Policy SP3: Meeting Housing Needs

Accepting the numbers needed are correct, then the plan satisfies the need for homes. Analysis is needed to ensure the right mix especially considering the balance against age profile of areas

We support the overall level of housing provision for Colchester set out in the Local Plan for the period to 2033 under Policy SP3. The policy provides for some 18,400 dwellings over the plan period 2013-33 i.e. some 920 per annum across the district. We note that this is a minimum figure and we support that approach. Subsequent elements of the Plan should also reflect the fact that the dwelling number provision is a minimum.

We do have some concerns over the timely delivery of such housing numbers and also the constraints associated with specific site allocations including the new Garden Communities. The three large new settlement areas (Garden Communities: Policy SP7) will inevitably raise questions of delivery and timing as all such schemes inevitably take many years to actually deliver housing on the ground.

As a result of such issues, there is merit in increasing the total small housing site provision to provide a wider range and choice of sites which are deliverable in shorter timescales or considering reserve sites to ensure adequate supply or a review mechanism by which additional sites can be brought forward should large schemes be unduly delayed and housing delivery affected.

Whilst it is for the Borough Council to determine the numbers of houses to be provided in the district in the period up to 2033, the University supports the commitment to meeting, in full, objectively assessed need.

The LDP Document covers the administrative area of Colchester with reference to the North Essex authorities to include Tendring District Council and Braintree District Council.

2.2 Currently, within the administrative area, healthcare provision incorporates a total of 21 GP Practices and 9 branch surgeries; 36 pharmacies, 30 dental surgeries, 17 opticians, and 1 Acute Hospital.

2.3 These are the healthcare services available that this LDP must take into account in formulating future strategies.

2.4 Growth, in terms of housing and employment, is proposed across a wide area and would likely have an impact on future Primary Care service provision. Existing GP practices in the area do not have capacity to accommodate significant growth.

2.5 In terms of optimal space requirements to encourage a full range of services to be delivered within the community there is an overall capacity deficit, based on weighted patient list sizes¹, within the 21 main GP Practices providing services in the area.

2.6 NHS England working with the North East Essex CCG (CCG) and the local authority has begun to address capacity issues in the area and as well as a number of proposals in the pipeline, the CCG are currently reviewing future models of care alongside a hub and spoke modelling exercise to determine how primary care at scale can support the local population in the future. We continue to work with GP practices within Colchester on options to significantly increase capacity and the range of services available to the community.

2.7 Optimal space standards are set for planning purposes only. This allows us to review the space we have available and identify the impact development growth will have in terms of capacity and service delivery. Space capacity deficit does not prevent a practice from increasing its list size, however it may impact on the level and type of services the practice is able to deliver.

2.8 NHS England and the CCG are currently working together to help plan and develop new ways of working within our primary care facilities, in line with the Five Year Forward View, to increase capacity in ways other than increasing physical space. The CCG's emerging Five Year Forward View plan will contain further detail on this and the 3 year Primary Care Estates and Technology Transformation Funding programme, which commenced in June 2016, will help to provide funding and solutions for existing capacity issues.

2.9 Existing health infrastructure will require further investment and improvement in order to meet the needs of the planned growth shown in this LDP document. The developments contained within would have an impact on healthcare provision in the area and its implications, if unmitigated, would be unsustainable.

Wivenhoe Town Council support and agree with the statement by Wivenhoe Society below.
'The National Planning Policy Framework aims to promote sustainable growth.
It requires Local Planning Authorities to provide an Objectively Assessed Housing Needs analysis. Unfortunately it gives no guidance on how needs should be assessed - whether these are local needs, regional needs or national needs. The Department of Communities and Local Government provides guidance entitled "Housing and Economic Development Needs Assessment" https://www.local.gov.uk/sites/default/files/documents/objectively-assessed-need-9fb.pdf
The Guidance takes as its starting point trend projections based on ONS statistics. The effect of this is that it is assumed that if there has been a historically high rate of growth in a particular area then the area must continue to grow at a high rate. There is guidance on what adjustments might be made but these are mainly expressed in "uplifts" to trends rather than downward adjustments. The only suggestion for a possible downward adjustment is where there have been effects of large employer moving out of the area or a large housing development such as an urban extension in the last 5 years. Housing market signals are also considered relevant but this is phrased in terms of upward adjustments to trend projections.
The Guidance nowhere makes reference to the other strand in the NPPF that growth should be sustainable. The proposed housing numbers put forward in this policy assume that the trend projections must be fulfilled and take no account of sustainability.
The comments here relate primarily to the dwelling numbers for Colchester Borough but also look at Tendring District.
The Objectively Assessed Housing Need Study (OAHNS November 2016 update) used the methodology in the guidelines but has made no adjustment for the fact that Colchester, principally because of recent availability and deliverability of sites, has grown at above the national and the regional average. DCLG guidance allows for adjustments to be made if there has been a large housing development such as an urban extension in the last 5 years. In the case of Colchester this has not been one single large development but a combination of a number of sites coming forward.
The total proposed for Colchester is 920 dwellings a year. However an additional 1,250 are also being proposed for Tendring in the East Colchester/West Tendring Garden Settlement over the plan period. This site would, in all practical, respects be an extension to Colchester urban settlement which would imply an average build rate of around 1,000 dwellings p.a. for Colchester over the lifecycle of 2 plans.

The 2014-based Household Projections: England, 2014-2039 (July 2016) project a 19% increase in the number of households by 2034 for England as a whole. If this rate of increase were applied to Colchester (assuming one dwelling per household) this would give a build rate per annum of 731 (790 correcting for an occupancy rate of 0.9264) which is considerably lower than 920.

House Prices in Colchester are below the national average. The OAHNS states that for Colchester "price signals provide no evidence of under supply: despite being on the main railway from London Colchester is one of the most affordable areas in the HMA and also in Essex. There is no justification in Colchester for applying a market signals uplift to the demographic projection. The possibility of downward adjustment does not seem to have been considered
There are good reasons for arguing that a downward adjustment should be applied to the trend projections. It is not feasible for an area to continue to grow at a rate well above the national average indefinitely. House prices in Colchester are below the national average and the Borough has now exhausted, or already allocated, its brown field sites so much of the proposed additional housing will have to be on green field sites. There are transport infrastructure issues. There is already considerable road congestion and journey times are highly unpredictable. Some areas of central Colchester have air pollution problems. In Urban Colchester the road network still reflects its Roman and medieval past. Even with unlimited expenditure on road improvements it is difficult to see that some of the problems are soluble. The following is a quote from the NPPF: "Pursuing sustainable development involves seeking positive improvements in the quality of the built, natural and historic environment, as well as in people's quality of life ". One of the bullet points is "improving the conditions in which people live, work, travel and take Leisure".
Various analyses of housing need are presented in the OAHNS and different estimates produced particularly with regards to employment effects and whether this should lead to upward revision in housing need. The authors of the report seem to have adopted a pick and mix policy on which projection they use, picking the higher of the markets adjusted uplift and the future jobs uplift on the grounds that this gives a higher housing need.
For Colchester we would argue that it is appropriate for housing need should be calculated on the 2014 ONS/CLG projections but with a down shift to reflect housing market signals and on the grounds that the projections are based on past trends in a period in which a large number of sites became available for development. Given the mixed findings of the different studies the evidence for a future job uplift is doubtful. The sustainability, in terms of quality of life for existing and future residents of the proposed building rates, should also be factored in as sustainability is one of the key themes of the NPPF.
An omission in the analysis of housing needs for Colchester and to some extent Tendring is that there is no analysis of the impact on housing demand generated by University of Essex and, to some extent, Colchester Institute students.
The proposed housing needs total for Tendring is not well justified in the OAHNS. The situation is complicated by the inconsistencies between census and other measures of population growth (UPC). The assumed rates of net inward migration cannot therefore be based on any firm evidence. House prices are low and have not risen faster than the regional rate despite the very low level of house building in recent years. If there were a strong demand for housing in the area a price rise would have been expected. Unemployment is high in the area. It is difficult to see why a market signals uplift from the best guess 484 dwellings to a total of 550 is suggested. '

The National Planning Policy Framework aims to promote sustainable growth.
It requires Local Planning Authorities to provide an Objectively Assessed Housing Needs analysis. Unfortunately it gives no guidance on how needs should be assessed - whether these are local needs, regional needs or national needs. The Department of Communities and Local Government provides guidance entitled "Housing and Economic Development Needs Assessment" https://www.local.gov.uk/sites/default/files/documents/objectively-assessed-need-9fb.pdf. The guidance is what it says "guidance" so does not have statutory force.
The Guidance takes as its starting point trend projections based on ONS statistics. The effect of this is that it is assumed that if there has been an historically high rate of growth in a particular area then the area must continue to grow at a high rate. There is guidance on what adjustments might be made but these are mainly expressed in "uplifts" to trends rather than downward adjustments. The only suggestion for a possible downward adjustment is where there have been effects of large employer moving out of the area or a large housing development such as an urban extension in the last 5 years. Housing market signals are also considered relevant but this is phrased in terms of upward adjustments to trend projections.
The Guidance nowhere makes reference to the other strand in the NPPF that growth should be sustainable. The proposed housing numbers put forward in this policy assume that the trend projections must be fulfilled and take no account of sustainability.
The comments here relate primarily to the dwelling numbers for Colchester Borough but also look at Tendring District.
The Objectively Assessed Housing Need Study ( OAHNS November 2016 update) used the methodology in the guidelines but has made no adjustment for the fact that Colchester, principally because of recent availability and deliverability of sites, has grown at above the national and the regional average. DCLG guidance allows for adjustments to be made if there has been a large housing development such as an urban extension in the last 5 years. In the case of Colchester this has not been one single large development but a combination of a number of sites coming forward.
The total proposed for Colchester is 920 dwellings a year. However an additional 1,250 are also being proposed for Tendring in the East Colchester/West Tendring Garden Settlement over the plan period. This site would, in all practical, respects be an extension to Colchester urban settlement which would imply an average build rate of around 1,000 dwellings p.a. for Colchester.

The 2014-based Household Projections: England, 2014-2039 (July 2016) project a 19% increase in the number of households by 2034 for England as a whole. If this rate of increase were applied to Colchester (assuming one dwelling per household) this would give a build rate per annum of 731 (790 correcting for a occupancy rate of 0.9264) which is considerably lower than 920.

House Prices in Colchester are below the national average. The OAHNS states that for Colchester "price signals provide no evidence of under supply: despite being on the main railway from London Colchester is one of the most affordable areas in the HMA and also in Essex. There is no justification in Colchester for applying a market signals uplift to the demographic projection." The possibility of downward adjustment does not seem to have been considered
There are good reasons for arguing that a downward adjustment should be applied to the trend projections. It is not feasible for an area to continue to grow at a rate well above the national average indefinitely. Between 2001 and 2016 the number of households in in Colchester grew by 20.3% compared to 13.2% for England and 12.1% for Essex (DCLG/ONS household projection data). The Borough has now exhausted, or already allocated, its brown field sites so much of the proposed additional housing will have to be on green field sites. There are transport infrastructure issues. There is already considerable road congestion and journey times are highly unpredictable. Some areas of central Colchester have air pollution problems. In Urban Colchester the road network still reflects its Roman and medieval past. Even with unlimited expenditure on road improvements it is difficult to see that some of the problems are soluble. The following is a quote from the NPPF: "Pursuing sustainable development involves seeking positive improvements in the quality of the built, natural and historic environment, as well as in people's quality of life " . One of the bullet points is "improving the conditions in which people live, work, travel and take Leisure".
Various analyses of housing need are presented in the OAHNS and different estimates produced particularly with regards to employment effects and whether this should lead to upward revision in housing need. The authors of the report seem to have adopted a pick and mix policy on which projection they use, picking the higher of the markets adjusted uplift and the future jobs uplift on the grounds that this gives a higher housing need.
For Colchester we would argue that it is appropriate for housing need should be calculated on the 2014 ONS/CLG projections but with a down shift to reflect housing market signals and on the grounds that the projections are based on past trends in a period in which a large number of sites became available for development. Given the mixed findings of the different studies the evidence for a future job uplift is doubtful. The sustainability, in terms of quality of life for existing and future residents of the proposed building rates, should also be factored in as sustainability is one of the key themes of the NPPF.
An omission in the analysis of housing needs for Colchester and to some extent Tendring is that there is no analysis of the impact on housing demand generated by University of Essex and, to some extent, Colchester Institute students.
The proposed housing needs total for Tendring is not well justified in the OAHNS. The situation is complicated by the inconsistencies between census and other measures of population growth (UPC). The assumed rates of net inward migration cannot therefore be based on any firm evidence. House prices are low and have not risen faster than the regional rate despite the very low level of house building in recent years. If there were a strong demand for housing in the area a price rise would have been expected. Unemployment is high in the area. It is difficult to see why a market signals uplift from the best guess 484 dwellings to a total of 550 is proposed.

We set out in detail in appendix 5 (page 40 http://www.cause4livingessex.com/wp-content/uploads/2017/07/CAUSE-2017-Part-1-Consultation-response.pdf) why the OAN is too high.

If the unjustified uplifts to the demographic forecasts are dropped then the need for two out of
the three garden communities is removed.

Support is extended for the overall objectively assessed housing need figure for Colchester Borough (920 homes per annum, and a total minimum housing supply of 18,400 in the plan period 2013 - 2033) set out in Policy SP3. This is consistent with Colchester Borough Council's (CBC) latest evidence base. However, we object to the trajectory for the reasons set out below.

It is noteworthy that the second paragraph in Policy SP3 expects each local authority to maintain a sufficient supply of deliverable sites to provide for at least five years' worth of housing, consistent with paragraph 47 of the NPPF. However, there is considerable objection and some doubt in respect of some of the housing allocations in the emerging Plan and the degree to which these will meet the five-year housing land supply requirements of the Borough. In this regard the Plan should be revised to include more sites capable of being developed in the early years, to ensure a degree of flexibility. eg. Land North of London Road, Stanway and Land at East Marks Tey are well placed to assist in meeting the objectively assessed need for housing in Colchester, including within the first five years of the Plan.

I accept the need for new housing in the Borough in line with the Objective Assessed Housing Need Study. Because much of the brownfield land has already been developed or allocated, I also support in principle that a major share of the new housing should be provided in a new sustainable Garden Community in East Colchester. Again, I agree with the principle of future major housing need being met by well planned sustainable communities as described in sections 6,7 and 8, however I disagree with the inclusion of the new Garden Community being proposed on the Colchester/Braintree Borders on the grounds that it is premature.

Support is extended for the overall objectively assessed housing need figure for Colchester Borough (920 homes per annum, and a total minimum housing supply of 18,400 in the plan period 2013 - 2033) set out in Policy SP3. This is consistent with Colchester Borough Council's (CBC) latest evidence base. However, we object to the housing trajectory.

It is noteworthy that the second paragraph in Policy SP3 expects each local authority to maintain a sufficient supply of deliverable sites to provide for at least five years' worth of housing, consistent with paragraph 47 of the NPPF. However, there is considerable objection and some doubt in respect of some of the housing allocations in the emerging Plan and the degree to which these will meet the five-year housing land supply requirements of the Borough.

The stated aim of SP3 is '...to achieve a better balance between the location of jobs and housing, which will reduce the need to travel'. However, housing provision on the scale proposed assumes and therefore is likely to encourage further substantial inward migration from London and elsewhere in the UK. It will therefore provide homes for the London labour market, helped by improved communications. It would not support local employment growth but will generate increased commuter travel.

The Plan is founded on housing growth proposals based on a SHMA which would add new housing equivalent to the current size of the town of Braintree over the next 25 years. This is an extremely substantial increase which will require very careful management at every stage if sustainability is to be realised.

We question whether the housing proposals in the north Essex Local Plans would help meet the greatest part of the OAN - ie the needs of newly forming households - over the Plan period. Also, the level of provision of housing land is so far in excess of past or likely future effective demand for housing as to compromise the renewal of services and infrastructure in existing communities. Far from meeting the needs of newly forming households, it is likely to undermine their housing prospects because of the geographic concentration of provision - not to mention the likely cost of starter homes.

None of the documents assessing housing needs and demographic trends address the potential needs and demand post 2037 (Strategic Housing Market Assessment Update 2015, the Objectively Assessed Need Report (2015) and Demographic Forecasts 2013-2037, (May 2015)). Indeed, all appear to predate the emergence of the Preferred Options Consultation in July 2016.

Finally, on OAN I note and concur with the conclusions of CAUSE at Appendix 5 to their representations, regarding the justification for the numbers included within the Plan for Colchester, and the extent to which they are based on over optimistic forecasts of employment growth, for which there is no obvious justification or evidence. Indeed, the evidence is that much of the employment land released in recent years, particularly to the south of Colchester, has ended up as retail or leisure. The rate of take up at the Colchester Business Park (the only employment area of this type in the Borough), has taken many years to come forward, suggesting the demand for commercial space in the town is slow.

Even if the OAN numbers can be justified, the Plan has also failed to respond to emerging opportunities for other sites that may come forward within the Plan period, eg. Defence Estates land at Middlewick Ranges, that could reduce the numbers required from the NGCs before 2033.

MTPC does not seek to dispute the overall housing need figures but notes that the Garden Communities will clearly not be able to make any contribution to delivery until the latter part of the local plan period. As noted elsewhere, on the basis of the lack of clear evidence, the deliverability of these numbers is questioned.

Colchester's target of 920 dwellings per annum is not justified by the evidence and not sustainable. It should be reduced to about 831 dpa in line with demographic projections from the DCLG, Planning Practice Guidance and historic delivery over the last 10 years.

The difference arises from confusion over whether jobs need houses - they might do in a gold rush town which is sucking in labour, but Colchester is a net exporter of labour.

I support CAUSE's response which provides more detail.

Policy SP3 (Meeting Housing needs) (p21) sets out the housing requirement for each of the three Councils in the HMA which would deliver a total of 43,720 new homes. Persimmon share the House Builders Federations (HBF) concerns that the total homes planned do not;
* Adequately consider increased in migration from London
* Adequately consider the need for authorities outside of London to assist in meeting the Capital's anticipated shortfall under the Duty to Co‐operate.
* Effectively assess key market signals in relation to Braintree and Colchester




Greater London Authorities and London Migration

Persimmon Homes representation of September 2016 on the Preferred Options Local Plan stated that 'The Local Plan makes no reference to the London HMA and the forecasted shortfalls in housing delivery in the Greater London Authorities (GLA) and how this will impact on the wider South East'. This concern does not appear to be rectified within the Reg 19 Draft Plan.

The Further Alterations to the London Plan (FALP), adopted on 10 March 2015, recognise that London's land supply falls short of its projected housing need. For related authorities, which include our HMA, this means that additional new homes will be required to help accommodate this cross‐boundary unmet need.

London might not be able to meet its own housing needs as recognised by the Inspector considering Further Alterations to the London Plan (FALP). The Inspector was satisfied with the evidence base and methodology used by the GLA in identifying a need for around 49,000 dpa over 20 years, and up to 62,000 dpa in the initial years of the plan in order to address historical failure to meet targets. However, the Inspector noted that the draft further alterations only allocated targets totalling 42,389 dpa to the individual London Boroughs. The Inspector expressed doubts that the resulting shortfall could be met by relying on co‐operation between Boroughs or by increasing housing densities. The inspector said that "it is not easy to see where London Boroughs would find additional sources of supply" and warned that, in finding solutions to meeting the pressing need for housing, "care must be taken not to damage [London's] environment such that it becomes an unpleasant place to visit, live and work". The Inspector recommended that the alterations be adopted despite his reservations, noting that non adoption would "result in the retention of the existing housing targets" of 32,210 dpa, which he said were "woefully short of what is needed". The Inspector recommended that the mayor of London may need to explore the possibility of "engaging local authorities beyond the GLA's boundaries in discussions" to ensure that the capital's housing needs could be met.

The FALP does not seek to deliver the full objectively assessed housing needs as set out in the Strategic Housing Market Assessment as required by the National Planning Policy Framework (NPPF). It also requires a step change in housing delivery if London Boroughs' are to meet their new minimum housing targets. This will put pressure on areas outside London to help accommodate the shortfall in the capital's forecast housing need. Local Authorities in the wider south east need to both individually and jointly consider providing for unmet need in London through their Local Plan preparation.

As highlighted by the HBF in the representations to the Regulation 19 Draft Local Plan (Aug 2017), the emerging Local Plans in London appear to fall short of delivering the London Plan minimum figure (42,000) which itself is below the lowest OAHN projection of 49,000.

Colchester has not effectively considered the wider impacts of London, the capital's ability to meet OAHN and the predicated outward migration to the surrounding parts of the South East. It



has to bear in mind that those Local Authorities immediately adjoining London have extensive areas outside of main settlements covered by the Metropolitan Green Belt and as such may be constrained in their ability to meet their Objectively Assessed Needs which will include assisting in addressing the capital's shortfall. Under the Duty to Cooperate, neighbouring authorities who are constrained by Green Belt can seek to accommodate a shortfall in their ability to meet housing needs by way of a neighbouring authority. Braintree is not constrained by Green Belt and has good transport links to London, which is highlighted in the Local Plan, so is well placed to assist in meeting housing demand.

The evidence suggests that;
‐ The SHMA should factor in the impact of increased migration from London on the HMA. The uplift as detailed at Table 4.1, para 4.10 of the OAHNS Update (2016) should be made.
‐ Under the Duty to Co‐operate, the HMA should assist in meeting the Capital's shortfall.

Key market signals

The HBF representations to the Draft Reg 19 Local Plan (August 2017) refer to the 2016 OAHNS market signals and the recommendations for an uplift. We support the HBF views that a higher uplift should be made in Braintree and minimum 10% uplift applied in Colchester due to the market signals and clear evidence on affordability.

Policy SP3 and conclusions on OAHN

Persimmon Homes agree with the HBF's analysis (Aug 2017) that based on both increased migration from London and concerns regarding affordability, OAHN are higher and should increase. The respective Local Plans should be advanced on meeting the minimum targets set out in the HBF's representations (Aug 2017).

We note and welcome Policy SP3 commitment for each authority to maintain a five year housing land supply. This is especially important given the significant uncertainties and technical challenges that remain regarding the delivery of the three garden communities and the undesirable socio‐economic implications if delivery is delayed.

'Each authority will maintain a sufficient supply of deliverable sites to provide for at least five years' worth of housing and will work proactively with applicants to bring forward sites that accord with the overall spatial strategy and relevant policies in the plan'.

The extract from draft Policy SP3 above does not mention that this should be judged against the housing requirement within the Local Plan or that there needs to be an appropriate buffer (i.e. 5% or 20%). The wording of SP3 should reflects para 47 of the NPPF and as such should be amended to read;



'Each authority will maintain a sufficient supply of deliverable sites sufficient to provide for at least five years' worth of housing against their housing requirements with an additional buffer and will work proactively with applicants to bring forward sites that accord with the overall spatial strategy and relevant policies in the plan'.

Notwithstanding this, it is not clear from Policy SP3 as to what actions the Council will take in the event of a persistent under delivery against housing requirements within the plan. As detailed above, the garden community is very ambitious and there remains significant risk that the timescales for delivery will slip. In the event of persistent under delivery, the Local Plan should set out what actions they shall take. Actions could include a partial review of the plan and allocation of additional housing sites.

Officer NB: Please see summary for appropriate summary for each rep. The full representations submitted are attached to all representations on JDi (The consultation portal).

The attached representations are submitted on behalf of Andrew Mattin, in relation to his land at Livelands, Marks Tey.
The following documents have been submitted:

Representations on the Publication Local Plan Statement, and this has also been split into the relevant response forms for ease of reference:
o Response Form General
o Response Form SG1
o Response Form SG2
o Response Form SG8, SS11 and the Sustainability Appraisal
o Response form SP2
o Response Form SP3
o Response Form SP7 and SP9
o Response Form Vision
o Sustainability Appraisal Comment Form
 Copy of correspondence to CBC regarding the SHLAA (dated 14th September 2016)
 Additional evidence relating to the site access:
o Road Safety Audit Stage 1
o Request for Road Safety Audit
o Designer Response by Create Consulting Engineers Ltd
o Site Access Arrangements Existing
o Site Access Arrangements Proposed
o Correspondence with Essex County Council
If you require any further clarification on the above please let me know. I would be grateful if you
could confirm receipt.

Policy SP3 is not sound as it is unjustified

Policy SP3 sets out the housing requirement for each of the Councils in the HMA which would deliver a total of 43,720 new homes. Whilst we would agree with the use of the 2014 Sub National Population Projections (SNPP) as a robust demographic starting point we are concerned that this level of delivery underestimates housing needs. In particular we are concerned that this figure does not:
* Adequately consider increased in migration from London (reflecting the London Plan's migration assumptions that underpin its own assessment of need)



* Effectively assess key market signals in relation to Braintree and Colchester
* Use ONS data as the starting point for Tendring's Objectively Assessed Housing Need (OAHN).
London migration

It is essential that Council's across the East and South East of England consider the impact of expected changes in migration between the three authorities and London. The Mayor of London's alternative 'Central Variant' migration assumptions in his SHMA of 2013 sets out the expectation that more people will move out of London, and fewer will move in from the rest of England than had been projected by the DCLG in its 2011- interim household projections. The Mayor is expecting that there will be 12,000 fewer households a year in London compared to the official DCLG projections at the time of examination. In this respect, we are pleased to see that Section 4 of the 2016 update to Objectively Assessed Housing Need Study (OAHNS) considers the impact of increased migration from London on the HMA. The potential impact is assessed by comparing the GLA's central scenario against the 2012 Sub National Population Projections and this analysis indicates that across the HMA there is likely to be a small increase in housing needs based on current GLA demographic models.

However, we do not agree with the final assessment that due to the annualised impact being relatively small it should not be considered. 64 homes per year over the plan period equates to 1,280 homes. This is a significant amount of housing need and should not be ignored. We would therefore suggest that even a minor uplift as indicated at paragraph 4.10 of the 2016 OAHNS should be considered. The changes in migration patterns between capital and the HMA also reflect the difficulties that London Boroughs are having in meeting their housing needs and concerns that the amount of unmet need arising from the capital in future will increase. As part of the evidence supporting the Further Amendments to the London Plan the GLA indicated a land supply to realistically deliver 42,000 dwellings per annum against an needs assessment of between 49,000 and 62,000 per annum depending on whether unmet needs are delivered over the next five or twenty years. Therefore as a minimum there is likely to be an unmet housing need of at least 7,000 dwellings. The table below sets out the delivery expectations of those 17 London Boroughs with an adopted or emerging Local Plan that reflects the housing requirements from the Further Amendments to the London Plan which were adopted in 2013 and clearly illustrates our concerns.

London Borough FALP requirement Delivery Difference
Bromley 641 641 0
Camden 1,120 889 231
Croydon 1,592 1,435 157
Enfield 798 798 0
Hackney 1,599 1,599 0
Hammersmith & Fulham 1,100 1,031 69
Haringey 1,502 1,502 0
Havering 1,170 1,170 0
Hounslow 822 822 0



Lambeth 1,195 1,559 -364
Redbridge 1,252 1,123 129
Richmond Upon Thames 315 315 0
RBKC 733 733 0
Southwark 2,000 2,736 -736
Sutton 427 363 64
Tower Hamlets 3,931 3,931 0
Wandsworth 1,812 1,812 0
Total 22,009 22,459 -450

This table shows there is an undersupply of 450 dpa compared to the housing targets in the London Plan. Although there are still 16 London boroughs who have yet to produce up-to-date plans that adopt the new London Plan housing targets, the evidence at the moment suggests that the London boroughs are struggling to produce local plans that will meet the London Plan minimum figure of 42,000 dpa let alone increase supply to achieve the London (lower end of the range) OAN of 49,000.

The evidence indicates the starting point should be increased, as a minimum, within both Colchester and Braintree based on GLA scenarios. Further consideration may need to be given to uplifting Tendring's starting point in future depending on London's ability to meet its housing needs. Tendring has in the past seen relatively high net in- migration from London. This is shown in the Edge Analytics report Greater Essex Demographic Forecasts 2013-2037 Phase 7 May 2015. Figure 2 of this report shows that Tendring experienced similar levels of net in migration from London to those authorities in Essex that border the Capital.

Market signals

The 2016 OAHNS examines the issue of market signals and recommends an uplift of 20% for Chelmsford, 15% for Braintree and Tendring and no uplift for Colchester. We disagree with some of this assessment and suggest the evidence points towards a higher uplift for Braintree and Colchester given the affordability ratios and rising house prices seen across the area.

With regard to Braintree there are clear affordability issues that are not dissimilar to those found in Chelmsford. Affordability ratios based on work place earnings in Chelmsford are 10.9 compared to 9.7 for Braintree. Despite a steeper fall in house prices during the recession the study shows that values have grown in line with the rest of Essex with Figure 5.17 showing a worsening trend with regard to affordability ratios since 2013. Therefore whilst we would agree that there has been no long term historical under supply of homes in Braintree compared to previous plan targets a high, and worsening, affordability ratio and steeply increasing house prices indicates that a 20% uplift in line with Chelmsford is warranted.

The study sets out that it does not consider there to be sufficient evidence to support an uplift for Colchester. The reasons given are that affordability is "slightly above the national average" with "house prices and rents well below national averages". Whilst



helpful in providing context studies should be careful when considering affordability ratios and house prices against other authorities as well as national and local averages. The affordability of housing is a national concern and the affordability ratio for England reflects this issue. Just because affordability is close to the national position should not be sufficient justification for not applying a market signals uplift. The same applies to local benchmarking. House prices could be lower within one area of an HMA but if incomes are also disproportionately lower there would still be significant affordability concerns that would support an uplift in the OAHN. The issue of using comparisons to assess market signals was considered at the examination into the Mid Sussex District Plan. On page three of his interim conclusions on the Council's housing requirement 2017 the inspector stated:

"The Council places much reliance on the relative position of Mid Sussex vis- à-vis other districts in the HMA and in Sussex. It believes that if house price trends and related signals in Mid Sussex are broadly aligned with those in nearby authorities, which by and large they are, it should not be necessary to make a significant uplift to its OAHN to reflect market signals. The flaw with this is that if each authority simply had regard to similar trends in neighbouring authorities, and each plan were to replicate the OAHN approach of its neighbours, the cycle would be perpetuated and there would be no adequate response to continually worsening affordability."

It is also worth remembering that despite lower than average house prices and rents it would still require someone on lower quartile earnings working in Colchester to borrow
8.7 times their salary to afford a home within this area. We would therefore suggest that based on the affordability ratios a minimum 10% uplift is applied on the basis of market signals. However, it should be noted that the Local Plan Expert Group advised that where affordability ratios were at this level uplifts of 20% should be considered. Therefore, to suggest, as the report does in paragraph 5.101, that there is no strong evidence for a market signal uplift would seem absurd.

Future jobs

We are pleased to see the consideration of jobs growth on the basis of whether there are sufficient homes, once the starting point and market uplifts have been considered, to meet the employment expectations of the area. Only where OAHN based on the demographic starting point and market uplifts indicate this would below the jobs growth expected in the area should an additional uplift be applied. The approach taken in the 2016 OAHNS would appear to be reasonable and given the uncertainties around economic forecasts we are pleased to see that a range of forecasts are considered.

Tendring and UPC

We fundamentally disagree with the decision to reduce the starting point for Tendring on the basis of UPC. In doing so the Council appears to be seeking to base future needs on past housing delivery rather than rely on the Government's published projections. We do not consider such a scenario to be appropriate and we consider Tendring's starting point for their OAHN should be the 2014 SNPP of 675 dwellings per annum. Given that this is a 20 year plan and planning policy requires regular reviews of



this plan it will be possible to consider future iterations arising from ONS demographic projections should this be required. By using the 2014 estimates as a starting point ensures consistency not only with other authorities in the HMA but will also allow for effective strategic reviews in future across all three local planning authorities.

Conclusion on OAHN

Based on both increased migration from London and concerns regarding affordability we would suggest the following OANs for each of the three Councils forming part of the "North Essex" area:
* Braintree - 762 dpa (623 starting point plus 12 units for London migration scenario and a 20% uplift)
* Colchester - 1002 dpa (866 starting point plus 45 units for London migration scenario and a 10% uplift)
* Tendring - 776 dpa (675 plus 15% uplift)

This level of delivery would require the North Essex HMA to deliver 2540 homes per annum, a total of 50,800 new homes between 2013 and 2033.

See attached response forms

Given the similarity of the policy with the previous version, my client repeats the previous concerns raised regarding the overly prescriptive elements contained within this policy. The second bullet point requires all new development to exhibit individual architectural quality within well considered public and private realms. This is a vague statement that taken to extreme could impose an unnecessarily high level of design quality that may not be appropriate to either the scheme or the area. The design requirements of the NPPF are adequately addressed in the first bullet point of this policy. The sixth bullet point requires the enhancement of the public realm through the provision of specified measures. This may not be appropriate or possible in all cases and as such the policy is unnecessarily rigid. The eighth bullet point assumes that all development will provide parking facilities. This may not be the case. For example, some development proposals may involve sites that are already adequately served by parking. The nineth bullet point has been expanded to require all new development to provide an integrated network of multi-functional public open space and green and blue infrastructure that connects with existing green infrastructure where possible. There is no definition of the term blue infrastructure anywhere in the Plan. Furthermore, this requirement may not be appropriate or necessary for all development and as such is an unjustified requirement. As currently drafted the policy is unjustified, inconsistent with national policy and prejudicial to the effectiveness of the plan.

The previous objection to the use of the word 'must' in the first paragraph of this policy is maintained as it is retained in this latest draft. As commented previously, it is important that the wording of this policy takes into account that a developer is rarely the provider of infrastructure. A good example is healthcare provision. A developer can reasonably be required to contribute towards healthcare (in the absence of CIL) but cannot be responsible for delivering the healthcare facility. The delivery of the facility relies on the actions of NHS England not the developer. As currently worded the policy is not consistent with national policy.

It is noted that the table continues to leave the annual requirement as a fixed figure rather than a minimum target which would be consistent with the stated minimum supply across the plan period. The previous request to refer to the annual supply as a minimum target is therefore repeated. It is also noted that the Plan has not been altered to explain how the need arising from London has been addressed. The previous request to address this is also repeated. It is considered that these issues raise doubts about the extent to which the plan is positively prepared and will be effective.

It is noted that the table continues to leave the annual requirement as a fixed figure rather than a minimum target. A minimum target would be consistent with the stated minimum supply across the plan period. The annual supply figure should therefore be expressed as a minimum target.
It is also noted that the Plan has not been altered to explain how the need arising from London has been addressed. The previous request to address this is repeated.
It is considered that these issues raise doubts about the extent to which the plan is positively prepared and will be effective.

see attached statement

The Trust notes the proposed growth in housing within the plan and would like to draw the Council's attention to the implications for local hospital services which are likely to arise from this.

The Infrastructure Delivery Plan (IDP) outlines the development of up to 10,935 dwellings during the period of the plan, with associated population growth of 24,494. The Trust notes that several other figures for dwellings and growth are quoted throughout the plan but all are broadly in this range. There are several observations which the Trust would like to raise in relation to these figures:
* These figures are significantly lower than the Objectively Assessed Need (OAN) for the Borough during this period, which is stated as 18,400 dwellings. This represents a shortfall of at least 40.5%. The Councils' planned development may therefore be an underestimate of the growth over the period.
* The IDP estimate of population per dwelling seems low (2.24) compared with historical occupancy in the borough (2.34 to 2.37 per dwelling) . This would tend to underestimate population growth as stated in the IDP.
* Historical population growth in the area is higher than the growth predicted in the IDP. Between 2014 and 2015 the population increased by 1.95% (3,519 persons) compared to the IDP projection of an annual growth rate of 0.96%to 2024 (6.9% over period). This would tend to underestimate population growth as stated in the IDP.
* Mid-year 2014 ONS projections for growth in the period of the plan are 14.6% compared to 12.6% in the IDP .
* Student population growth is estimated to be approximately 10,000 by 2021 but it is not clear that this figure is included in the overall figures.
Overall, the IDP appears to be based on a low estimate of population growth during the period of the plan.

The IDP recognises some potential impacts on health services in section 4. However, it significantly underestimates the impact of population growth on these services. In particular:
* The Sustainability and Transformation Partnership (STP) plan, referenced in the IDP, assumes that growth in activity will be consumed within existing revenue resources. The IDP notes the need to "increase estate, or invest in buildings and infrastructure" in primary care and that "hospitals will need to be redesigned to treat the patients of the future" . However, this does not take into account the capital investment requirements in the footprint of the Borough, the revenue consequences of this and the service infrastructure impact of such changes.
* The STP plan only covers the period to 2021. Extrapolation of this revenue-neutral position cannot be assumed beyond this.
* The Trust has considered three scenarios, based on different estimates of growth (IDP estimate, ONS estimate and historical growth rate). The impact on hospital services are set out below. Note that these do not include primary care, ambulance or social care impact.

Scenario % population growth 2017-2033 Hospital infrastructure cost Hospital revenue cost
IDP growth estimate 12.26% £11.8m £18.3m
ONS growth estimate 14.60% £13.6m £21.2m
Historical growth projected forward 33.60% £31.4m £48.7m

Cost per 1% growth 1% £1.02m £1.58m
All figures are at 2017/18 costs and exclude infrastructure costs associated with travel, water and sewerage etc.
* No provision is made for these cost pressures beyond 2021.

The IDP reflects only the growth of the Colchester population. The catchment population of the hospital extends into several other District and Borough Councils, including Tendring, Braintree, Maldon and Chelmsford. Estimated growth in these populations from local plans (at East of England mid-point occupancy of 2.33 per dwelling) is an additional 77,973 persons. This is not accounted for in the figures shown above but will have a direct impact on hospital services for Colchester.

Key responses to the consultation
1. The IDP estimates of population growth appear to be at variance with other sources, including the OAN, ONS projections and recent historic data. Further, other sources of population growth, particularly the student population do not appear to be fully accounted for. The Trust has reservations about the accuracy of the estimates which appear to underestimate the need for housing in the period of the plan.
2. The Trust has provided estimates of the capital and revenue impact of estimated population growth on hospital costs. These cost pressures are not accounted for by the STP plan beyond 2021. For each 1% population growth the hospital will experience approximate capital costs of £1.02m and revenue costs of £1.58m. No provision for these cost pressures is made at this time.
3. The infrastructure transformation required by the hospital is likely to have an impact on Council infrastructure including transport (road and bus particularly), water and sewerage. These are not accounted for in the IDP.
4. The impact of growth in surrounding areas (outside Colchester Borough) which form the catchment population of the hospital is not accounted for. This is in the region of an additional 78,000 persons over the duration of the plan.

The Trust is grateful for the opportunity to respond to the consultation and would be happy to engage in further dialogue.

see attached

Formal Response to: Colchester Publication Draft Local Plan (Regulation 19)
I am writing on behalf of Basildon Borough Council in respect of the Colchester Publication Local Plan Regulation 19 Consultation. The matters set out in this letter represent Basildon Borough Council's consultation response as agreed at the meeting of the Infrastructure, Growth and Development Committee on the 19th July 2017.

SECTION 1
In relation to Section 1 of the Colchester Publication Local Plan, Basildon Borough Council wishes to offer support to Colchester Borough and its neighbouring authorities in pursuing the strategic approach to growth involving the extension of existing settlements in accordance with the settlement hierarchy, and in delivering three new garden communities in North Essex over the period to 2033 and beyond. However, Colchester Borough Council is advised that unmet need for housing may arise from the South Essex Housing Market Area (HMA). The Objectively Assessed Housing Need (OAHN) in South Essex is for between 3,750 and 4,000 homes per annum. This equates to 80,000 homes over a 20 year period. There is currently a concern that there may be insufficient capacity to deliver this quantum of housing in the South Essex HMA, although at this time the full scale of any unmet need has not been quantified. However, as work in South Essex is progressed, any gap between the OAHN and potential supply will become clear, and the need may arise for the South Essex authorities to make a request of other authorities in different HMAs within Essex to assist in meeting that unmet need. Basildon Borough Council does not wish to delay the north Essex authorities in progressing their plans to take into account these concerns. However, it is noted that Section 1 of the Colchester Publication Local Plan does not include a mechanism for its review in light of any such requests. In order for Colchester to be able to consider such requests it is considered that a review mechanism should be introduced within Section 1. Basildon Borough Council would be satisfied that this concern could be overcome by a modification to the Publication Local Plan to this effect, but would wish to attend the Examination in Public in relation to this matter to ensure that it is adequately addressed, and is sufficiently robust.

Colchester Borough Council is advised that this same representation has been made in respect of Section 1 of the Braintree Publication Local Plan and the Tendring Publication Local Plan.

ONGOING ENGAGEMENT
Basildon Borough Council recognises that the concerns it has raised in respect of both Section 1 and Section 2 of the Colchester Publication Local Plan required ongoing engagement to be appropriately resolved. As stated earlier in this letter, Basildon Borough Council is prepared to work withColchester Borough Council and the other authorities in north Essex to identify solutions to these objections prior to these plans being progressed to submission.
If you wish to engage with Basildon Borough Council on these matters please contact Amanda Parrott (email: Amanda.parrott@basildon.gov.uk) or Matthew Winslow (matthew.winslow@basildon.gov.uk) to make arrangements.