paper.





The approach adopted by the report is to apply a po licy decision not to meet the higher levels of housing growth required to mee t the higher economic projections (paragraph 134). It is clear that the d ecision not to meet these higher levels is the application of the LEP policy to redistribute economic growth. As such this is clearly a policy led decisi on and contrary to the Framework and OAN which requires the OAN to reflect the needs of the economy in terms of the policy off position.

Figure 42: OANs for 2011-31 for Stroud suggests tha t to meet this lower policy constrained level of employment growth would requir e 9,500 dwellings (475 dwellings a year).

There is no logic to this approach the forecast job growth is forecast to occur at the district level dependant on its own economic base to suggest that this can be redistributed is illogical.

The table on the next page demonstrates that the le vel of dwellings that would actually be required to meet the projected level of employment growth. The approach adopted by the report requires the continu ation of patterns of household formation and working that are deeply inf luenced by the long term undersupply of housing and demand during the past t wo decades. This mismatch has had a negative impact in the national economy nad has deepened the impact of the worldwide recession. Pla nning to perpetuate these conditions into the future is not considered to be a suitable response to the Framework or the PPG .

Summary of outputs from the Chelmer Model

Dwelling change 2011-2016

2016-2021

2021-2026

2026-2031

2011 2031

Ave dwg 2011 to 2031

Dwg 2014 to 2031

2012 SNPP (2008HHRR) PA adjustment 489 460 483 433 9,323 466 7,857 2012 Half Trend PA adjusted 456 413 442 389 8,500 425 7,131 2012 Half Trend PA adjusted 2444 Labourforce 456 607 619 561 11,218 561 9,849 2012 Half Trend PA adjusted 4403 Labourforce 351 772 702 653 12,393 620 11,340

Labour force change 2011-2016

2016-2021

2021-2026

2026-2031

2011 2031

Ave 2011 to 2031

Total 2014 to 2031

2012 SNPP (2008HHRR) PA adjustment 13 -57 -86 -81 -1,054 -53 -1,094 2012 Half Trend PA adjusted 13 -57 -86 -81 -1,055 -53 -1,095 2012 Half Trend PA adjusted 2444 Labourforce 13 181 158 144 2,484 124 2,444 2012 Half Trend PA adjusted 4403 Labourforce 13 292 296 287 4,443 222 4,403

Population change 2011-2016

2016-2021

2021-2026

2026-2031

2011 2031

Ave 2011 to 2031

2012 SNPP (2008HHRR) PA adjustment 565 680 820 640 13,526 676 2012 Half Trend PA adjusted 565 680 820 640 13,526 676 2012 Half Trend PA adjusted 2444 Labourforce 565 1,085 1,146 1,072 19,338 967 2012 Half Trend PA adjusted 4403 Labourforce 565 1,252 1,364 1,310 22,452 1123

Migration 2011-2016

2016-2021

2021-2026

2026-2031

2011 2031

Ave 2011 to 2031

2012 SNPP (2008HHRR) PA adjustment 450 643 816 768 13,388 669 2012 Half Trend PA adjusted 450 643 816 768 13,388 669 2012 Half Trend PA adjusted 2444 Labourforce 450 1,048 1,100 1,100 18,492 925 2012 Half Trend PA adjusted 4403 Labourforce 450 1,215 1,300 1,300 21,327 1,066

Other matters


Reference should be made both to our original submi ssion to the plan examination. Unfortunately the nature of this consu ltation does not facilitate the presentation of our full case which is based up on both the most up-to-date information regarding the demographic and economic scenarios but also recent decisions from other plan examination.

On the current evidence base we would suggest that the full objectively assessed need for housing taking into account impro vements to the economy and changes to the pension age would require a dwel ling provision of between 11,218 and 12,393 (2011 to 2031) or 561 to 620 dwe llings a year.

Contact Details


Name: Roland G Bolton

Organisation: Strategic Planning Research Unit at D LP Planning Ltd

Contact phone / email: roland.bolton@dlpconsultants .co.uk

01142289190

21

Appendix 4: Don’t Strangle Stroud and Eastington Pa rish Council in association with Strategic Planning Alliance

1



Background











QUESTIONNAIRE

2







The “Due allowances” used in this report are not va lid as described in the relevant sections below. The allowances appear to h ave been added to achieve a predetermined figure. We question whether the rep ort is Objective and as such is not sound in a number of areas.



Births




Deaths




3





These “adjustments” are not valid for three reasons :-

1. They are attempting to fit a “UK wide” solution to Stroud. 2. The 2012 population projections already include an updated formula for

migratory flows in the UK (as confirmed by the ONS) 3. Neil Macdonald has assumed that the “post recess ionary” population

projections would be reduced by the effects of the recession. Referral to the ONS data confirms that his “assumption” is inco rrect. The trend from the last five years shows an increased population p rojection for Stroud (as confirmed by the ONS). If Neil McDonald and SDC wish to “return to trend” then a lower population projection must be used deflating the housing requirement. NMD’s approach is not objective (evidence based) an d is therefore UNSOUND Impact on OAHN ……… - 50 Houses









UPC is a measure of a previous projection’s accurac y between two census points. Neil McDonald appears to be implying that a ll ONS population projections have to be corrected by a UPC. This ass umption is not credible and it is surprising that this has not been challenged at the proof reading stage.

4

The 2012 projections have already been corrected to the 2011 census data. The ONS have confirmed the obvious - that UPC should no t be used in this way.

Additionally, the components of UPC show that the i nternal migration is the major contributor to the UPC. The ONS confirms that the 2012 projections have been updated to include this change in internal mig ration.

Neil Macdonald carries out a very eloquent descript ion of the UPC, however his use of UPC appears to suggest that he is again hunt ing for reasons to inflate the housing figure, or he does not understand the base subject. The use of UPC here is completely UNSOUND.

Impact on OAHN………………. - 200 houses

Estimate Population




Neil Macdonald has not presented any valid evidence that backs up the increasing of the 13,600 number from the ONS projec tion in the period 2011-2031. In addition the Local Plan makes no argument for any action to increase the projected population. Indeed it emphasises the use of the ONS and DCLG projections.

His “adjustments” are not supported by the ONS or D CLG guidance – To achieve this higher figure the report does not “est imate an increase”. It creates an increase through invention – an erroneous correc tion value, UPC or “double counting”.

ONS and DCLG statements and guidance confirm this a ssertion.

These are very basic errors which do not inspire th e confidence of the reader in NMD as an “expert”. The 16,700 figure is therefore without any credible evidence and as such is UNSOUND.

The ONS projected figure of 13,600 has to be used a s it is the only one with a credible evidence base.


The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are

5

half way between the 2008 and 2011 based rates. Thereafter household formation rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups.



Neil Macdonald doesn’t go into the detail of the co mponents of change included in the 2011-based DCLG household projections whatso ever . If he had, he would note that the household formation rates used are fr om the very optimistic 2008-based (pre-recessionary) DCLG projections. This inf ormation is present in the DCLG release notes – as we have already commented o n in previous submissions. So the household projections that come from this data set are therefore based on pre-recessionary data. We are su rprised that NMD did not appear to know this, or decided to gloss over this fact in his report and his presentations.

Neil Macdonald then carries out a “correction” to t his projection using previous (2008-based) data, without first correcting this da ta with the very UPC that he has explained in such great detail elsewhere. If he had, then there would be no correction to carry out. This essentially applies t he “return to trend” logic twice.

Impact on OAHN……… - 250 houses

So in this OAN, we have one example of the UPC bein g used when it shouldn’t, and one of NOT being used when it should. As commen ted earlier we are concerned that NMD does not appear to understand wh at the UPC Is, and when it should be used.





The previous figure presented by SDC was 3.2% (from SDC’s own records). Why is this different? Neither Neil Macdonald nor Offic ers have checked the data SDC Officers have already presented for this EIP. H is data is based on 2011 information – the 3.2% number is informed by later information presented by Keith Woodhead. The use of this out-of-date number is contrary to NPPF guidance on using the latest data.



6



The “adjustments” made to the base number of houses are not valid – they rely on the inappropriate addition of UPC in the populat ion base, then fail to take UPC into account when applying older projection dat a. This error again appears to suggest a lack of knowledge or lack of research into the data used.

The correct (ONS – advised) demographic based calcu lation would be: - 8,200

Market signals




Under supply




Concealed Families




Overcrowding




7

Affordable housing





Economic forecasts




This report suggests an economic boost for jobs tha t has no adequate evidence – and only based on the South West projection by CE (as per Neil McDonalds presentation given in the council chambers). At thi s presentation Neil McDonald stated that the CE data was for the South West regi on. Since that time the data we have now seen is presented as Stroud Data. No ex planation as to this change has been offered although we do understand f rom Keith Pearson that Neil McDonald has normalised the Data. No explanati on as to how this data has been “normalised” has been provided or offered. Cou ld we have an explanation that is supported by the working papers? Given that the SW has at least eight very large centres of population and employment, th e task of normalisation will be very complex and time consuming.

By Contrast Oxford has provided Stroud District spe cific data. Neil McDonald has not provided any explanation as to why this mor e accurate Stroud specific data has not been used. This again leaves the impre ssion that NMD is hunting for any data, however tenuous, that raises the Obje ctively Assessed housing need. This is UNSOUND.



8



This approach suggests a boost based on a single da taset that covers the South West (that may have been normalised by undeclared m ethods). It ignores Stroud specific data (as described in Neil McDonald’s pres entation in the council chambers) – this is contrary to NPPG guidance to us e up-to-date and local data wherever possible. This methodology is unexplained and not objective and is therefore UNSOUND.





It is inappropriate to project economic growth over such a long timescale. Government departments are struggling to do this a year or two into the future. To project such high and sustained levels of econom ic job creation over a twenty-year period is both unrealistic and UNSOUND.

The Euro area is almost back in recession. China’s growth rate is beginning to slow. Growth rates are slowing across Asia. So to c onfidently suggest these high and sustained levels of growth over the next t wenty years is completely unrealistic.

We have another census in seven year’s time a revie w date should be planned now. This is both common sense, and in line with th e NPPF.





9

The CE analysis is the ONLY ONE that supports this expansion level, and is not focussed on Stroud, but is based on the South West (as stated by Neil McDonald’s in his presentation in the council chamb ers). The OE analysis for Stroud, in contrast ,concludes that Stroud’s plan w ould include ample houses for job-related growth.

Further, Neil McDonald’s report makes an arbitrary decision concerning the number of jobs that Stroud itself would support. Th is is not based on any neighbouring local plan, or any other evidence (oth er than the CE report for the SW). This level of jobs increase is extremely unlik ely in Stroud. Also It represents a massive increase in out-commuting from Stroud, which is contrary to the policy stated in the local plan.

We also understand that the FoD have strong reserva tions about Neil McDonald’s report. There is therefore no agreement between the LPAs on the likely jobs growth. Further, there is no mention of the “duty to cooperate” which is an absolute requirement especially if Stroud is considering to take 50% of something that only two parties out of three have a greed. This means that SDC do not know the number from which they are agreeing to take 50%. Stroud’s population at 113,000 compares to the FoD and Cotsw old combined of around 165,000.

So Neil McDonald has taken a South West Regional fi gure from CE, normalised it in a way that is not revealed, Ignored Stroud-sp ecific data from OE without objective explanation. He has arrived at a random f igure for jobs growth for three LPAs and allocated 50% to Stroud with no decl ared logic or agreement.

This approach conflicts head-on with the SDC policy to reduce out-commuting.

The addition of these 800 houses is not logical, ob jective or SOUND.

10

Other matters


1. Neil Macdonald has failed to take the elderly po pulation into account with respect to C2 housing, as deemed necessary by the Sec. of State in his rulings (October 6 th Release). This omission is startling as it fails to take account of this specifically declared NPPF requirement. This makes the plan is UNSOUND. This amounts to 328 fewe r houses, and 722 additional care home beds, shown below.

Impact of these mathematical and mis-counting error s on the proposed OAN.

Proposed NM OAN = 11,200

Correction for UK flow change = - 50

Correction for UPC error = - 200

Correction for double counting (RTT) = - 250

Correction for un-evidenced jobs growth = - 800

GIVES A TOTAL = 9,900

Adjusting for secretary of state directive on C2 dw ellings

Correction for population in care = - 328

Plus previously omitted C2 care home beds = +722 beds

Final Total Houses plus C2 care home Beds = 10,29 4

The option remains to insert up to 800 county jobs growth boost (out-commuters)

Giving a Total Houses plus C2 care home Beds = 11,0 94

This would represent up to a 17% increase in units of accommodation and responds sympathetically to the elderly, which was absent from the Neil McDonald report.

11

2. This OAN fails to answer the specific questions set by the inspector:-

• It does not match the process used by JCS to inform their housing need or attempt to explain the differences – see note be low.

• It does not seek to back up, or explain, the previo us work carried out by Keith Woodhead.

• It carries out an additional assessment that isn’t what the inspector asked for.

• It fails to explain why alternative data sources ar e not compared – “POPGROUP”, “HEaDROOM”, “What Homes Where”.

• It fails to answer the inspectors query on the affo rdable housing number. • The relationship between the Gloucestershire Strate gic Economic Plan

and the Local plan is not made clear.

Note –

1. The “objectively assessed” housing number for th e JCS area has been calculated by a very different method to the one us ed for Stroud. In his published “JCS method”, Neil Macdonald calculated h is average household size from the officer-supplied housing nu mber and ONS population projection. Then, it was no surprise thi s original number was the result when this average household size was use d in his calculations. This effectively chose a number first, and then mad e the calculations fit this number. Evidence of this is in a JCS report pr ovided to councillors and available.

2. Included in this very same document is the state ment:- “In absolute numbers, the change in the fertility rate is the largest factor, with the annual birth rate for 2012 falling from 733,000 in the 2011 based projections to 693,000 in the 2012 set, a reduction of 40,000 a year. A reduction had been anticipated as it had been acknowledged by ONS that the approach used in the 2011 based projections had led to an overestimation of births. However, as children do not form households this fall in births will not have a significant impact on the number of households in the next 20 years” This quite remarkable assertion was then paraphrase d by Neil Macdonald’s written responses to councillor’s quest ions in the report as: - “ Babies don’t buy houses” This strange methodology does not appear to have be en applied in the Stroud calculation.

3. Neil McDonald’s reports to the JCS have the CCHP R and Cambridge University logos displayed prominently on the front sheet, so claiming accreditation from these institutions.

4. At the presentation on the 14 th October (and in SDC notes to the inspector) Neil McDonald was presented as being par t of CCHPR.

12

5. We have contacted Cambridge University and CCHPR and they confirmed that Neil MacDonald is a Client (Customer) of CCHPR . He has no employment connection directly to Cambridge Univers ity.

6. Neither Cambridge University nor CHHPR have any sponsorship, oversight or responsibility for any of the reports produced by Neil MacDonald, neither for the JCS nor Stroud areas.

7. The presence of the names and logos of Cambridge University and CCHPR on the cover sheet would appear to attribute accreditation that does not exist.

As a community group we are again very seriously co ncerned that data appears to have been manipulated to produce a particular an swer. For the JCS area, Neil Macdonald has acknowledged this in writing. As pre viously highlighted, Keith Woodhead’s original TOR’s instructed a particular n umber in the same way.

NMD has represented himself in various forums as ca rrying a degree of Cambridge University accreditation or CCHPR sponsor ship. In the Stroud reports, the Cambridge and CCHPR logos have now bee n removed from his presentation material since we wrote to Cambridge a nd CCHPR seeking to better understand his relationship with them.

NMD’s report is simply wrong in a number of areas. We have identified these and are concerned that a retired Director from the DCLG should make such basic errors. It is difficult for the public and in deed the Inspector to have confidence in a report littered with such basic mis takes. It is also very concerning that these were not identified when offi cers reviewed the report.

Mark Russell has confirmed in writing that the JCS and SDC OAN methodologies are the same. Perhaps this is correct , and Neil McDonald has been working toward a predetermined figure for his SDC report as KW was before him.

Contact Details


Name: Ian Stuart

Organisation: Don’t Strangle Stroud, Eastington Par ish Council in association with SPA, (Strategic Planning Alliance) group of pa rishes and community groups

Contact phone / email: [email protected] . [email protected]

22

Appendix 5: Dursley Town Council

23

Appendix 6: Home Builders Federation



Background











QUESTIONNAIRE





Do you agree with this approach? YES (please highlight as appropriate)




Births


Do you agree with this approach? YES


Deaths
















Estimate Population


Do you agree with these figures? YES





Do you agree with this approach? NO


It is not understood what the report means in the s tatement that HFR associated with international migration will unwind .

The report is contradictory by stating that modelli ng a partial return to trend for all age groups reduces the number of households formed but Figure E2 shows that a partial return to trend for all age gr oups is higher than the partial return to trend for 25 – 34 age group only. Likewis e this result is also shown in the Tables in the Appendices on pages 75, 90, 105, 111 and 116. Therefore it is unclear why a partial return to trend for just the 25 – 34 age group is favoured other than as a means to reduce the OAHN.

This scepticism about the approach to HFR is also r einforced by the latest analysis by CCHPR dated March 2014 for the GCT JCS which modelled two further alternative scenarios. The report states “ CCHPR concluded in May 2013 that the “Partial return to trend” scenario wo uld be a reasonable central case (33,200 dwellings). They remain of that view. However, both “Partial return for 25-34s” (30,500 dwellings) and “Indexati on to 2008 rates from 2021” (30,900 dwellings) are credible alternative options ”.

There is no convincing argument that the mid-point between 2008-based and 2011-based projections is the most appropriate appr oach. There are examples of Inspector’s disagreeing if the mid-point project ion produces a lower figure than a blended approach (please refer to South Worc estershire, Derbyshire Dales and Amber Valley Inspector’s Reports).

The HFR assumption is critically important because no other upward adjustments are undertaken to account for past unde r-supply, existing unmet need or affordable housing needs.

Therefore further sensitivity testing should be und ertaken for assumptions on:-

• full return to trend ; • blended rather than mid-point approach.



Do you agree with this figure? YES




Do you agree with this figure? NO


A higher figure would result from different assumpt ions on HFR (see comment above).

Market signals


Do you agree? NO


The market signals on house prices and rents in Cot swolds and on affordability in Forest of Dean suggest that an upw ard adjustment to OAHN is required.

Under supply


Do you agree? NO


Concealed Families


Do you agree? NO


Overcrowding


Do you agree? NO


Affordable housing


Do you agree? NO



Economic forecasts




In addition to using the above mentioned economic p rojections consideration should be given to the inter-relationship between O AHN and the Gloucestershire LEP SEP as indicated in the Inspect or’s Interim Report.





It is not transparent what economic activity rates are used for the over 60’s. A clarification would be helpful.





It is confusing. Why is the projected increase in j obs for the period 2014 – 2031 when the period for the assessment of OAHN is 2011 – 2031? The economic projection with an earlier start date covering the period 2011 – 2031 shows a higher figure.





The proposal to use only half the additional homes identified from the CE analysis is an arbitrary choice. Why not more than half or even all?

Other matters


The OAHN should also give consideration to the dist ribution of housing needs across the Gloucestershire HMA so that no unmet nee ds arise because an individual LPA is proposing a housing requirement i n its plan below OAHN.

Contact Details


Name: Sue Green

Organisation: Home Builders Federation

Contact phone / email: [email protected] / 07817 865534

24

Appendix 7: Keep Eastington Rural

1



Background











2

QUESTIONNAIRE







The starting points are fine in themselves but the “Due allowances” used in this report are not valid as described in the relev ant sections below. The allowances appear to have been added to achieve a p redetermined figure. We question whether the report is Objective and as suc h is not sound in a number of areas.



Births




Deaths



3






These “adjustments” are not valid for three reasons :-

1. They are attempting to fit a “UK wide” solution to Stroud. 2. The 2012 population projections already include an updated formula for

migratory flows in the UK (as confirmed by the ONS) 3. Neil Macdonald has assumed that the “post recess ionary” population

projections would be reduced by the effects of the recession. Referral to the ONS data confirms that his “assumption” is inco rrect. The trend from the last five years shows an increased populat ion projection for Stroud (as confirmed by the ONS in writing to our D SS). If Neil McDonald and SDC wish to “return to trend” then a lower population projection must be used deflating the housing requirement. Impact on OAHN ………50 Houses





4





UPC is a measure of a previous projection’s accurac y between two census points. Neil McDonald appears to be implying that a ll ONS population projections have to be corrected by a UPC. This ass umption is not credible

The 2012 projections have already been corrected to the 2011 census data. The ONS have confirmed in writing that UPC should n ot be used in this way.

Additionally, the components of UPC show that the i nternal migration is the major contributor to the UPC. The ONS confirms in w riting that the 2012 projections have been updated to include this chang e in internal migration.

The use of UPC here is completely UNSOUND.

Impact on OAHN……………….200 houses

Estimate Population




Neil Macdonald has not presented any valid evidence that backs up the increasing of the 13,600 number from the ONS projec tion in the period 2011-2031. In addition the Local Plan makes no argument for any action to increase the projected population. Indeed it emphasises the use of the ONS and DCLG projections.

His “adjustments” are not supported by the ONS or D CLG guidance – To achieve this higher figure the report does not “est imate an increase”. It creates an increase through invention – an erroneous correc tion value, UPC or “double counting”.

ONS and DCLG statements and guidance confirm this a ssertion.

The 16,700 figure is therefore UNSOUND.

The ONS projected figure of 14,100 has to be used a s it is the only one with a credible evidence base.

5


The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are half way between the 2008 and 2011 based rates. Thereafter household formation rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups. Do you agree with this approach? Yes/No


Neil Macdonald doesn’t go into the detail of the co mponents of change included in the 2011-based DCLG household projectio ns properly. If he had, he would note that the household formation rates used are from the very optimistic 2008-based (pre-recessionary) DCLG proje ctions. This information is present in the DCLG release notes, so the househ old projections that come from this data set are therefore based on pre-reces sionary data

Neil Macdonald then carries out a “correction” to t his projection using previous (2008-based) data, without first correctin g this data with the very UPC that he has explained in such great detail else where. If he had, then there would be no correction to carry out.

This essentially applies the “return to trend” logi c twice. Impact on OAHN………250 houses



Do you agree with this figure? Yes/No If No, what should the figure be?

The previous figure presented by SDC was 3.2% (from SDC’s own records). Why is this different? His data is based on 2011 in formation – the 3.2% number is informed by later information presented by Keith Woodhead. The use of this out-of-date number is contrary to NPPF guidance on using the latest data.



Do you agree with this figure? Yes/No If No, what should the figure be?

The “adjustments” made to the base number of houses are not valid – they rely on the inappropriate addition of UPC in the po pulation base, then fail to take UPC into account when applying older projectio n data.

The correct (ONS – advised) demographic based calcu lation would be: - 8,200

6

Market signals




Under supply




Concealed Families




Overcrowding




Affordable housing




7


Economic forecasts




At Neil McDonalds presentation given in the counci l chambers he stated that the CE data was for the South West region. Since th at time the data we have now seen is presented as Stroud Data. No explanatio n as to this change has been. Could we have an explanation that is supporte d by the working papers please?

Given that the SW has at least eight very large cen tres of population and employment, the differences are very significant.

By Contrast Oxford has provided Stroud District spe cific data. One would have expected that this survey would have been given mor e weight than the CE data based on the South West.

The decision of how to balance the two sets of data is unclear and should be laid out more logically to survive detailed scrutin y. Without that, this is segment of the report is potentially UNSOUND.





Please see previous question

This methodology is inadequately explained, not obj ective and is therefore potentially UNSOUND.

8





It is inappropriate to project economic growth over such a long timescale. Government departments are struggling to do this a year or two into the future.

The Euro area is almost back in recession. China’s growth rate is beginning to slow. Growth rates are slowing across Asia.

No economy in the world has ever gone twenty years without at least one recession: usually two. To project such high and su stained levels of economic job creation over a twenty-year period is both unre alistic and UNSOUND.

We have another census in seven year’s time a revie w date should be planned now. This is both common sense, and in line with th e NPPF.





The CE analysis is the ONLY ONE that supports this expansion level, and is not focussed on Stroud, but is based on the South W est (as stated by Neil McDonald’s in his presentation in the council chamb ers). The OE analysis for Stroud, in contrast ,concludes that Stroud’s plan w ould include ample houses for job-related growth.

Further, Neil McDonald’s report makes an arbitrary decision concerning the number of jobs that Stroud itself would support. Th is is not based on any neighbouring local plan, or any other evidence (oth er than the CE report for the SW). This level of jobs increase is extremely u nlikely in Stroud. Also It

9

represents a massive increase in out-commuting from Stroud, which is contrary to the policy stated in the local plan.

We also understand that the Forest of Dean have st rong reservations about Neil McDonald’s report. There is therefore no agree ment between the LPAs on the likely jobs growth.

Further, there is no mention of the “duty to cooper ate” which is an absolute requirement especially if Stroud is considering to take 50% of something that only two parties out of three have agreed. This mea ns that SDC do not know the number from which they are agreeing to take 50% . (Stroud’s population at 113,000 compares to the FoD and Cotswold combined o f around 165,000).

This approach conflicts head-on with the SDC policy to reduce out-commuting.

The addition of these 800 houses is not logical, ob jective or SOUND.

Other matters


1. Neil Macdonald has failed to take the elderly po pulation into account with respect to C2 housing, as deemed mandatory by Para 037 of the National Planning Guidance, 6 th Match 2014 and 6 th October 2014. Whilst we understand that his ToRs did not include this analysis, we fee l a consultant statistician would have flagged the SINGLE largest demographic c hange : the number of over 75s in Stroud District is due to rise by over 60% (sixty percent) over the plan period.

There are currently 1204 Class C2 bed spaces in Str oud District, substantially occupied by over 75s. A first estimate of the impac t of the demographic shift would be to plan for 722 bed spaces (Class C2) in t he Plan Period AND to remove these 722 people from the General Housing re quirement.

In Neil McDonald’s report all 722 people are assume d to be wanting a house, in the formation ratio of 2.2 per household, thus over -counting the General Housing requirement by (722/2.2) 328 houses.

Impact on OAHN..…(deduct) 328 houses ADD 722 residential Class C2

Cumulative total impact on OAHN…

Deduct (328,200,50,250= 828)….10,372 houses

Add…residential Class C2..………..722 beds

= 11,094 units

10

2. This OAN fails to answer the specific questions set by the inspector:-

• It does not match the process used by JCS to inform their housing need or attempt to explain the differences – see note be low.

• It does not seek to back up, or explain, the previo us work carried out by Keith Woodhead.

• It carries out an additional assessment that isn’t what the inspector asked for.

• It fails to explain why alternative data sources ar e not compared – “POPGROUP”, “HEaDROOM”, “What Homes Where”.

• It fails to answer the inspectors query on the affo rdable housing number.

• The relationship between the Gloucestershire Strate gic Economic Plan and the Local plan is not made clear.

Note –

1. The “objectively assessed” housing number for th e JCS area has been calculated by a very different method to the one us ed for Stroud. In his published “JCS method”, Neil Macdonald calculated h is average household size from the officer-supplied housing nu mber and ONS population projection. Then, it was no surprise thi s original number was the result when this average household size was use d in his calculations. This effectively chose a number first , and then made the calculations fit this number. Evidence of this is i n a JCS report provided to councillors and available.

2. Included in this very same document is the state ment:- “In absolute numbers, the change in the fertility rate is the largest factor, with the annual birth rate for 2012 falling from 733,000 in the 2011 based projections to 693,000 in the 2012 set, a reduction of 40,000 a year. A reduction had been anticipated as it had been acknowledged by ONS that the approach used in the 2011 based projections had led to an overestimation of births. However, as children do not form households this fall in births will not have a significant impact on the number of households in the next 20 years” This quite remarkable assertion was then paraphrase d by Neil Macdonald’s written responses to councillor’s quest ions in the report as: - “ Babies don’t buy houses” This strange methodology does not appear to have be en applied in the Stroud calculation.

3. Neil McDonald’s reports to the JCS have the CCHP R and Cambridge University logos displayed prominently on the front sheet, so claiming accreditation from these institutions.

4. At the presentation on the 14 th October (and in SDC notes to the inspector) Neil McDonald was presented as being par t of CCHPR.

11

5. We have contacted Cambridge University and CCHPR and they confirmed that Neil MacDonald is a Client (Customer ) of CCHPR. He has no employment connection directly to Cambridge Univ ersity.

6. Neither Cambridge University nor CHHPR have any sponsorship, oversight or responsibility for any of the reports produced by Neil MacDonald, neither for the JCS nor Stroud areas.

7. The presence of the names and logos of Cambridge University and CCHPR on the cover sheet would appear to attribute accreditation that does not exist.

As a community group we are again very seriously co ncerned that data appears to have been manipulated to produce a parti cular answer. For the JCS area, Neil Macdonald has acknowledged this in writi ng . Keith Woodhead’s original TOR’s instructed a particular number in th e same way. Has the same thing happened here?

Contact Details


Name: Tom Low

Organisation: Keep Eastington Rural

Contact phone / email: [email protected] 07974 369680

For the avoidance of doubt, the answers provided he re are consistent with those of DSS (Don’t Strangle Stroud) and SPA (Strat egic Planning Alliance)

25

Appendix 8: Origin 3 on behalf of Taylor Wimpey

Origin3 is a limited company registered in England and Wales. Company Registration No. 6370231

Registered Offices: Tyndall House, 17 Whiteladies Road, Clifton, Bristol, BS8 1PB

T: 0117 927 3281 E: [email protected] W: www.origin3.co.uk

Page 1

Origin3 Ref: 141126_14052_Response to Statement of Common Ground Questionnaire

SUBMITTED ELECTRONICALLY VIA EMAIL

Ms. H. Johnstone

Stroud District Council

Ebley Mill

Ebley Wharf

Stroud

GL5 4UB

26th

November 2014

Dear Ms Johnstone

RE: Response to Statement of Common Ground Questionnaire on behalf of Taylor Wimpey

This letter provides comments from Taylor Wimpey Homes in respect of the SHMA OAHN report (dated

October 2014) and the Statement of Common Ground Questionnaire. It provides a short overview to the

response in the preamble below followed specific responses to the questions raised.

We would be pleased to discuss any of the responses with the LPA if this is a suitable way forward.

Preamble

The Government’s agenda for growth is clear and remains a core aspect of planning. The ministerial

forward to the National Planning Policy Framework (NPPF) explains that:

“Development means growth.”

The NPPF is more explicit in respect of economic and housing delivery. Paragraph 18 states in respect of

delivering sustainable development that:

“The Government is committed to securing economic growth in order to create jobs and prosperity…”

Paragraph 47 goes on state with regards to housing:

“To boost significantly the supply of housing, local planning authorities should:

Use their evidence base to ensure that their Local Plan meets the full objectively assessed needs

for market and affordable housing”

Furthermore, in the plan making section of NPPF, paragraph 154 explains that:

“Local Plans should be aspirational but realistic.”

The overall objective of Government, which is set out in their planning policy, is one of encouraging

growth and in respect of housing and the need to plan for it, in an aspirational but realistic manner.

Origin3, Tyndall House, 17 Whiteladies Road, Clifton, Bristol, BS8 1PB


Page 2

As was observed at the examination, there is no definitive answer in terms of establishing a housing

requirement, because it requires an element of subjective judgement to interpret the raw data that is

before the Council.

To align the judgement element of the SHMA with the stated policy requirement of Government, the over-

riding theme should be to boost economic and housing supply and to provide an aspirational but realistic

housing requirement.

The reason for taking this approach at the SHMA stage is because, to some degree, it has to predict the

influence of Government Policy and my view this element of the SHMA is wrong. It is not aligned with

Government Policy, specifically the NPPF, but also those of the Treasury. It is not aspirational and,

moreover, continues to use the data as a method for seeking to establish the lowest possible housing

requirement.

There are three key elements which clearly highlight this:

The assumption that there will only be a partial return to the headship trend.

The statement that there is no strong case for additional housing to support affordable housing

delivery when quantifiable need is not being met.

Continued lack of alignment with the LEP policy approach to growth.

The brief comments in answer to the Statement of Common Ground Questionnaire on behalf of Taylor

Wimpey are, therefore, written in the above context.

Q1 Population Forecasts

No comments are made in respect of population forecasts.

Q2 Components of Change

No comments are made in respect of Births and Deaths, UK inflows or outflows, International migration

flows or UPC.

Q3 Estimate Population

No comments are made in respect of population estimates.

Q4 Household Formation Rates

We do not agree with the approach set out in the SHMA in respect of a partial return to trend.

Recognition in the SHMA that the 2011 based household projections, which were based upon 2011

Census data is flawed, is agreed. The matter has been widely reported at local plan examinations and by

relevant professional bodies. However, the decision of the SHMA to support partial only a return to trend

in the 25-34 age group is a matter of judgement and as described in the preamble above. It should be

considered in the context of several factors, including economic influences and Government policy,

which is outside the control of the Stroud District and the Local Plan.

There are a number of factors which determined historic headship rates, particularly in the period

covered by DCLG 2011 in Figure 14 of the SHMA. These include, but are not exclusive to:

International migration and lifestyle choices (larger households);



Page 3

Mortgage availability to young adults;

Impacts of educational debt;

Full time employment availability for younger adults;

Limited change in house prices in the recessionary period; and

Availability of lower cost housing (affordable housing) as a result of reduced built rates and

scheme viability.

It is noted at Paragraph 54 of the SHMA that some of these effects are noted by the author, but reference

is also made to structural factors which are not explained. If this refers to structural changes in the

housing market, such as a move away from owner occupation to long term rental, the ability to make

these changes will be heavily influenced by the Local Plan and its role in steering the overall quantum of

housing delivery. The right level of housing has to be planned for in order for structural changes, such as

a move towards long term housing lets rather than purchases to be implemented fully. It would be wrong

at a local level to assume that structural change will not happen over the period to 2031 when at a

national level the indicators are that there is significantly more interest from long term investors to move

into the housing market as part of the long term rental sector.

Equally, schemes like the Government’s ‘Help to Buy’ will continue to support a market where the

availability of a substantial deposit remains affected by matters such as educational or other debt.

Moreover, why should the SHMA seek to influence a Local Plan on the basis of a relatively pessimistic

approach to headship projections because of the above factors? A plan which under supplies the total

level of housing provision will inevitably have a detrimental effect on affordability and the availability of

affordable housing which sits outside of the open market. This is where judgements in the SHMA need to

be aligned with Government policy, including NPPF. The notional approach in the SHMA of a partial

return to trend in not aligned with the statements set out in the preamble above about boosting the

supply of housing or supporting economic growth.

Until more reliable data becomes available, which references a longer term trend, a greater alignment

with the 2008 headship rates should be used.

Q5 Empty and Second Homes

It is reasonable to include an allowance for empty and second homes.

Q6 Housing Needed From Demographic Calculations

As explained earlier, the assumptions that have been sued in arriving at the demographic OAN are not

fully agreed, particularly those that have required a judgement to be made. The net effect of this has not

been calculated as part of this response to the questionnaire.

Q7 Market Signals

Affordability remains a good indicator of supply. This relates to two aspects, house price to income ratios

and housing land prices. The Gloucestershire Housing Affordability Model demonstrates house prices in

Stroud are between 8-9 times income, which demonstrates a significant issue locally. At this level, there

should be some recognition that constrained supply has affected housing price inflation in this part of

Gloucestershire.



Page 4

There is no reference in the SHMA OAN report to housing land prices, but experience suggests that they

are generally high.

The evidence suggests that there should be some recognition of market signals within the OAN.

Q8 Under Supply

No comments are made in respect of under supply.

Q9 Concealed Families

No comments are made in respect of concealed families

Q10 Overcrowding

No comments are made in respect of over crowding

Q11 Affordable Housing

Paragraph 87 of the SHMA is a good indicator of the problem faced by long term constraint on the

housing market perpetuated by a lack of strategic guidance through updates of the Gloucestershire

Structure Plan (3rd

alternation) and the Regional Spatial Strategy, both of which did not achieve adoption

as policy. The statements at paragraph 88 and 89 when coupled with those at paragraph 87 suggest that

the SHMA has resigned itself to under-provision and an inability to chance the status-quo because

funding is not available. Again, this is a judgement and pre-determines that there will be no substantive

policy or structural changes in the housing delivery market in the period to 2031.

The SHMA should make some allowance for structural change in the housing market, including

increasing the supply of affordable housing and the effect this will have on the demographic based

estimate. The indicators from all political parties at a national level are that structural change and

affordability are key matter to be addressed.

Q12 Supporting Economic Growth

Using the economic forecasts from CE and OE are appropriate. Noting the differences between the

forecasters, and the significant variation between OE (4.3%) and CE (7.7%) for Stroud and that using the

Gloucestershire figure of 6.1%-6.2% appears a more reliable and consistent approach.

As acknowledged by the SHMA, trying to predict the effects of economic growth for a single LPA area

has inherent difficulties and even more so when trying to disaggregate this by sector. There are real risks

of getting this substantially wrong, as can be seen by the variance in the underlying positions reached by

OE and CE about sector growth.

Similarly there are inherent dangers in trying to interpret changes in productivity rates even over a full

economic cycle. Many factors influence this, not least the availability of technology, its progressive

improvement and the availability finance to support its use.

In terms of establishing the OAN in line with the NPPF, productivity should not be used as a means of

adjusting downwards the likely need for housing, due to its volatility and the unreliable nature of this part

of the predictions. Aligning the SHMA with the NPPF should focus upon those elements of the projections

which boost economic growth in a realistic manner.



Page 5

There are no comments on the job assessment period.

In terms of interpreting the economic forecast, there are significant concerns about how this has been

arrived at. There are significant variances between the scenarios of CE and OE and the SHMA

assessment of OAN recognises this. However, the acceptance that a notional 50% of the CE

assessment should be included in arriving at the OAN has limited justification. It effectively accepts that

both CE’s and OE’s estimates and methodologies are correct and that a generalised adjustment should

be made at the end of the process. Again our concerns relate to the judgement that has been made.

It is noted at paragraph 123 of the OAN report that CE projections are based upon economic activity rate

changes in the south west, whilst OE are based upon population projections at a local authority level. As

is seen earlier in this representation, there are some frailties around population projections and it largely

depends upon which have been used to determine growth. Likewise, in arriving at Figure 41 of the

SHMA OAN report, it also depends on the headship rates and other factors that have been used to

derive a housing need figure as opposed to a population change figure.

It seems that the finer the grain of detail that is applied to projections, the more this produces

questionable results and this is recognised in paragraph 132(a) of the document. In the case of

uncertainty, a precautionary approach should be taken and that is to plan for the full objectively assessed

level of growth. There is a realistic prospect that CE’s assessment of needing significantly more housing

is correct and in the context of the growth agenda – why is this not being taken as the starting point for

planning purposes?

Summary

As explained, our concerns with the SHMA OAN report are focused not upon the overall methodology,

but rather with some of the judgements that have been made to arrive at the OAN figure. The

judgements do not appear to be aligned with the growth agenda set by the NPPF and, therefore, the

expectations in arriving at a full objectively assessed need for housing remains questionable.

Changes to headship rates, affordability and affordable housing delivery and economic effects would

address some of the concerns that have been raised.

If you have any queries in relation to this response, please do not hesitate to contact me.

Yours sincerely,

Colin Danks

Director

Origin3 Limited

26

Appendix 9: Pegasus Group on behalf of Robert Hitch ins Ltd

1 | P a g e



Background






undertaken.
















been published.







2014.






2 | P a g e


QUESTIONNAIRE





Inspector.












Births





Deaths


based projections.



3 | P a g e









based projections.







Estimate Population







4 | P a g e




Pegasus Group considers that as a minimum a consistent full return to trend (rebased to

take account of the 2011 Census) should be used for all age groups in order that the

negative trends experienced during the recession are not planned for (contrary to the third

core planning principle of the NPPF).

The projections include an arbitrary application of different headship rates during the plan

period, and so should not be used to support a phasing policy.

Furthermore, the way in which the partial return to trend is applied, such that a mid-point

between the 2011 and 2008 headship rates is adopted, effectively plans for a medium

economic growth scenario following a negative growth scenario, rather than being

aspirational (in conformity with paragraph 154). Pegasus Group consider that it is

appropriate to apply the negative headship rates of the 2011 projections during the short-

term i.e. to 2015, but then to apply the growth rates implied in the 2008 projections from

2016 onwards to provide for a balanced market.

The effect of a consistent return for all age groups results in an increased demographic led

need of 9,200 homes as identified in Figure E2. However, the application of a full return to

trend (rebased) as preferred by Pegasus Group will result in different figures.

Pegasus Group support the application of the 2011 rates over the short-term before

adjusting to longer term trends as this provides for a balanced projection over a plan period.

However, the arbitrary application has a very significant impact on the variability of

household growth during the period and cannot be robustly used to develop any phasing

policy. Paragraph 136 suggests some sort of phasing based upon this evidence, but the

arbitrary and unjustified application of household formation rates undermines the evidence

supporting this.





5 | P a g e






Pegasus Group can only draw on the information contained in the report, which identifies a

consistent partial return to trend projection of 9,200 homes. However, if the headship rates

provided for more aspirational economic growth, it is likely that these would identify a

significantly increased demographic led housing need.

Market signals





Pegasus Group note that the report now includes a section on market signals however it

concludes that there is no case for making adjustments. Pegasus Group considers that

adjustments need to be made to reflect some market signals including under supply and

affordable housing as identified in the following sections.

Under supply





Pegasus Group consider that at least a further 400 homes should be provided to address the

unmet need arising from previous under-supply in Stroud. The 2011 Census identifies 376

concealed households, and in February 2014 Stroud Council was aware of 22 homeless

households. No information is available on the number of shared households. Nevertheless,

this demonstrates that as a minimum of the order of 400 additional homes need to be

provided to cater for this need. This is co-incidentally consistent with the level of under-

delivery relative to the Council’s proposed objectively assessed need from 2006 to 2014.

Furthermore, the report only assesses job growth from 2014-2031. This means that the job

growth from 2011-2014 is not considered which may have demonstrated an additional need

6 | P a g e

for housing. This further supports the application of an allowance to account for any under-

supply.

Concealed Families





See previous comments on under-supply

Overcrowding





Affordable housing





An up-to-date assessment of the objectively assessed need for affordable housing is

required. However, the affordable need identified in the now out-of-date SHMA could be

met by providing for a minimum of 10,700 homes (plus historic unmet needs of

approximately 400 dwellings needs) assuming 30% of delivery is affordable. This will

increase once the required assessment is undertaken, but provides a useful indication for

now.

The PPG (2a-029) requires that the total number of affordable homes is considered. This is

consistent with paragraph 47 which requires that the full objectively assessed need for

market and affordable homes is provided for. The report, however, dismisses the affordable

need, on the basis that it would be undeliverable. Such an assertion cannot be justified

without the affordable need firstly being established.

7 | P a g e


Economic forecasts





used?

The projections used are one source of appropriate information. However, no consideration

of the Gloucestershire SEP as identified in the Inspector’s Interim Report appears to have

been undertaken.












See previous comments on under supply.










8 | P a g e

Pegasus Group considers that the objectively assessed need required to support economic

growth is identified in Figure 42 for each District (subject to the application of justifiable

household formation rates as previously raised). A revised distribution can be proposed

within the HMA but only if it was explicitly agreed with the JCS authorities that the JCS area

would deliver an additional 2,700 homes to respond to the displaced economic needs of

Stroud, Cotswold and the Forest of Dean. Given that the JCS has been submitted to the

Secretary of State on 20th November and does not include an allowance for 2,700 dwellings,

it is not clear how this issue can be addressed at this late stage in the planning process.

Other matters



The previous matters identify the objectively assessed need, subject to additional evidence

that would be required.

Based on the current evidence base, which has significant weaknesses as identified

throughout this response, the objectively assessed need for the period 2011 to 2031 for

Stroud District is at least 11,100 (10,700+400). However, once the headship rates have been

applied in a robust way that provides for economic growth, and once the affordable need

has been updated to reflect this, it is likely that the objectively assessed need will be

significantly greater.

Paragraph 153 of the report identifies a different time period for the Stroud Local Plan as

compared to all the preceding analysis. This presents a fundamental error in the

assessment. Housing completions from 2006 will have influenced the projections and so the

early part of the purported objective assessment of need simply reflects what has been built

rather than what is required. As a result, there is no objective assessment of need from

2006 to 2011 (the base date of the national household projections) and yet the report

purports to assess this need from 2006 to 2031.

Contact Details



Name: Neil Tiley

Organisation: Pegasus Group on behalf of Robert Hitchins Ltd

Contact phone / email: [email protected]


27

Appendix 10: RPS on behalf of Redrow Homes Ltd

Our Ref: 141126 L JPW0322 AM E-mail: [email protected]

Your Ref: Direct Dial: 01454 853 000

Date: 26 November 2014

Ms Helen Johnstone Planning Policy Stroud District Council Ebley Mill Ebley Wharf Stroud GL5 4UB

Dear Helen

Stroud District Local Plan Objectively Assessed Need – Statement of Common Ground

On behalf of my clients, Redrow Homes Limited, please find enclosed a completed questionnaire in respect of the Statement of Common Ground on the objectively assessed need for housing in Stroud District. I would be grateful if you could confirm receipt and also keep me informed of any future developments. In particular, could you please confirm whether the NMSS report has been considered by Members as yet? Kind regards Yours sincerely For RPS

Alistair Macdonald Director cc: Mr Keith Annis, Redrow Homes Ltd. Encs: Statement of Common Ground Questionnaire – response of Redrow Homes Limited



Background






undertaken.
















been published.







2014.







QUESTIONNAIRE





Inspector.







Do you agree with this approach? Conditional Yes/No (please highlight as

appropriate)

Response: The above text being mooted for agreement between parties in respect

of population forecasts states that the report concludes that the 2012 SNPP, with

due allowances, should generally be adopted as the more reliable projection.

Redrow does not consider that this is an acceptable statement to include within a

Statement of Common Ground given the subjective nature of the phraseology used.

Redrow will, however, agree that the evidence contained within the 2012 SNPP is

the starting point for determining the Objectively Assessed Need for Stroud District

on the basis that it represent the latest available information in the context of

paragraph 016 of the Planning Practice Guidance (PPG)





Births



Do you agree with this approach? Conditional Yes/No


Response: While Redrow agrees that the 2012 based projections birth evidence is

appropriate for projecting future births associated with population projections,

however, it is not clear from the report or statement above on the manner in which

the evidence has been used. The report sets out at paragraph 43 that the 2012

projections for births appear to be plausible projections, however, it is not clear from

the report whether the population profile has been used directly, or whether the

fertility rates have been used and applied to a base population profile.

This distinction is important in appraising alternative scenarios such as economic

scenarios, as it is important that age specific fertility rates are integral to establishing

revised population projections, to that of the baseline 2012 SNPP.

Further clarity is therefore required and Redrow is happy to engage further to reach

agreement on this.

Deaths


based projections.



Response: Redrow agrees that the 2012 based projections are a better basis for

forecasting future deaths, however, similarly to the birth statement above, it is not

clear whether actual projection data or age specific mortality rates have been used.

Further clarity is therefore required and Redrow is happy to engage further to reach

agreement on this.






Response: Redrow concurs that the use of a ten year observation period is more

robust in respect of internal migration trends.




based projections.



Response: The 2012 SPPP International Migration trends are constrained at a UK

level as set out in paragraph 30 of the Council’s Report. This is currently 154,000

people per annum. However it is already observed that the national constraint has

been exceeded in 2012, 2013 and 2014, with net migration in those years

comprising 184,000, 212,000 and 243,000 respectively. This amounts to an

additional 177,000 people over the ONS constraint cap in just three years. This

accounts for more than a single year of the ONS cap in itself within the three year

period. It is therefore clear that the Governments ONS cap of 154,000 has already

been exceeded substantially.

The 2012 SNPP is therefore considerably underestimating the level of international

migration. The exceedance of the Government’s constraint is therefore a serious and

significant factor to be considered. It is also observed that the constraint of 154,000

has only been achieved once since 2004. The Council should therefore incorporate a

sensitivity test of increasing international migration proportionally as observed.

A self-imposed Government constraint is no mechanism for forward forecasts.



Do you agree with this approach? Yes/No No objection

Response: Redrow raises no objection to the approach used with respect to UPC


Estimate Population





Response: Redrow cannot at this time agree to this position as it seeks clarification

on a number of points above.






The Council’s Report contains a detailed review of recent changes in actual,

estimated and projected headship rates for Stroud (pp 29-35).

The most up to date official household projections are CLG’s 2011-based Interim

projections. The Councils Report explains that the rates used in these projections

were derived from the 2011 Census. This identified household formation rates which

differed from those used in the previous (2008-based) CLG household projections.

The Councils Report initially sets out (paragraph 46 refers) that the 2008-based

projections were based on trends which predated the economic downturn and which

could be taken as broadly indicative of previous longer term trends. However the

reprt subsequently suggests that as the 2008-projections failed to pick up some

trends which were apparently even before the downturn, the household formation

rates used in those projections are inappropriate as they stand and proposes a

partial return to these rates (paragraph 54 refers).

The difference between household formation rates in the two sets of projections

varies by age group. It is greatest for the 25-34 and over 60 age groups, but the

rates differ throughout the age spectrum.

For the 25-34 age group, the 2011-based projections suggest that the household

formation rates are lower than the 2008-based rates in 2011 and will continue to

diverge further over the 2011-2021 projection period.

The divergence for this age group from longer term trends is attributed in the

Council’s evidence to two factors. Firstly, significant international in-migration after

2001 reduced household representative rates because new in-migrants are more

likely to live in larger multi-person households than the rest of the population in this

age group, at least in the early years of residence. Research by Holmans1 attributes

around half of the reduction in household formation in the 25-34 age group nationally

to this cause. But as international migration levels in Stroud were less significant

than in many other areas, the report notes that the local impact might have been

less.

The second factor reducing the rate of household formation would have been an

increase in the tendency of people aged 25-34 to live together in shared houses/flats

or to remain living with parents.

1 Alan Holmans (2013) The Town & Country Planning Tomorrow Series Paper 16, New estimates of housing

demand and need in England, 2011 to 2031, TCPA/CCHPR.

ONS research2 using national data broadly supports this hypothesis. The Council’s

report sets out that this second element of change in household formation will mainly

have been brought about by the worsening economic situation after 2007, the

collapse in housing supply, and the difficulty in obtaining mortgages. This suggests a

return towards previous trends if economic conditions improve, together with some

elimination of ‘suppressed’ household formation. However, it also argues that the

changes in household formation started before 2007 as a result of the deteriorating

affordability of housing arising from rapid increases in house prices and rents. These

causes may be more enduring, for example if mortgage finance remains more

difficult to obtain than in 2006-07. It is also suggested that welfare benefit reforms

will have a permanent impact. This would support an argument for not returning to

2008 formation rates as these may not have reflected the pre-2007 trends.

The report’s discussion of the potential causes of reduced household formation in

the 25-34 age group is interesting, but does not provide a definitive basis for

determining what might happen to household representative rates in the future. The

report itself accepts that this is a matter of ‘judgement, not science’ (paragraph 55

refers). It considers that a return to the 2008-based projection household formation

rates is unlikely to occur because of the continuing impact of international migration,

and because an improvement in the affordability of housing would be needed on top

of a general improvement in economic circumstances. It opts instead for rates

gradually moving back to the mid-point between those used in the 2008-based

projections and in the 2011-based projections over the period from 2015-2025, after

which the ‘gap’ would remain constant.

There are clear anomalies in this approach which the report itself illustrates

unintentionally through the example in the chart in para 64. This shows an assumed

increase in rates over the period 2015-2025, followed by a fall in rates thereafter. No

clear reasoning is offered either for the ten year timescale for the recovery in rates

(2015-25) or for the threshold point at which convergence with the 2008-based

projections ceases. Most strangely, the decline in rates which follows is not justified

by reference to any demographic factors and it is hard to conceive what factors

might justify this. The decline is merely brought about mechanically by the extended

linear projection of the 2011-based projection household representative rates.

Nowhere in these projections do CLG make any claim to suggest that these rates

can reasonably be projected onward beyond 2021 and the report provides no

explanation for how this has been carried out.

The Council’ evidence shows less interest in household formation amongst other age

groups because these are ‘less clear’ (paragraph 57 refers) and proposes no

amendments to the 2011-based projection headship rates. Redrow consider that the

2 ONS (2012) Young Adults Living With Parents in the UK, 2011, available at

http://www.ons.gov.uk/ons/dcp171776_266357.pdf and ONS (2013) Families and Households in England and Wales 2011, available at http://www.ons.gov.uk/ons/dcp171776_296986.pdf



processes affecting housing demand arising from deteriorating affordability, and from

the specific impacts of the post 2007 economic downturn, are likely to have had

impacts on all age groups, and these need to be taken into account in the report. For

example, it would certainly be expected that many of the impacts identified for the

25-34 group to affect the 15-24 age group, perhaps to a greater extent, yet they are

not apparent from comparing the 2008-based and 2011-based rates. This is not a

case for ignoring the difference but rather suggests that we need to examine both

sets of rates more closely and carefully. It seems to that if there is a case for

modifying the 2011-based formation rates for 25-34 year olds, this must by definition

apply to other age groups because these groups were subject to the same

pressures. If looking at particular age groups, the scale of modification needs to be

argued group by group and applied consistently.

Other approaches to the resolution of differences in household formation rates have

been taken elsewhere. In South Worcestershire for example, the Inspector’s Interim

conclusions following the EIP of the Draft Local Plan recommended an approach

which adopted 2011-based rates until 2021, and then applied factors to the 2021

rates for the remainder of the plan period which were derived from the 2008-based

rates for that period. This was called an ‘index’ approach. This approach has the

advantage of modelling the resumption of long term trends in household formation,

rather than an unexplained further decline after 2025 caused by the extension of

2011-based rate trends. The processes of declining household size have been

established over a long period in the UK. They reflect the desire for the consumption

of more space and for a greater degree of independent living, processes which can

be expected to persist unless permanently extinguished by economic circumstances

over a long period. The level of housing supply will of course also in itself play a part

in determining outcomes, and it seems more appropriate to plan for the resumption

of long term trends than to accept the impact of deteriorating affordability (in part

caused by a supply shortfall) as a permanent feature of household formation.

Redrow does not necessarily advocate the use of the South Worcestershire

approach in the case of Stroud – there is for example a case for considering the

resumption of long term trends before 2021 – but an approach of this kind seems

more appropriately to reflect household aspirations and longer term household

formation processes.

It is not Redrow’s aim in this response to provide a definitive suggestion as to the

appropriate household formation rates to be used in the plan, but rather to

demonstrate that this is a significant issue which requires further consideration and

discussion amongst the interested parties and with the Inspector, rather than being a

matter where common ground has been established.




Response: Redrow agrees that an allowance for vacant and second homes is

appropriate and that 3.96% is based upon a reasonable planning judgement.







Response: Redrow does not consider that the demographic baseline is sound at

8,700 dwellings. There are considerable issues in respect of the Headship Rate

assumptions that need to be rectified before Redrow can consider the baseline

demographic scenario as soundly based.

Market signals





Response: Redrow does not agree with the conclusion that there is no strong case

for additional housing on the basis of market signals evidence. The evidence

presented is selective in its data sources to seek to justify no uplift.

The report uses lower quartile house prices rather than the median house price

which is typically used. Redrow object to the use of lower quartile house prices and

affordability ratios without an equitable assessment of median house prices. The

report suggest that the lower quartile data is more appropriate as it better represents

those that are seeking to enter the housing market for the first time (paragraph 76

refers), however, the housing market is far wider than first time buyers and market

signals should be considered across the entire housing market range which is why

the median data is more appropriate.

The above evidence indicates a significant variation across a more representative

indicator of the housing market. It also illustrates the wide variances in the market

data including the significant influence of the ratio for the Cotswold District. It is noted

from the above, that while the ratio for Stroud District generally follows a

Gloucestershire profile, this county profile is highly distorted by the influence of

Cotswold District. It is also not statistically appropriate to rely on the County as a

single comparator as the County average is itself a derivative of the individual district

data, and as such will always follow the profile of the districts themselves. The

comparator is therefore weak when considered in isolation like this and need wider

objective assessment.

Redrow has therefore referred to the 2014 Strategic Housing Market Assessment

(SHMA) published by Stroud District, which undertakes a more robust assessment of

the housing market area. The SHMA sets out (paragraph 5.9 refers) that while the

housing market based upon median house prices has remained relatively stable over

the last eight years, it acknowledges that this is not representative of the

Gloucestershire housing market and states (paragraph 5.10 refers) that to fully

understand the housing market it is necessary to undertake further detailed

assessment. Redrow concurs that a single approach as advocated in the Council’s

most recent report is not an in depth assessment and uses relatively simple data

sets to arrive at its conclusion. The 2014 SHMA, however, undertakes further

detailed assessment of the Housing Market Area and arrives at different conclusions.

It also does this on the basis of sub-housing market areas.

0.00

2.00

4.00

6.00

8.00

10.00

12.00

14.00

Median Affordability Ratios

Gloucestershire

Cheltenham

Cotswold

Forest of Dean

Gloucester

Stroud

Tewkesbury

In table 5.3 it appraises the price change in entry level house prices across the

County. This indicates as set out in paragraph 5.16 that entry level prices have

increased most in Gloucester and Stroud Valley (sub-housing market), both of which

are significant.

In concluding, the Council’s own evidence contained within the 2014 SHMA indicates

that the scale of key housing market gaps in Stroud is significant, particularly in

respect of the gap in the housing market. Table 5.6 of the SHMA sets out that Stroud

Valley has the second highest housing market gap in all of Gloucestershire in one

and two bedroom properties and is one of the highest recorded through three and

four bedroom properties.

The Council’s own SHMA evidence therefore illustrates that there housing market

signals justify uplift in respect to house prices and the evidence presented in the

latest technical evidence produced by the Council is not as in-depth or robust as the

SHMA prepared under paragraph 159 of the NPPF.

Under supply





Response: Redrow does not agree that there is no strong case for additional

housing on the basis of this limited assessment. The assessment is over simplistic

and does not appropriately reflect the guidance contained within the PAS Technical

Guidance on establishing Objectively Assessed Need. The note, seeks to use a

single indicator of comparing an indexed approach of past completions to that of

national completions.

It infers from this that there is no deviation from the national trend and on this basis

there has been no undersupply of housing in the District. This is not accepted by

Redrow.

It is already established that the Government has acknowledged that there is a

national shortfall in the delivery of homes historically and there is a need to boost

house building. Therefore comparing a trend in Stroud District to a national trend,

that the Government states has resulted in a lack of housing, and concluding that

given Stroud is comparable there is no undersupply is an inaccurate interpretation. In

fact the converse is true, that if Stroud District has followed the profile of national

supply, then the conclusion of the nation undersupplying housing is also concluded

similarly for Stroud District. Therefore on this basis alone Stroud District has

contributed to under supply.

Redrow refers specifically to the PAS Technical Guidance that refers to the correct

interpretation of undersupply. This is where supply has fallen below housing need,

and not necessarily below previous targets. The Council’s Report does acknowledge

this positon in paragraph 80, but does not then follow the PAS guidance through in

the context of paragraph 5.34 of the guidance. This sets out that under-supply needs

to be considered against the need for housing, not necessarily targets, unless those

targets are representative of need at the time. In this context, Redrow refers to the

recent planning appeal [APP/C1625/A/11/2165671] in January 2013 within Stroud

District. The Inspector in determining this appeal considered past supply and

whether the Council had performed sufficiently to justify a 5% NPPF buffer or

whether it had persistently undersupplied to justify a 20% NPPF buffer. In doing so,

the Inspector will have had to therefore consider supply of housing within Stroud

District against the need for housing, and not housing targets set out within a Plan as

the PAS guidance indicates is necessary for assessing this particular market signal.

The inspector undertook this process and stated that the authority had undersupplied

against housing need and that this justified a 20% buffer.

More pertinently, however, at paragraph 38 of the Inspector’s Report, it states that it

was common ground between the main parties (one of which was Stroud District

Council) that there has been a historic shortfall in meeting housing targets. The

report then explores the relationship between housing targets and the need for

housing for the purposes of measuring under supply. It concludes that against the

Council’s own assessment of housing need the Council has under supplied since the

year 2006 and that the level of need established in the period from 2006 was agreed

by all parties as the level of housing need. Therefore the Inspector concluded that

the Council had undersupplied against housing need.

In the context of the above and the guidance contained within the PAS guidance, the

Council has clearly undersupplied against local housing need and this has been

established through independent consideration by the Planning Inspectorate.

The evidence available to the Inspector therefore demonstrates that the Council has

persistently under-delivered and this component of market signals justifies uplift.

There is no justification otherwise.

Concealed Families





Response: Redrow does not agree with the Council’s approach - see affordable


Overcrowding



Response: Redrow does not agree with the Council’s approach - see affordable




Affordable housing





Response: Redrow does not support the conclusion that there is no justification for

uplift in respect of affordability, concealed households or overcrowding. The report is

overly dismissive of the affordability evidence presented through the 2014 SHMA

that illustrates affordability is a key component of the Gloucestershire housing

market. The SHMA sets out that there is 10,787 households living in unsuitable

accommodation with no solution (paragraph 7.14 refers). The SHMA indicates that

overcrowding is the biggest contributor to housing need across all districts in the

housing market area (Figure 7.1 refers) and that concealed homes are a driver of

local need.

The approach advocated within the recent Council evidence is one that identifies that

the PAS guidance suggests a degree of pragmatism in determining the affordable

housing component of housing need. However, the interpretation of pragmatism by

the Council is to have no regard to the need for affordable housing. The evidence

illustrated in the SHMA clearly indicates that uplift is required on the basis of

overcrowding and concealed households and that the annual need for affordable

housing in Stroud District is 492 dwellings per annum (Table A5.2) of the SHMA.

This is a considerable factor to take into account in setting the OAN. The approach

taken by the Council is, however, dismissive of this and the ability to deliver this level

of affordable housing due to lack of potential funding from developers (paragraph 8.7

refers). However, on the same token the Council has published a Core Strategy

setting out that at least 30% affordable housing will be provided (Policy CP9 refers)

and that is entirely viable according to its Local Plan Viability Assessment evidence.

The Council’s housing need evidence therefore has no regard to the Council’s own

evidence through Policy CP9, the 2014 SHMA evidence on the considerable need

for affordable housing to address concealed households and overcrowding, nor its

own viability evidence.

Redrow consider that uplift is required to the base demographic scenario on the

basis of all affordability components and for the Council to consider that absolutely

no uplift is required is invalid and unsound.


Economic forecasts





used?

Response: While Redrow supports the use of the latest 2014 economic forecasts

from Cambridge Econometrics (CE) and Oxford Economics, it does not consider that

these should be the only considerations with regard to the economic potential of the

area. The authority should also have regard to the Gloucestershire Local Economic

Partnership (LEP) Strategic Economic Plan that identifies that growth is set at 4.8%

GVA per annum. Significantly it should have regard to the statement in the LEP’

Strategic Economic Plan that states at page 14 that 3.2% of this GVA is already

included within emerging local authority plans. The Council should therefore have

regard to the LEP Strategy Economic Plan in considering future economic

performance.

The PPG also states that the OAN assessment should consider past economic

trends and while Redrow acknowledges that the two sources of CE and Oxford

provide past data, the PAS guidance also refers to the Government’s Official Labour

Force Statistics at Nomis as a source of economic data. This should also be

considered.

Redrow notes that the Council’s report sets out past job growth from Nomis on page

76 and records job growth from 2001 to 2011, which illustrates a job growth of

12,000 jobs over that 10 year period. This equates to 1,200 jobs per annum.

However, for some reason, the most recent job figure from the year 2012 is omitted

from the Council’s evidence. This additional year demonstrates significantly higher

job provision historically. If one takes the full data range to the most recent year

available (in the context of paragraph 016 of the PPG stating to use the most up to

date evidence), one observes a job growth of 1,250 jobs per annum historically.

Redrow therefore does not understand why when the Council’s report at page 76

refers to past Nomis job growth the report then continues to makes no reference to

past job growth from the Government’s official statistics. It only refers to the CE and

Oxford Economics figures. Redrow would expect the Council to benchmark forward

forecasts against official statistics, rather than benchmark CE and Oxford data

against themselves, as has been done. When benchmarking Ce and Oxford

forecasts to past provision, as is required by the PPG, it is observed that the

forecasts from both forecasting houses are relatively conservative.

A straight extrapolation of past trends of 1,250 jobs per annum would indicate 25,000

jobs over the plan period. This compares to the forecasts of 4,800 from Oxford and

8,900 from CE. This therefore demonstrates that for all the criticisms of economic

forecasts being too high and unreliable set out in the Council’s report, the

comparison of them to past job growth demonstrates another picture, where they are

relatively conservative.

Redrow therefore considers that the economic scenarios should also use evidence

on past jobs and the forward plans of the LEP.







Response: Redrow does not concur that the economic activity rates should be used

as per projection. The Council is responsible for undertaking an objective

assessment of housing need. Within this it is required to establish its own view on

economic growth informed by economic projections and this includes assumptions

on economic activity rates. It must then justify its decisions as sound at examination.

By deferring this issue to the factors used within each forecast, it potentially uses two

assumptions, those contained within CE and those contained within Oxford

Economics as each will have different assumptions regarding the activity rates of the

population in the future. Equally, from the evidence presented, it is not possible to

establish what those rates are or how they relate to specific age cohort evidence

within the Council’s demographic evidence. The Council should therefore be more

definitive and set out what it considers are realistic economic activity rates across all

age cohorts of its population projections and use those consistently in all sensitivity

scenarios.






Response: Redrow does not concur that this is an appropriate approach. The report

seeks to over complicate the issue and avoids addressing housing need across the

full plan period. It is a simple attempt to reduce the housing need associated with the

projected employment growth over the plan period. This is not acceptable or sound.

The plan period is from 2011 to 2031 and job growth over that period is projected to

be between 7,800 and 8,600 jobs from Oxford and CE respectively. By seeking to

align job forecasts from 2014, the Council seek to remove the implication of job

growth over the three year period of 2011 to 2014 which is 3,000 jobs and 3,700 jobs

for Oxford and Cambridge projections respectively. The Council’s report states that

this is a period of economic flux (paragraph 124 refers), however, from the evidence

it appears that there is no flux and that both projections are relatively consistent in

their estimation of job growth over this period. Equally when one considers this level

of job growth compared to past trends of some 1,250 jobs per annum, which would

suggest a growth of 3,750 jobs over that same period, the forecasts are entirely

consistent with past trends.

The period for job forecasts to inform local plan housing need should be based upon

the Plan period from 2011. There is no sound reason not to do so and the approach

to move to 2014 is simply an attempt to reduce the need for new homes. Such an

approach is unsound.










Response: Redrow supports the use of the economic forecasts from Cambridge

Econometrics but it does not support the use of this evidence from the year 2014. In

this context, it cannot agree to the specific requirement above as it is unsound.

The approach of the Council is also unsound in respect of its assumptions in respect

of accommodating only half of the CE projection based upon the LEP position. This

is a ‘policy on’ based assumption where the OAN should be based upon a ‘policy off’

position. To introduce ‘policy on’ assumptions into OAN is unlawful.

The assumptions in respect of government services and job growth are also taken

outside of any assessment by the LEP into sectors where it will promote economic

growth. This may also be interpreted as a ‘policy on’ consideration and care needs to

be expressed in relation to such adjustments. Therefore one should not assess the

reduction of any economic sectors unless an objective assessment is taken on all

sectors in light of the LEP proposals and its Sector Group proposals of the Strategic

Economic Plan. In this context, it is clear that this adjustment to the CE data is not an

objective assessment, outside of seeking to reduce the housing need.

It is also noted that the LEP has set out that it is an ambitious plan to achieve 4.8%

and that 3.2% of this is already set out in Local Plans. These economic aspirations of

the LEP are therefore in addition to the baseline projections forecast by CE and a

reduction in the economic growth on this basis for Stroud is not consistent with the

requirements for OAN. Furthermore, the Inspector has set out that Stroud has a

clear relationship with Gloucester City and this is one of the key locations for growth

within the LEP Strategic Plan and as such will support the economic potential of

Stroud.

Redrow only supports the use of lawful policy off assumptions in respect of

establishing the OAN for homes, as such the full CE evidence should be used.

Other matters



Response: In the interests of the examination, Redrow has sought to agree with the

Council on as many factors as possible, however, unfortunately it believes that the

additional work undertaken to establish the housing need for the authorities of

Stroud, Cotswold and Forest of Dean is not an objective assessment of housing

need. Redrow will provide further evidence on any of the matters presented within

the Report.

Contact Details



Name: Alistair Macdonald

Organisation: RPS

Contact phone / email: 01454 853 000 / [email protected]

28

Appendix 11: Regeneris Consulting on behalf of Glad man Developments



Background






undertaken.
















been published.







2014.







QUESTIONNAIRE





Inspector.







Do you agree with this approach? Yes (please highlight as appropriate)




Births



Do you agree with this approach? Yes

Deaths


based projections.






Do you agree with this approach? Yes (but)


Broadly we agree (although in practical terms for the base demographic projection it

makes little material difference for Stroud). However, the implications for the working

age population and labour force need to be considered under the scenario for an

increase in households to increase the workforce.



based projections.





Estimate Population



Do you agree with these figures? Yes, as a base starting point for estimating an

OAN


The report starts with the 2011 household formation rates but then recommends a partial return to trend for age group 25-34 year olds from 2015 until in 2025 they are half way between the 2008 and 2011 based rates. Thereafter household formation rates are assumed to remain half-way between the 2008 and 2011-based rates. It is assumed there will be no return to trend for other age groups.

Do you agree with this approach? No


First of all we do not see the logic in the partial return to trends for 24 to 34 year olds.

A 50% return from the 2011-based to the 2008-based headship rates is described as

a “prudent planning assumption”. To us this choice seems arbitrary. Earlier the report

described the factors that it has properly set out as reasons for the dampened

household formation rates (para 54). The report also accepts that the international

migrant affect is likely to be lower in Stroud that the England average (we are

grateful that the authors have picked up this point made earlier by us).

However, the report seems to offer a council of despair in terms of affordability

issues for younger people (not likely to change in the “foreseeable future” see para

55(b)). By 2031 we see no reason why the structural issues the report identifies

could and indeed should have not been addressed. To assume only 50% “catch up”

seems to be arbitrary.

We suggests that “positively planning” would instead assume that the economic

affordability issues for young people can and should be surmounted. Therefore at

the very least the planning assumption should assume full return to trends for those

aged 25 to 34 in Stroud. We believe from the earlier presentation that applying full

return to trends for this age group would increase the OAN purely on a demographic

basis by around 30 dpa to 460 dpa.

The report makes stronger points about dealing with the use of 2011-based forecast

household formation rates for other age groups.



Do you agree with this figure? Yes




Do you agree with this figure? No


See above. At the very least we suggest that for those aged 25 to 34 there should be

full return to trends by 2031, we believe this would add of the order of 20 to 30 dpa to

the base demographic OAN.

Market signals


Do you agree? No



The report is too dismissive of the evidence on affordability and the case for a

market signals adjustment. Taking a longer time period (pre-dating 2001) there is

some evidence of a worsening in relative affordability in Stroud (which would be

consistent with the evidence suggesting relative constraint since the mid 1990s).

If the case for some level of market signal adjustment is accepted, then:

At the very least this argues strongly for the use of “undiluted” 2008 long term

trend household formation rates;

Earlier work by Regeneris has suggested that a market signals uplift could be

considerable greater especially if the intention is to ensure that previously

identified affordable housing needs.

We also note that the report says “It certainly would not be appropriate to

increase the total volume of housing planned for until the amount of affordable

housing that can be delivered through S106 agreements equals the affordable

housing need” (para 88). This may be reasonable in the context of purely

considering the need for market housing, by NPPF requires LPAs to aim to

meet the full need for market and affordable housing.

Under supply


Do you agree? No



We are a little sceptical of the analysis in the report. The data presented for Stroud

could well be influenced by the fact that the period from 1994/5 onwards saw

housebuilding rates fall relative to the England average (due to policy constraint).

Concealed Families


Do you agree? Yes

Overcrowding


Do you agree? Yes

Affordable housing


Do you agree? No



The report acknowledges that assessing affordable housing need is out of scope of

the work. It quotes PPG “An increase in the total housing figures included in the local

plan should be considered where it could help deliver the required number of

affordable homes”. However, it seem to ignore the role of an increase in the volume

of market housing to help deliver against the assessed need for affordable housing

in Stroud.


Economic forecasts



Do you agree with this approach? Yes, in part but….


used?

We consider it sensible if possible to use two sets of forecasts where these are both

reasonably up to date. CE and OE are well respected forecasting houses. We accept

that there is a considerable degree of uncertainty around forecasts at a local level.

However, we have some concerns with how the forecasts have been used and

interpreted:

1. The work should have reviewed in more detail the evidence from past

economic and employment growth in Stroud (and elsewhere). This

provides a useful sense check. Clearly past trends should not necessarily be

extrapolated forward; there may be good reasons why some sectors such as

public services will see slower growth than historically due to squeezes on

public spending (but note that the ageing of the population in Stroud will

increase demand for some caring/health service).

2. An analysis of past trends over at least one economic cycle in Stroud

suggests, we consider, that the current OE forecasts are particularly cautious

for Stroud.

3. The OE forecasts have, for some reason, been reduced for Stroud over the

last 9 months even though the UK level forecasts have been upgraded. For

instance trough to trough (1993 to 2011) total employment in Stroud grew by

around 11,000 jobs in Stroud. The effective flat-lining of the OE forecasts for

Stroud from 2020 onwards are simply implausible. It is also the case that this

assumption is not consistent with that assumed in earlier work on future

employment land needs in the Stroud area.

4. We note the report states in the context of past trends that “the projections for

Stroud might be argued to be a little low”. This strikes us as a serious

understatement. The extrapolation in Figure 35 is a little difficult to interpret,

but for Stroud the flat-lining of growth especially in the OE forecasts beyond

2020 looks most implausible

5. The second key point is that the report focusses almost entirely on the

potential downsides to the employment forecasts and does not provide a

balanced assessment. This is spite of the report stating that “there is

considerable uncertainty in the projections, not that they are necessarily too

high or too low” (para 111). The sensitivity analysis focussed on lower rates of

jobs growth in certain sectors rather than for instance a slower rate of decline

in manufacturing employment in Stroud.

6. We note the comments made about productivity and jobs growth. However,

we have no reason to consider that future productivity growth is understated

by either CE or OE. This is clearly a factor these economic forecasters have

to consider carefully in their modelling. It is dangerous to try and compare the

recovery from the recent recession from that of the 1990s as the shape and

nature of the recession is fundamentally different.

7. We do not consider that the approach of sensitivity testing one sectoral

growth factor from the CE forecasts (public services) is necessarily robust

either. By the same token it could be argued that both sets of forecasts are,

for Stroud, less positive for the prospects of manufacturing jobs than historic

experience would suggest.







We can understand why the authors have taken this approach as, at one level, it

appears logical. It does however assume that the models are robust in their

assessment of economic activity rates at a local level. We do not consider that this is

always the case.

These forecasts are sensitive to the actual starting point, in terms of economic

activity rates by age and gender in 2011, and the nature of future population change.

The approach adopted by OE is very broad brush as they do not at a local level

forecast economic activity rates by age and gender groups. This is our preferred

approach and is possible using POPGROUP. We are wary of using the OE forecast

economically active and the consequent population and households which are all

contained in a “black box”.

We have carried out some analysis of the OE forecasts of working age population

and residents in employment over the period 2011 to 2031. They imply, certainly for

Stroud, an implausibly large increase in economic activity rates for the whole

population compared to the numbers aged 16-64. In Stroud the ratio is forecast to

rise to 95 in work for every 100 aged 16-64 (much higher than the UK ratio and from

a ratio of 85 in 2012). This would imply, given what we know about the age structure

forecasts by SNPP 2012, economic activity rates for the over 65 year olds by 2031

which are dramatically higher in Stroud than any forecasts we have seen elsewhere

(eg from the OBR).

This does not strike us as a sound basis for planning. A more robust approach is to

apply plausible increases in economic activity rates (based on national view of

increases by age group) to the forecasts population in Stroud, to see what for a

given population rise is the likely future workforce. This can then be compared to

plausible employment forecasts to see what the implications for housing are.

.






It is not entirely clear what the authors have done. If they have ignored the jobs rise

2011 to 2014 then this is seriously flawed. By focussing on the period after 2014

the authors would be missing out on a particularly important period of jobs growth

since the middle of the recession (both CE and OE suggest that around 50% of all

jobs growth 2011 to 2031 is in the first three years 2011 to 2014 in the case of

Stroud). The effect has been that any spare labour has largely been mopped up in

Stroud during this three year period. The authors say “moreover, from a very

practical point of view, it is the period from now onwards that is most relevant” (para

125). This of course ignores the effect that the economic/jobs growth over the last

three years will have had on the labour market and spare capacity. The start date

and time period considered is therefore important.

Also the speed of the recovery in different places may have influenced the

subsequent degree of catch up post 2014, so the performance in 2011 to 2014 and

subsequently is intimately linked.










Our first concern is that the work is not at all clear and transparent in:

1. Exactly how the authors have calculated the extra housing need for “surplus”

jobs over what the base labour requirement is for Stroud (in Figure 40)

2. The assumed relationship between extra jobs and extra labour force,

population and houses

It is difficult therefore to understand exactly how or indeed why the authors have

arrived at the 800 adjustment for Stroud. Based on the CE forecasts the adjustment

should have 1,800 or increasing the 20 year OAN to 525 dpa. This increase would

have been more in line with that proposed for Cotswold and Forest of Dean.

Other matters



We have consistently argued that setting an OAN from 2006, which is now 8 years

ago does not make sense. It also has the effect of reducing the average annual OAN

due to the particular changes that took place over that period. Other areas in

Gloucestershire (such as the JCS area) are using 2011 as the starting point. This

makes a lot more sense as we have a firm fix on a number of data points in 2011

due to the Census. We are not aware of other LPA (who have yet to derive an OAN)

who are trying to assess the OAN from a starting point as far back as 2006. We

understand that this is not the choice of the authors.

Contact Details



Name: Stephen Nicol

Organisation: Regeneris Consulting (acting on behalf of Gladman

Developments)

Contact phone / email: [email protected], Mobile: 07818067309

Or Nicole Penfold, Gladman Developments, [email protected] Tel:

01260 288 849



Documents

What Are the Objectively Assessed Needs for …parties before any further hearing sessions resume. On 14 October 2014, a technical workshop was held in the Council Chamber, Ebley Mill,