Proposed site: 47 & 55 Bucknalls Drive, Bricket Wood. 0 Site address: 47 & 55 Bucknalls Drive, Bricket Wood. DLA Ref: 1991/009 February 2016

Transcription

1 St Albans Strategic Local Plan Publication 2016 Representations by DLA Town Planning On behalf of Peter Rice Developments Ltd & Raymond Rice Developments Ltd Proposed site: 47 & 55 Bucknalls Drive, Bricket Wood. 0 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

2 CONTENTS 1.0 EXECUTIVE SUMMARY INTRODUCTION REPRESENTATIONS TO POLICY SLP REPRESENTATIONS TO POLICY SLP CONCLUSIONS TABLES Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

3 1.0 EXECUTIVE SUMMARY 1.1 Representations made at the pre-submission stage must be based on the soundness of the SLP, as defined in para 182 of the NPPF. Taken as a whole the published SLP is manifestly unsound for the following reasons: A Soundness Test 1 Positively prepared The SLP is not sound because it is not based on a robust objective assessment of housing need. If the objectively assessed need for housing (OAN) had been properly assessed, in line with Government guidance, a significantly higher housing target would be required, which the SLP in its current form is unable to meet. The Council s OAN assessment is: o Not up to date demographic projections pre-date Census information and latest household representative rates. o Based on inappropriate assumptions about past trends o Unsupported by Council's own consultants o Is not adjusted for market signals There has been no consideration of how the SLP could help meet unmet needs from neighbouring authorities. o Dacorum Borough has a challenging new housing target, yet the SLP uses land on the edge of Hemel Hempstead to meet St Albans need; o No consideration is given to meeting unmet needs from Luton. Soundness Test 2 Justified Policy SLP1 is not the most appropriate strategy when considered against reasonable alternatives. The strategy presents an unbalanced housing supply with too great an emphasis on large sites and not enough provision made for small-scale sites. The SLP s supporting evidence is not up-to-date the SHLAA dates from 2009 and was based on a previous and very different policy context. The demographic modelling was undertaken in 2013 and pre-dates the release of key Census 2011 data, the CLG Household Projections and new Household Representative Rates. The last detailed review of Green Belt boundaries was in the early 1980s. Soundness Test 3 Effective There are deliverability doubts about the plan given the emphasis on several large sites Housing provision requires an average of 40 dwellings per hectare, considered to be difficult to deliver given density of surrounding development and scale of infrastructure needed. 2 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

4 There are no meaningful contingency arrangements if housing provision does not proceed as expected. Soundness Test 4 Consistent with national policy The SLP fails to significantly boost housing supply one of Government s top priorities Demonstrating a five-year housing land supply in a local plan is crucial SLP cannot demonstrate a five-year housing land supply, even measured against its own constrained housing target. A summary of proposed changes 1.2 To fully respond to the challenges facing St Albans district an entirely new plan is needed and the Council should commit to starting this work immediately. However, in the meantime an interim plan is needed based on the OAN set out in the South West Hertfordshire SHMA of 705dpa. To address this need in the short-term consideration should be given to allocating additional sites from those already featured in the Council s evidence base and to including positive policies that will deliver housing elsewhere in the district. 3 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

5 2.0 INTRODUCTION 2.1 These representations relate to the pre-submission version of the Strategic Local Plan (SLP) for St Albans, published on 8 January 2016 under Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations These representations are intended for the consideration of the Planning Inspector appointed to conduct the public examination of the SLP, once it is submitted by St Albans City and District Council (SADC). However, clearly SADC will need to consider these representations before deciding whether to submit the SLP as published of whether to propose further changes to make it sound and then re-publish. 2.3 These representations highlight a number of important flaws in the published SLP, as summarised. Proposed changes are set out that could remedy some of these flaws on an interim basis, although the picture will not be complete until a full review of the local plan is produced. 4 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

6 3.0 REPRESENTATIONS TO POLICY SLP8 Summary 3.1. Policy SLP8 is unsound for the following reasons: Soundness Test 1 Positively prepared It is not based on a robust objective assessment of housing need. If the objectively assessed need for housing (OAN) had been properly assessed, in line with Government guidance, a significantly higher housing target would be required, which the SLP in its current form is unable to meet. The Council s OAN assessment is: o Not up to date demographic projections pre-date Census information and latest household representative rates. o Based on inappropriate assumptions about past trends o Unsupported by Council's own consultants o Is not adjusted for market signals There has been no consideration of how the SLP could help meet unmet needs from neighbouring authorities. o Dacorum Borough has a challenging new housing target, yet the SLP uses land on the edge of Hemel Hempstead to meet St Albans need; o No consideration is given to meeting unmet needs from Luton. Soundness Test 2 Justified Policy SLP8 is not the most appropriate strategy when considered against reasonable alternatives. The strategy presents an unbalanced housing supply with too great an emphasis on large sites and not enough provision made for small-scale sites. The SLP s supporting evidence is not up-to-date the SHLAA dates from 2009 and was based on a previous and very different policy context. The demographic modelling was undertaken in 2013 and pre-dates the release of key Census 2011 data, the CLG Household Projections and new Household Representative Rates. Soundness Test 3 Effective There are deliverability doubts about the plan given the emphasis on several large sites Housing provision requires an average of 40 dwellings per hectare, considered to be difficult to deliver given density of surrounding development and scale of infrastructure needed. Soundness Test 4 Consistent with national policy The SLP fails to significantly boost housing supply one of Government s top priorities 5 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

7 Demonstrating a five-year housing land supply in a local plan is crucial SLP cannot demonstrate a five-year housing land supply, even measured against its own constrained housing target. Proposed changes summary To fully respond to the challenges facing St Albans district an entirely new plan is needed and the Council should commit to starting this work immediately. However, in the meantime an interim plan is needed based on the OAN set out in the South West Hertfordshire SHMA of 705dpa. Assessing housing need Planning Practice Guidance 3.2. The Government s Planning Practice Guidance (PPG) sets out a recommended approach to assessing housing needs. The starting point estimate for overall housing need should be the Household Projections published by the Department for Communities and Local Government (CLG) (Reference ID: 2a ). These projections are produced at the national level so shouldn t be accepted without critical analysis. However, any deviation from the national set of projections should be based on evidence and fully justified. The SLP proposes a housing target (436 dwellings per annum) which is more than 30% lower than the most recent (2012-based) CLG household projections (637dpa). In the SLP evidence base the most recent CLG household projections are not considered in any meaningful way and the substantial deviation is nowhere explained or justified The PPG goes on to explain the adjustments that may be necessary to the starting point estimate: The household projection-based estimate of housing need may require adjustment to reflect factors affecting local demography and household formation rates which are not captured in past trends. For example, formation rates may have been suppressed historically by under-supply and worsening affordability of housing Completion rates have not kept pace with projected household formation rates in St Albans for many years. This issue does not appear to have been considered in detail in the SLP evidence base The starting point estimate should also be considered in the light of information on a range of market signals, including land prices, house prices, rents, affordability, rate of development, overcrowding. According to the PPG a worsening trend in any of these indicators will require upward adjustment to planned housing numbers compared to ones based solely on household projections. The SLP evidence base contains no consideration of market signals nor how these should influence the SLP s housing target. 6 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

8 3.6. The PPG goes on to set out how the housing needs of specific groups should be considered, how the overall need for affordable housing should be calculated and how 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. Again, the SLP s evidence base fails to grapple with any of these issues. Assessing housing need the SLP evidence base 3.7. As set out above, the SLP evidence base does not take the approach advocated in the PPG. Instead, the housing target of 436 dwellings per annum has been taken from some demographic modelling undertaken by Edge Analytics in 2013 (Housing Growth Forecasts demographic analysis and forecasts, Edge Analytics, October 2013). The various scenarios produced by Edge are set out in Table 1 below. Of the 9 scenarios presented, the 436dpa figure was the lowest demographic-based projection, higher only than the dwellingconstrained figure of 250dpa. Table 1: Demographic scenarios (Edge Analytics, 2013) Housing Vision s recommended housing target SLP s chosen housing target 3.8. Edge do not set out a recommended dwelling target but present a range of options. These options were then considered by consultants, Housing Vision, in producing the Council s Strategic Housing Market Assessment (SHMA) in Housing Vision recommended using the 5-year trend figure of 584dpa. However, the Council determined to use the 10-year trend figure of 436dpa. The rationale for adopting 10-year trends is not explained in detail, 7 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

9 nor is it justified by reference to evidence. The lack of professional endorsement for the 436dpa target by either of the Council s consultants is particularly telling. Assessing housing need recent case law 3.9. The main principles involved in assessing housing need and setting a local plan housing target have been established through recent case law The Hunston judgement (Hunston Properties Ltd [EWCA] Civ 1610 relating to a site within St Albans district) confirmed that constraints such as Green Belt should not feature in the calculation of housing need but could be considered in terms of the extent to which a Local Plan should go to meet those needs (Sir David Keene, para 25) These issues were further considered in the judgement in respect of a High Court challenge brought by developers, Gallagher Estates Ltd and Lioncourt Homes Ltd, against the Solihull Local Plan ([2014] EWHC 1283 (admin) it is clear that paragraph 47 of the NPPF requires full housing needs to be assessed in some way. It is insufficient, for NPPF purposes, for all material considerations (including need, demand and other relevant policies) simply to be weighed together. Nor is it sufficient simply to determine the maximum housing supply available, and constrain housing provision targets to that figure. Paragraph 47 requires full housing needs to be objectively assessed, and then a distinct assessment made as to whether (and, if so, to what extent) other policies dictate or justify constraint. (Hickinbottom J, Para 94) At the Court of Appeal ([2014] EWCA Civ 1610) this judgement was considered by Laws LJ who held that: The NPPF indeed effected a radical change. It consisted in the two-step approach which paragraph 47 enjoined. The previous policy's methodology was essentially the striking of a balance. By contrast paragraph 47 required the OAN to be made first, and to be given effect in the Local Plan save only to the extent that that would be inconsistent with other NPPF policies. (Laws LJ, para 16) The constraints to development in St Albans district seem to have featured in the Council s determination of not only the housing target for the district but also the calculation of objectively assessed need. This is indicated by the fact that the housing target chosen by the Council was the lowest among a range of demographic projections and was chosen without any endorsement by the Council s professional consultants, nor indeed any specific recommendation by SADC planning officers. 8 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

10 3.14. More significantly, the Council s flawed approach to concluding a housing target is also indicated in the text of the SLP itself at paragraph 6.24 when it talks of balancing the SHMA findings with other considerations. If the Objectively Assessed Need for housing (OAN) is as SADC claim it to be then it is not clear how the factors listed in paragraph 6.22 of the SLP (and set out in detail in the Council s evidence in the background note on A Local Housing Target 2014) have been taken into account. The balanced approach, weighing all factors together, which the Council has gone to great lengths to explain can only have taken place in consideration of the OAN. This is directly contrary to the approach advocated by the Hunston and Gallagher/Solihull judgements referred to above. Assessing housing need the approach of surrounding authorities The Government s Planning Practice Guidance emphasises the importance of councils working together on housing needs assessments: Local planning authorities should assess their development needs working with the other local authorities in the relevant housing market area or functional economic market area in line with the duty to cooperate. This is because such needs are rarely constrained precisely by local authority administrative boundaries. (PPG Ref. ID: 2a ) The definition of the Housing Market Area (HMA) is therefore important and must pick up any important cross-boundary relationships in the HMA. A number of authorities in the South West Hertfordshire area have come together to commission a joint SHMA. Dacorum, Three Rivers, Hertsmere and Watford Councils have commissioned consultants GL Hearn to produce a SHMA for this area and Regeneris to look at economic needs and supply. The final study was published in early February SADC was invited by the above authorities to become a commissioning authority for the SHMA but unfortunately declined. Instead SADC participated merely in an observatory capacity GL Hearn s view of the extent of the HMA is set out at para 2.6 of the SHMA: The inclusion of St Albans in a common HMA to the commissioning authorities is inconsistent with St Albans City & District Council s own SHMA Report; but is supported by up-to-date independent work undertaken for Bedfordshire and surrounding authorities; and its inclusion within a common Broad Rental Market Area, as defined by the Valuation Office Agency (VOA). 9 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

11 3.19. SADC expressed the view that St Albans should not be included with the HMA. GL Hearn responded as follows: During consultation St Albans City and District Council has criticised the inclusion of St Albans district within the HMA, referring mainly to evidence on house prices. We have reviewed the evidence in the light of this Council's comments, both at an early stage and later in the Study. Our conclusion is that there are very strong grounds for including St Albans within the HMA. (GL Hearn, SW Herts SHMA,para 2.13) GL Hearn proceeded to assess housing needs across the HMA and produce an OAN figure for each authority within the HMA. GL Hearn s OAN for each area is set out in Table 2 below: Table 2: Conclusions on OAN at Local Authority Level (Per Annum, ) OAN for Housing Dacorum 756 Hertsmere 599 St Albans 705 Three Rivers 514 Watford 577 HMA 3, It is striking that the OAN for St Albans as identified by GL Hearn differs so dramatically from St Albans own work. Given that GL Hearn s work was produced for the HMA as a whole, was based on up-to-date information (unlike SADC s own work) and was agreed collaboratively by four councils, it is considered that this work should carry greater weight than that produced by SADC. In addition, it is also worth considering that GL Hearn s work may be an underestimate of housing need since it does not adjust for Unattributable Population Change (see below for details). Population trends and components of change Population and household projections are based on past trends. In projecting trends forward it is important to analyse in detail the nature of those trends to understand what is being projected forward and whether those assumptions are appropriate for the projection period Information from the Census is generally regarded as the best available demographic information. It is not perfect by any means but it is the best available. No specific doubts have been raised by the Council about the reliability of Census information for St Albans. Table 3 below sets out basic information about St Albans from the Census. 10 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

12 Table 3: St Albans population and household change (source: 2001 & 2011 Census, ONS) Years Population Households Average household size ,200 52, ,600 56, Change ,400 3,481 Annual change 1, % increase % 6.61% It can be seen that the population grew in the 10-year period to 2011 by 11,400 or 1,140 per year. However, household growth took place at a slower rate over the 10-year period (6.61% compared to 8.82%). The effect of this was an increase in average household size If household growth at taken place at the same pace as population growth (i.e. household size were to have remained constant between 2001 and 2011) then an additional 1,164 households would have formed over the ten-year period. In reality these households have not formed for a variety of reasons. The increase in household size over the ten-year period runs counter to the national trend for decreasing household size. However, it is reasonable to speculate that the constraints on the supply of new housing have had an impact on the ability of households to form More detailed information is available on the key components that make up population change (births, deaths and migration). Information from the Office for National Statistics (ONS) is detailed on an annual basis in Table 4 at the end of this report The Council s housing target in Policy 8 is derived from a 10-year trend projection produced by Edge Analytics in a report dated October The 10-year period chosen by Edge was 2002/3 to 2011/12 being the most recent information available. However, as is evident from the Table 4, that 10-year period was characterised by two distinct periods. The first five-year period (2002-6) saw relatively low population growth (an average of 786 persons per year), whereas the second five-year period ( ) saw much higher growth (1,512 persons per year). This pattern was evident in all aspects of population growth with more births, less deaths, more internal in-migration and less international out-migration in the second half of the decade compared with the first. Taking a 10-year average dilutes the impact of the higher population growth and projects a lower rate going forward ONS uses five-year trends to produce the Sub-National Population Projections that underpin the CLG Household Projections. These projections are, according to the national Planning Practice Guidance (PPG) (ID 2a ), the starting point for consideration of objectively assessed housing need. Nevertheless, the PPG does not 11 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

13 stipulate that five-year trends must be used to calculate housing need. When planning for the long-term there is sometimes sense in taking a longer-term view of trends. However, just as five-year trends are not stipulated in government guidance, using ten year trends does also not automatically produce accurate and appropriate projections for planning purposes. Detailed analysis is needed of past trends and how they may alter looking ahead. Sadly, that analysis is not present in any of the Council s evidence studies Using ten-year trends can be useful in reducing the effect of rogue results that might distort a five-year trend. However, the overall pattern evident from Table 4 above is one of gradual and sustained increase in population. It would appear difficult to maintain an argument that the natural change element of population growth will not continue its recent trajectory. Similarly, it is difficult to envisage a substantial drop in migration (either internal or international) given the failure of recent government action on the issue Even if a ten-year trend could be justified, if the Council had produced an up-to-date 10- year projection ( ) it would have been based on trends showing an annual average population increase of around 1,200 persons per year, as opposed to 950 persons for the period. 250 additional people each year could total 5,000 over a twenty year plan period, meaning around 2,000 additional houses. This illustrates the importance of projecting forward appropriate trends. Past housing completions in St Albans district When looking at past trends it is important to appreciate policy factors that may have influenced those trends. The Green Belt covering most of St Albans district means that new sites on the edge of the built up area must come forward through the Local Plan process. In St Albans the last local plan was adopted in 1994 and hence the supply of new greenfield sites has diminished. Completions are now therefore reliant on brownfield sites being recycled for other uses. The overall level of completions in St Albans since 1994 is shown in Figure 1 below. The trend line added shows the gradual decline in housing completions. 12 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

14 Figure 1: Housing completions in St Albans Looking back over a 10-year period, housing land supply has been constrained by the lack of a new local plan proposing new greenfield sites and this has had an impact on the ability of new households within St Albans to form and on those wishing to move into St Albans from outside. The trends that appear for that 10-year period are not natural trends but are heavily influenced by the shortage of new homes being built. If a new Local Plan had been produced sometime during the early 2000s, new sites would have been allocated, housing completions would have been higher, population growth would therefore have been higher and, potentially, out-migration to other parts of the UK might have been lower. This needs to be factored in when considering future population and household projections. Unattributable Population Change The components of population change produced by ONS and shown in table 4 are only accurate if an adjustment is made for other or Unattributable Population Change (UPC). In other words, if you take the 2001 census population as a starting point and add ONS annual additions for natural change, internal and international migration, the population you would have by 2011 would be substantially less than the 2011 census recorded around 2,250 people less. ONS use UPC as a way of boosting the population so that it matches the 2011 Census. In St Albans case, UPC is an upward adjustment of about 226 persons per year. This issue is outlined in the Edge 2013 report and the relevant figures are copied below. Figure 10 from the Edge Report shows the unadjusted figures and figure 11 shows the figures incorporating UPC. The key impact UPC has is that the large migration 13 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

15 overseas during the period is reduced or removed and the relatively small international in-migration is increased. 14 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

16 3.34. Critically, however, ONS does not incorporate UPC when producing its population projections. The rationale for not adjusting for UPC is that ONS cannot be certain where the error lies. The consultants that produced the Council s SHMA, Housing Vision, addressed the issue of UPC in their Response to Supplementary Questions report in 2015 and explain that it could be due to sampling error in either of the recent censuses or errors in the intercensal components Edge Analytics view on UPC is set out in paragraph 4.16 of their 2013 report: On the assumption that births, deaths and internal migration have been robustly measured (and that the 2001 Census provided a robust population count for St Albans District), the adjustment that resulted from the mid-year population estimate revisions (to account for the so-called unattributable change ) is predominantly associated with the mis-estimation of international migration: the balance between immigration and emigration flows to and from the District Housing Vision s 2015 Supplementary Questions report outlines how the 2012-based population projections underestimate international migration into the UK. The Council has not identified any specific concern about either the 2001 or 2011 censuses. On this basis, while we cannot be sure, all the evidence points to underestimated international migration being the source of the population underestimate A recognition of the effect of UPC on demographic projections has been accepted by a number of local plan examination Inspector s including at the Bath and North East Somerset local plan. It has also been accepted in the context of a Section 78 appeal for land at High Street, Henlow (APP/P0240/W/14/ ). Each case should be examined on its merits and the fact that it has been accepted elsewhere is not enough. However, neither is it enough to dismiss this potentially significant factor simply because ONS are not sure how to deal with it at the national level For St Albans, making an appropriate adjustment to reflect UPC would mean an upward adjustment to the population and household projections, possibly of the order of 100 homes per year or around 2,000 homes over the plan period. This is a substantial increase and highlights the importance of considering this issue in more detail. Household Representative rates (HRR) Converting population projections into household projections requires the use of Household Representative Rates (HRR). These are published periodically by ONS, with the latest (2012-based) iteration being published in However, the SLP evidence base does not contain a household projection for St Albans using the latest HRR. The most recent demographic modelling was undertaken by Edge in 2013 and used the interim based HRR, which only covered the period to 2021 and was not informed by the 2011 Census results. 15 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

17 3.40. Work published by Barton Willmore in 2015 compared the effect of applying the interim 2011-based HRR and the 2012-based HRR to the same population over the period 2011 to The effect varies from area to area but for St Albans Barton Willmore found a 16.2% increase when applying the 2012-based HRR compared with the interim 2011-based HRR ( The overall effect for St Albans is not as straightforward as adding 16.2% to the SLP housing target but as a reference point, a 16.2% increase in households would require in the order of 1,400 additional homes over the plan period On such a critical issue as household projections it is vital that the SLP evidence base is upto-date. It is imperative that a new population and household projection be carried out using the latest demographic information available, including the latest HRR. Market signals/affordability adjustment As set out above, an important element of Objectively Assessed Need for housing (OAN) is consideration of market signals and whether an adjustment to the raw projection is needed Property prices in St Albans hit the national media in 2014 when the annual house price increase hit 24% - the highest in the country ( Mean house price increases since the fourth quarter of 1995 in St Albans and surrounding districts are set out in Table 5 below. Also included for comparison purposes are the findings for Aylesbury Vale and Milton Keynes districts. Mean house price growth in St Albans of 472% since 1995 is the highest in the area Table 6 below sets out housing completion figures for the same group of authorities for the period (the most recent data available) Although the picture is complex, comparing Table 5 with Table 6, shows a group of similar authorities (St Albans, Hertsmere and Three Rivers) where dwelling growth for the past decade or so has been limited and where average house prices have increased significantly. With the highest house prices in the area, average house prices that are increasing rapidly and continuing restrictions on new housing supply, St Albans is a prime candidate for the sort of upward adjustment to the housing target envisaged by the PPG. Instead, the SLP proposes a constrained housing target that will only perpetuate the current affordability problems. Housing needs and local authority boundaries The approach of the authorities in South West Hertfordshire to this issue has been set out above. Their joint commissioning of GL Hearn to produce a SHMA for the whole of the 16 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

18 Housing Market Area is to be welcomed and it is disappointing that SADC felt unable to participate in this joint work The key advantage of looking at housing need across an HMA is that it can set aside local authority boundaries and examine where housing need is arising and, as a consequence, how any future housing sites relate to housing need. Thus, within the demographic projections for Dacorum Borough, a substantial element of the household growth will occur in Hemel Hempstead (the largest settlement in Dacorum). In planning terms it therefore makes sense for Hemel Hempstead to grow and eastward growth of the town appears the most likely direction. However, sites on the eastern side of Hemel Hempstead just happen to fall within St Albans district. As a consequence of the lack of understanding about how housing market areas relate to local authority boundaries, the SLP promotes growth around St Albans but claims that it will meet housing need arising in St Albans district There are two significant problems with this approach. Firstly, as a general rule housing need should be met as close as possible to where the need arises since it enables people to remain in the area where they currently live, can enable shorter commutes to work and helps people to retain their existing network of social contacts. If a substantial element (currently more than 25%) of the housing need arising in St Albans is planned to be met on the edge of Hemel Hempstead, which relates far more closely to Dacorum than it does to St Albans district, this has significant consequences for those wanting to stay in, or move in to, St Albans The second problem is that a significant chunk of the capacity for future development around Hemel Hempstead is being taken up meeting housing needs from elsewhere. This presents a significant issue for Dacorum Borough Council who will be shortly beginning the process of seeking to accommodate a housing need of around 756 dwellings per annum (compared with a current Core Strategy target of 430dpa). Dacorum Borough Council has previously written to neighbouring councils alerting them to the fact that it may not be able to accommodate its housing need within the district. If the 2,500 homes possible to the east of Hemel Hempstead are not able to contribute to Dacorum s housing need then it is likely that this housing will either need to be accommodated in less sustainable locations or shipped outside of the district, both of which have sustainability implications Had SADC engaged with the SW Herts authorities in the joint SHMA work it would have had a better understanding of how housing needs operate across local authority boundaries and how any provision relates to that need To address this soundness issue in the SLP it will be necessary to recognise that a substantial portion of the proposed housing to the east of Hemel Hempstead will be needed to meet Dacorum s housing need and cannot therefore contribute to meeting St Albans need. This will leave a shortfall in the housing provision in St Albans which will need to be made up. 17 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

19 Five-year housing land supply A critical function of a local plan is to set out a five-year supply of housing sites. The government s Planning Practice Guidance explains the additional rigour with which the five-year supply will be tested at Examination, compared with individual planning applications: The examination of Local Plans is intended to ensure that up-to-date housing requirements and the deliverability of sites to meet a five year supply will have been thoroughly considered and examined prior to adoption, in a way that cannot be replicated in the course of determining individual applications and appeals where only the applicant s/appellant s evidence is likely to be presented to contest an authority s position. (Reference ID: ) The five-year housing target should come from the local plan. Leaving aside the question marks over the SLP s housing target outlined above, the detail of the five-year land supply calculation is set out in Table 7 below. 436 dwellings per year produces a basic five-year requirement of 2,180 (row G). There has been a shortfall of 356 dwellings over the period (row F) and this needs to be added to the requirement. A buffer needs to be added in line with the NPPF para 47. The standard buffer is 5%, although this should be increased to 20% where there has been a record of persistent under delivery. The 436 dwellings per year target applies from 2011 and completions have not reached this target in the four years since On this basis a 20% buffer would be appropriate In terms of supply, the Council s latest AMR covering the monitoring period 2014/15 sets out a five-year supply of 2,336 dwellings. With a 5% buffer this supply produces a five-year supply figure of 4.39 years (row K, column 4). Applying the 20% buffer the supply reduces to 3.84 years (row O, column 4). The housing trajectory in the SLP adds in delivery from the broad locations at North West Harpenden (166 dwellings by 2020) and East St Albans Oaklands (154 dwellings) to make a five-year total supply of 2,656 dwellings (row J, column 5). With a 5% buffer a supply of 4.99 years (row K, column 5) is produced and with a 20% buffer the supply becomes 4.36 years (row O, column 5) It is only when both the two Green Belt sites are added and when a 5% buffer is applied that the SLP can demonstrate a five-year target. The pattern of delivery since 2011 justifies the application of a 20% buffer. According to footnote 11 of NPPF para 47, to be deliverable sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular that development of the site is viable. As both of the broad locations (North West Harpenden and Oaklands) will remain in the Green Belt until adoption of the DLP, it is difficult to see how they can be considered a suitable location for development now. The Council sets out at great length in its 2015 AMR (para 13) how it considers housing need does not constitute very special circumstances to justify development in the Green Belt. This would appear to preclude early delivery of these sites 18 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

20 ahead of the DLP timetable. Given the previous delays in plan-making in St Albans it is difficult to be optimistic about the prospects of the DLP being adopted on time and hence enabling delivery of the two broad locations. Taking all of this together, these two broadly locations cannot be considered deliverable now, which means that the SLP cannot demonstrate a five-year supply of housing, which means that it is not sound The supply of housing land set out in the SLP is heavily reliant on 3 large proposed development sites (East of Hemel Hempstead, North West Harpenden and Oaklands College). If any one of these sites were to be delayed it would jeopardise the housing target being met. Given that these sites will remain in the Green Belt even if the SLP were adopted the scope for delays is substantial. A more balanced portfolio of sites, including more smaller sites, would help make the housing land supply more robust It is also worth noting that these calculations assume that the SLP housing target is adequate. These representations have argued that the SLP housing target is not adequate and its usefulness in measuring a five-year housing land supply is questionable. By way of comparison, using the South West Herts SHMA OAN target of 705dpa would produce a five-year supply of between 1.96 and 2.24 years (depending on the size of the buffer applied) once the Green Belt sites have been discounted. Table 7: St Albans five-year housing land supply calculations 19 Site address: 47 & 55 Bucknalls Drive, Bricket Wood. Five-year supply estimate from AMR Five-year supply estimate from SLP (includes GB strategic sites) A Total requirement B Plan period C Annual target (A/B) D Target (4xC) E Completions (from AMR) F Shortfall (D-E) G target (5xC) Target + shortfall + buffer H (G+F+ 5%) % BUFFER I Annual requirement (H/5) Five-year supply (Council J estimate) K Five-year position (J/I) Target + shortfall + buffer L (G+F+ 20%) % BUFFER M Annual requirement (L/5) Five-year supply (Council N estimate) O Five-year position (N/M)

21 Proposed Changes In setting out changes to make the SLP sound the need to get a plan adopted as quickly as possible must be a substantial consideration. The current local plan dates from 1994 and is no longer fit for purpose. Similarly, the scale and urgency of the need for housing is such that new provision is needed now. With this in mind, finding the SLP unsound and beginning the process again is in nobody s best interests. A pragmatic approach is therefore needed To fully respond to the challenges facing St Albans district a new plan is needed with a new housing target, a new strategy for development and a full review of the Green Belt boundaries last reviewed in the early 1980s. It is important at this stage that the Council commits to this new plan, together with a timetable for the work. However, this new plan will take 2-3 years to complete and an interim approach is needed to deliver additional housing land in the short-term In our view for an interim plan there is no need to begin again the lengthy work towards an OAN figure. Instead DLA Town Planning would suggest that the SLP s 436 dwellings per annum (DPA) housing target is replaced with the OAN set out in the South West Hertfordshire SHMA of 705dpa. We would argue that, if anything, this figure could be an underestimate of housing need since GL Hearn did not adjust for UPC, which for St Albans represents a positive adjustment that could mean around 2,000 additional homes over the plan period. Nevertheless, using the GL Hearn OAN figure would be appropriate as an interim change pending a full review of the SLP and a new housing target defined The SW Herts SHMA uses the CLG household projections as the starting point and incorporates an element of uplift responding to market signals. While the merits of this OAN could be debated at length, it is considered a reasonable enough proposition on which to base an interim strategy In addition to the basic St Albans housing requirement it is also important to recognise cross-boundary housing market area issues. The proposed broad location at East Hemel Hempstead will largely meet housing need arising in Dacorum borough. As such, it cannot all count towards St Albans housing requirement. This issue will need agreement with Dacorum Borough Council. In any event, the net effect is to substantially increase the housing need in St Albans An annual housing target of 705dpa would produce a total target of 14,100 over the plan period. Deducting the Council s current housing land supply leaves a shortfall of 4,945 homes. This would need to be supplemented by the increase in housing requirement as a 20 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

22 result of assigning some or all or the growth east of Hemel Hempstead to Dacorum s housing need. The total shortfall is likely to be in the region of 6,000-7,000 homes Clearly there will be additional work for the Council to do to investigate how best to achieve this increase. DLA Town Planning s response to policy SLP1 sets out a suggested starting point for the Council to consider and that could be the subject of public consultation. However, with such obvious and well-documented capacity for development in the district the starting point should be that this scale of development can be accommodated. This approach would accord with the NPPF s requirements and the approach set out in the Gallagher/Solihull judgement referred to above. 21 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

23 4.0 REPRESENTATIONS TO POLICY SLP1 Summary 4.1. As the housing target in the SLP is so wholly inadequate, the proposed strategy is similarly inadequate to deal with the increased housing provision necessary. Leaving aside the substantial flaws in Policy SLP8, Policy SLP1 is unsound for the following reasons: Soundness Test 2 Justified Policy SLP1 is not the most appropriate strategy when considered against reasonable alternatives. The strategy presents an unbalanced housing supply with too great an emphasis on large sites and not enough provision made for small-scale sites. The SLP s supporting evidence is not up-to-date the SHLAA dates from 2009 and was based on a previous and very different policy context. The last detailed review of Green Belt boundaries was in the early 1980s. Soundness Test 3 Effective There are deliverability doubts about the plan given the emphasis on several large sites Housing provision requires an average of 40 dwellings per hectare, considered to be difficult to deliver given density of surrounding development and scale of infrastructure needed. There are no meaningful contingency arrangements if housing provision does not proceed as expected. Soundness Test 4 Consistent with national policy The SLP fails to significantly boost housing supply one of Government s top priorities Demonstrating a five-year housing land supply in a local plan is crucial SLP cannot demonstrate a five-year housing land supply, even measured against its own constrained housing target The changes to policy SLP1 proposed by DLA Town Planning are: Inclusion of additional strategic sites Inclusion of additional small scale sites Inclusion of a positive policy relating to emerging neighbourhood plans 22 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

24 4.3. Such changes amount only to an interim solution and are predicated on there being a commitment by the Council to an immediate review of the local plan, a new housing target produced and a full review of detailed Green Belt boundaries. Representations 4.4. It is difficult to make meaningful comments on policy SLP1 since it is predicated on a housing target that substantially underestimates household growth over the plan period. Nevertheless we consider that the strategy in policy SLP1 is not the most appropriate strategy when considered against reasonable alternatives. The strategy presents an unbalanced housing supply with too great an emphasis on large sites and not enough provision made for small-scale sites. This makes the overall housing land supply less robust and vulnerable to delays with large sites requiring significant infrastructure investment. Considerable capacity exists around the district for small-scale sites which could supplement the strategy and help add robustness without affecting the overall purpose of the Green Belt. However, such sites have not been provided for One possible reason that this capacity has not been recognised by the Council is that the evidence is not up-to-date. The latest SHLAA published alongside the SLP dates from 2009 and was based on previous policy context with a much lower housing target derived from the now-revoked East of England Plan. The last detailed review of Green Belt boundaries was in the early 1980s as part of the evidence for the original 1985 District Plan In order to meet the SLP s housing target the three broad locations identified need to be built out with a gross to net ratio of 60% and a net density of 40 dwellings to the hectare (dph). While this density may be achievable in a new town context, it is considered difficult to deliver on the edge of historic towns like Harpenden and St Albans. There is little in the way of supporting evidence to demonstrate that this density if achievable. Moreover, there are no contingency arrangements in the SLP if the overall net density falls below 40dph The lack of contingency provision is much wider than just the density issue as a setback with one of the strategic sites could jeopardise the overall strategy in SLP1. The relatively small amount of overprovision against the 436dpa target amounts to less than 5% of the total and is insufficient to provide resilience over the plan period, particularly if housing requirements increase. The Council states at para 6.37 of the SLP that the housing target is considered not to be affected by current or future alternative projections unless there is a highly significant change. However, this statement holds no credibility since the plan is based on almost the lowest housing target possible and contains no contingencies of any substance to cope with an increased housing requirement. 23 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

25 4.8. The Monitoring Framework at Appendix 4 of the SLP is wholly inadequate with no reference to what action will be taken if any of the monitoring targets are not met As a means to get an interim plan in place as quickly as possible, DLA Town Planning proposes a change to policy SLP8 to replace the 436 dwellings per annum (DPA) housing target with the Objectively Assessed Need for housing (OAN) set out in the South West Hertfordshire SHMA of 705dpa. This would be an interim change pending a full review of the SLP and a new housing target defined. An interim way forward If 705dpa were used as an interim housing target it would require a further 5,380 dwellings over the plan period. This would need to be supplemented by the increase in housing requirement as a result of assigning some or all or the growth east of Hemel Hempstead to Dacorum s housing need. The total shortfall is likely to be in the region of 6,000-7,000 homes needing to be planned for, over and above that proposed in the SLP. There are a number of reasons why this scale of increase probably underestimates the total housing need in the district over the plan period but as an interim approach it has merit Clearly, identifying a further 6,000-7,000 homes would represent a significant change to the submitted SLP. Nevertheless, the scale and the urgency of the housing need situation is such that it is in nobody s best interests for the plan to be found unsound and for the council to have to start work again. The aim must therefore be to make the maximum possible contribution to housing need while making as little change to the overall strategy as possible DLA Town Planning s suggestion is therefore that consideration is given to augmenting the strategy set out in SLP1 with the addition of other sites. In order to boost housing supply in the short-term and avoid sending the SLP back to square one, one option would be the consideration of sites identified in the Council s evidence base (specifically the Green Belt Review work undertaken by SKM, in 2013 and 2014) but rejected as not being required in the plan period strategic sites were initially suggested by the consultants although we understand one of these (S7 land at London Colney) is no longer being progressed by the landowner. The strategic sites are listed below in Table Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

26 Table 8 strategic sites identified by SKM, February 2014 Strategic Sites identified in Council evidence Estimated housing capacity (based on SADC s 40dph estimate) S4 north of St Albans 920 S6 Northeast of Harpenden 760 S8 Land at Chiswell Green 360 Total of all 3 strategic sites 2, In addition to the strategic sites 8 small scale sub-areas were also identified in the Council s evidence (Green Belt Review Purposes Assessment, SKM, November 2013). Table 9 below lists the small scale sub-areas together with their gross area, the net developable area (based on a simple 60% ratio taken from the SKM study) and then a density assumption of 40 dwellings per hectare. Table 9 possible additional small scale sub-areas Small scale sub-areas identified in Council evidence Gross area Net area (60% of gross) Estimated housing capacity SA-SS1 Land at northeast edge of St Albans SA-SS2 Land at southwest edge of Redbourn SA-SS3 Land at southeast edge of Redbourne SA-SS4 Land at west of Harpenden SA-SS5 Land south of Harpenden SA-SS6 Land north of How Wood SA-SS7 Land south of Wheathampstead SA-SS8 Land east of Wheathampstead Total of all 8 non-strategic sites 1, At this stage it is not possible to set out which sites should feature. However, the scale of the increase in housing need would require the equivalent to all 3 strategic sites, all 8 small-scale sub-areas and substantial additional sites beyond these. Further work is needed to establish which sites are most appropriate for inclusion in the SLP at this stage. Sites that have been part of the consultation on previous versions of the SLP by virtue of being included as part of the evidence base would be easier to allocate at this stage without substantial prejudice to those wishing to make comments, albeit they would require consultation as a change to the SLP. 25 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

27 4.15. DLA Town Planning is firmly of the view that there is significant capacity for development in St Albans district through small-scale sites on the edge of existing towns and villages. Although these sites are currently in the Green Belt, many of them contribute very little to the overall purpose of the Green Belt and could be brought forward without harm to the overall functioning of the Green Belt in the district. The detailed Green Belt boundaries in St Albans were last reviewed in the early 1980s as part of early work towards the original District Plan adopted in As such, they are no longer fit for purpose and need reviewing in light of the substantial new need for housing in the district Unfortunately, the Council s evidence base does not allow an estimate of the capacity of such sites since any site in the Green Belt was dismissed early on in the SHLAA process. However, DLA Town Planning estimates that a substantial portion of the additional homes needed could be provided for through small-scale adjustments to the Green Belt boundary. In any event, a detailed review of Green Belt boundaries would be needed to establish what capacity exists. This work ought to be done as part of the proposed immediate review of the Local Plan To help bridge the gap between housing need and supply in the interim period until a full review of the local plan is adopted we consider a policy could be included that supports Neighbourhood Plan to come forward and that specifies that, in the context of planning applications, weight may be given to proposed sites included in emerging Neighbourhood Plans when considering Very Special Circumstances. The amount of weight will clearly need to be considered on a case-by-case basis and will reflect the stage reached with the Neighbourhood Plan and the level of public support for the sites proposed. Such a policy would help provide a further incentive for community groups to continue with neighbourhood plans whereas, without such a policy, neighbourhood plans could grind to a halt due to conformity issues with the current adopted Local Plan. Proposed Changes In summary, DLA Town Planning suggests that additional sites are considered, starting with the strategic and small-scale sites identified by SKM. In addition, sites included in emerging neighbourhood plans should also be favourably considered in advance of a full review of the local plan Such changes amount only to an interim solution and are predicated on there being a commitment by the Council to an immediate review of the local plan, a new housing target produced and a full review of detailed Green Belt boundaries. 26 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

28 5.0 CONCLUSIONS 5.1. There are substantial flaws in the published SLP and it is not considered sound. However, finding the SLP unsound and restarting the plan-making process from the beginning is not in the best interests of any of the stakeholders to the process A new plan needs to be started that includes a new housing target and a full review of detailed Green Belt boundaries. A commitment is needed from the Council to an immediate start and a detailed timetable for this work In the meantime, consideration should be given to changes to the SLP to make it sound on an interim basis. This would include the use of a housing target taken from the OAN identified in the South West Herts SHMA. Additional sites that were identified in the Council s evidence base and which have already been included in previous consultation could be considered for inclusion in the form of changes to the SLP The suggested changes would boost housing supply in the short-term, while ensuring that an appropriate strategy is put in place over the longer-term. 27 Site address: 47 & 55 Bucknalls Drive, Bricket Wood.

29 6.0 TABLES Table 4: Components of population change, St Albans, (source: ONS) 28 Site address: DLA Ref:

30 29 Site address: DLA Ref: Table 5: Average house prices, St Albans and nearby districts (source: ONS)

31 30 Site address: DLA Ref: Table 6: Annual dwelling completions, St Albans and nearby districts (source: AMRs)

32 REPRESENTATIONS TO THE DRAFT ST ALBANS STRATEGIC LOCAL PLAN (FEBRUARY 2016) APPENDIX 1: Land at 47 & 55 Bucknalls Drive, Bricket Wood On behalf of Peter Rice Developments Ltd & Raymond Rice Developments Ltd DLA Ref: 91/009 January 2016 SITE POTENTIAL: SKETCH.. 1

33 Introduction This report is submitted as an appendix to the representations made by DLA Town Planning to the St Albans District Council Draft Strategic Local Plan (SLP) (January 2016). The representations to Policy SLP8 sought greater recognition within the SLP of the capacity for development from small-scale sites around the district. Such sites could significantly boost the district s housing land supply while having very limited impact on the Green Belt. The Report Site & Surrounding Area The Report Site is located eastern side of Bucknalls Drive (Nos 49 to 75) and to the west of Bricket Wood Common. Bucknalls Drive comprises the southernmost extension of the large village of Bricket Wood, some 600m south-west of the village centre. REPORT SITE Figure 1. Site Location 1.

34 The Report Site It is proposed that Element Nos 1 and 2, an area of some 1.1 ha, are released from the Green Belt. - Element No1: Nos 47 & 55 Bucknalls Drive Accessed from the main section of Bucknalls Drive via a drive adjacent to Nos 53 and 59, these comprise a pair of large detached chalet bungalows set in the narrowest northern section of the site. - Element No 2: Grassland This central section of the site comprises an area of essentially level grassland which increases in width to the south. - Element No.3 This area could be retained as woodland and form an extension to Bricket Wood Common to the east. Figure 2. Site Elements Map 2.

35 The Site Context The immediate locality includes the following elements: Nos 49a, 51a & 53a, Bucknalls Drive These 3 modern detached chalet bungalows, located to the rear of the main residential frontage, abut the northern section of the report drive and share the access drive serving Nos 47 & 55 located within the site (See above). These dwellings were approved in Moran Close / Hampstead Close These 2 small residential cul-de-sacs of detached chalet bungalows, located to the rear of the main Bucknalls Drive frontage, about the central section of the report site to the east. Hampstead Close to the south, a private road with a gated access serving 2 dwellings, was approved in Bucknalls Drive Main Frontage This comprises a linear residential road of markedly suburban character. A mix of detached bungalows, chalet bungalows and 2 storey houses of individual design are found with a relatively uniform building line to both sides of the road. REPORT SITE Building Research Establishment(BRE) Located immediately to the south of the report site, this 26ha employment site. It lies within Metropolitan Green Belt, despite the proliferation of built development Bricket Wood Common This has an area of some 78ha and consists of diverse habits including ancient semi-natural woodland, seasonal streams and supports an array of wildlife. The common clearly defines the eastern boundary of the report site. A public footpath runs adjacent to the common site boundary with the report site providing a link with Mount Pleasant Lane to the north. Accessibility The site is well served by public transport services as set out below. 3.

36 Local Bus Services The site is around 0.5km from the bus stops on Mount Pleasant Lane to the north and which provide access to the following services. The above services call at the following railway stations: St Albans Abbey; Park Street: Bricket Wood; Watford Junction. Rail Services Bricket Wood Station is located some 1.3km to the north-west of the site. The Station is on the Abbey Line running between Watford Junction and St Albans Abbey Stations. Watford Junction is also on the West Coast Main Line, which provides connections to London (Euston), Birmingham, Manchester, Liverpool, Glasgow and Edinburgh. Local Services The application site is located in close proximity to a good range of shops and services within 2km of the site, as set out below. 4.

37 Opportunities and Constraints Opportunities - Satisfy 5 year housing supply - Proximity to BRE (employment) - No loss of visual amenity - Potential new area of open space created, adjacent to Bricket Wood Common Constraints - Within a Landscape Development Area - groundwater body underneath the site is already at poor status 5.