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SHLAA

SHLAAIt's an awful acronym. Not a beverage (that's Shloer), not even the way to Amarillo, (that's 'sha la la la la la la') this one stands for 'Strategic Housing Land Availability Assessment'. (SHLAA - pronounced 'shlar')

It's part of the awful 'change for change's sake' plan devised by the Government to introduce a loose-leaf planning system throughout the country.

In this loony loose-leaf system, every council has to produce a 'Core Strategy' which contains the essence of its planning.

This is then supplemented by various sub-documents both at the start, and as and when the need arises. These may be based on a geographic area, or a topic such as conservation, or whatever. (Our take on this is that it will make it easier to change the plans - or part of them - as you feel like it, instead of having something more fixed and permanent which is what a plan ought to be)

Part of the Core Strategy will be about where housing should be provided, and this decision must be informed (according to Government) by an assessment of what land is available for housing in each Council area.

It practice, it's a bit more complicated, but that's the essence.

So how do you go about working out what land is 'available'?

Well in modern local government, you follow the 'guidance' the Government kindly provides for you.

'Guidance' such as this (and also on more or less everything else) is part of the process that is emasculating decisions by local people, turning our town halls into the administrative arm of Central Government.

And on this particular issue, Government says we have to have a Strategic Housing Land Availability Assessment (shortened to SHLAA).

Initially, Fylde appointed a posh consultancy called 'Halletech' to undertake this work for them. But last year, they decided to fire the consultants.

We don't know exactly what went wrong, and despite some folk asking, the details have not been released. The official answer is that it was "because of the quality of he work and the work and the length of time being taken to produce it" Less officially, the officer in charge told the Committee recently "they were not producing what officers wanted, and certainly not in the timescale"

We understand Halletech are now suing the Council.

The job of doing this work has been taken back 'in house' which means it is being done directly by staff of the Council.

A Steering Group of the great and good was established in the early days.

We understand this contained several local developers (Many people thought it was unusual to have developers involved, but again it is the 'advice' from Government that they should play their part). The group also had some of the more established civic and planning groups like the Campaign to Protect Rural England (CPRE).

We would have expected such a group to be steering the officer's work, (especially with developers on board) but it only met once or twice.

We know some group members who complained it was not doing anything like 'Steering'

More recently, after a long period of not meeting at all, the Steering Group was told it would have an opportunity to comment on the final draft of the SHLAA.

Again we wouldn't have described that as the role of a Steering Group, that's more how Fylde does 'consultation'.

Very recently however, they have been reconvened again and, in an attempt to take the wind from the sails of those who would protest at where the SHLAA is going, another (separate) group called 'Stakeholders' has been selected by officers. From what we can see, these are mostly the protest / pressure groups who oppose development on various sites around the Fylde.

These are not the sort of folk to sit quietly in the background. They make the Steering Group seem quite placid by comparison.

The overall purpose of the present stage of the SHLAA is to identify sites with potential for housing; to work out how many houses each site will hold; and to work out the timeframe when they are likely to be developed.

And the point of all this is to enable every Council to show that it has at least a five year supply of land available for housing, (to fulfil the ridiculous government targets that bear no relationship to real local housing need, but are theoretical target levels based on an apportionment of national population projections, and more especially, an apportionment of predicted immigration numbers ).

So we have a Kamikaze concept, operating under Fred Karno rules of engagement, working in Heath Robinson fashion to plan our future development.

We ought not to expect too much from this system.

Even more confusingly, the Conservatives have suggested that if they get into office at the next election, they will scrap all the regional planning system and return power to local people for planning decisions.

That's a good thing in many ways. But it illustrates how wasteful the process can be.

For example, because our Commissar got his accounts into such a mess and walked headlong into a financial black hole, Fylde had just borrowed £405,000 to be spent "developing the Core Strategy" and "investment in the council's assets and infrastructure". That loan is going to take 25 years to pay off, and it's quite possible that next year or two the Conservatives could scrap the whole planning system devised by Labour.

But at present, Army style, we're following the last instruction from Government to undertake the SHLAA.

So when the Officers reported progress to, and sought direction from, the Planning Policy Scrutiny Committee chaired by Cllr Kevin Eastham recently, we went along to listen.

This was probably one of the more important meetings Fylde has held in recent times, but there was almost no-one else in the public gallery except the Commissar and the Chief Executive, and not even all the Committee had been able to turn up.

The Chairman opened the meeting by saying there was good news and less good news.

The good news was that Fylde was now getting some of the 'Planning Delivery Grants' it needed to pay for the work to be done (ie it had now stopped pouring all its money into financial black holes), but the less good news was that having to do all this SHLAA stuff transparently (as required by Government) was bringing lots of planning information into the public domain that would not normally see the light of day; and their having to identify every site with potential for housing would make people feel very unsettled and threatened (because plans now exist that appear to show great swathes of housing behind where people think they have a permanent view over green fields and so on).

It was evident to us there was great nervousness at allowing some of these plans to be seen. They were referred to in the report (which also said they were on display), but they were not displayed, and we had to go through a bit of a process to have them made publicly available - which they now are. (See later).

The officer began a very professional presentation by saying the SHLAA was probably the most important piece of evidence that would inform the Core Strategy, and they need to look at all the options before they decide on particular sites for development.

He made a great play of saying this was a technical exercise to identify, assess capacity, and assess availability - adding that it wasn't a plan, nor was it a mechanism of allocating sites in the strategy, it was simply a scoping exercise to see which sites *might* be considered suitable.

He said "The identification of a site in the SHLAA as being suitable and achievable does not mean it would get planning permission and, conversely, that fact that a site is not in the SHLAA won't mean it is necessarily refused".

The reason for all this soothing talk is that he knows - and any seasoned watcher knows - that when these maps become seen, there will be an outcry that FBC could well do without from those potentially affected by them.

He also knows that despite the fact that this is a scoping exercise, once a site gets any sort of provisional designation on a plan in the planning office, in practice it is usually only a matter of time before it gets seen as a site for building - however much it is made clear that this is not the intention when it is first identified.

That's why there has been so much assurance to the contrary provided.

He went on to say the Steering Group had met again (the day before the Planning Policy Meeting), and he now felt confident they could make progress and complete the SHLAA.

He also noted dismissively that some of the 'Stakeholder groups' would never be satisfied, and several of them had disagreed with his proposal not to include existing employment sites within the SHLAA sites.

This last comment needs a bit of explaining.

The Government says 65% of the houses have to go on 'brownfield' (previously developed) land as opposed to 'greenfield' land. Brownfield sites are typically run-down or derelict former industrial sites (although they can include housing areas in need of redevelopment)

To many people, it makes sense to build on derelict industrial sites first, because that protects and preserves farmland, green fields, and wildlife.

But Fylde has a policy of protecting industrial sites for employment, and the officer was arguing persuasively that we should not consider brownfield (former industrial) sites for redevelopment at all, because we want to retain them for employment uses, not housing. (He argued this even though at present, no-one wants to use them for industrial or employment uses).

What this means in practice, as Cllr Trevor Fiddler pointed out, is that if you exclude such sites from the SHLAA altogether by deeming them unsuitable, then inevitably your green spaces come under much more pressure for development because they're the only areas left to build on.

We found it strange that some of the other considerations were not sufficient to exclude sites from the SHLAA list as well.

For example, there are some sites that are protected by European and UK designation for wildlife that it will be almost impossible to build on, but these are not excluded from consideration. There are areas in what is known as Floodzone 3 (that has the highest risk of flooding), again wholly unsuitable for residential use, but these were not suggested for exclusion from consideration. There were others that could have been excluded from consideration because of conflict with Fylde's existing planning policies as well.

We could understand this situation better if every site identified had been included, but it hasn't.

There are already some exceptions. We understand the first 'long list' of potentially developable sites numbered over 200 locations, but already, for reasons like 'poor access' that list has been cut down to 100 or so sites.

The officers explained that Government sets the criteria that they should, and should not, take into account in designating whether sites were included in the SHLAA, and apart from the employment land issue, they were following the Government guidance.

We wondered why, if they could decide not to follow the guidance and go their own way on the employment land, why they couldn't go their own way on other things, but no-one on the Committee thought to ask that.

The officer also said the reconvened Steering Group had been happy to go along with his view of this yesterday, (so that was alright really).

Furthermore, we don't recall hearing any assurances that the money was immediately available. How would Cllr Henshaw know anyway?. The way the Commissar keeps other Councillors in the dark, its amazing they get to hear anything. Several tell us they hear what's going on in Fylde more through these pages on counterbalance than from their agendas.

He said he wanted the Committee do decide whether to exclude employment land from the consideration.

He also wanted them to decide whether there should be independent verification of the list of sites they had drafted, adding that some local 'stakeholder groups' would (presumably in his opinion) never be satisfied. So he asked the committee to decide whether to employ independent consultants to verify what the officers had done. We wouldn't be surprised to find that it is also government guidance to have the SHLAA independently verified, but that this can be overridden at local level.

He did a very good job of killing this idea off by adding that the Steering Group had considered it yesterday and they all thought they could agree with what he was doing, so it wouldn't be necessary to employ consultants. But the Committee could decide to do so if they liked.

Fat chance.

Thirdly he wanted the Committee to decide whether they should consult the public on the sites to be included in the SHLAA.

He said some councils do include a public consultation, but there is a danger in doing this because some people would be upset, so he suggested they don't do a public consultation, but instead, they just write to Parish Councils to seek their views on behalf of the community.

We were less than impressed by the last two suggestions.

It was evident a path was being followed here and he didn't want to be diverted from it by having to consider public comments, or to risk other professionals disagreeing with what the council's officers had said should be included.

So after the meeting we asked for copies of the plans. They were public agenda items and are therefore publicly available - even if the Council doesn't really seem to want anyone to see them.

So they have now been published along with all the other current SHLAA documents on the Councils website and can be downloaded as two large very large PDF files.

With a broadband connection it's not too long a process, but don't try it with an old style dialup connection. It seems to take a long time to get the connection going, so you have to be patient to get the download. If anyone has real trouble in getting them, let counterbalance know and we'll see what we can do to help.

The links below will (for as long as the Council leaves this page available) enable a download of the individual files. To save the file to your hard disk, just right click the link and choose 'save' or 'save as' when the option comes up.

The first set of maps 'SHLAA Maps' is a 35 mb PDF file showing locations within the existing built up areas that might have housing provided on them.

The second is the more controversial. Called 'SHLAA Maps Urban Extensions' this 27 mb PDF file is a set of maps that looks at all the towns and villages in Fylde and identifies potential sites for building new houses that would extend the residential areas into (usually) green field land.

They show for example huge potential for expansion around Whyndyke Farm and Whitehills (all the way down to Bambers Lane), and off Queensway in St Annes, and around Kirkham, Wesham, Clifton, Warton, Newton, Elswick, Staining and other places, but curiously, we couldn't find one showing any possible urban extensions for Wrea Green and are not sure if this is right, or if it is an omission.* See Update at end

So what did the Committee make of this report?

Well, Chairman Kevin Eastham was quick to pitch in saying he wanted to support the officer's recommendation. They had discussed it at the 'briefing meeting' before this committee and it probably didn't need to be discussed by the Cabinet, but could just go to the portfolio holder for a decision.

You can see which way the wind is blowing there then.

Cllr John Bennett (recently 'defected' to the Conservative group - if defected is the right word for someone whose voting record has been remarkably similar anyway) was fundamentally opposed to the idea. He said it should be the Council that decided where they wanted development to take place; they should be pro-active instead of re-acting to what developers wanted.

We figure most people would agree with him, but the officer said no, this was a technical exercise, and councillors would be involved when it is completed. Such is the way Local Government works today.

Cllr Chew from Singleton & Greenhalgh made a valiant attempt to wrest control of the monster from central Government and to stop the officers slavishly following all the Government 'guidance'. She asked why someone from the Committee was not on the Steering Group (which brought the response that nothing was happening to involve councillors yet, "Your stage comes later" he added).

She also asked about whether we should challenge the housing numbers from Government.

Cllr Fiddler jumped in at this point and said he was concerned there had never been any proper debate about the numbers of new housing at Fylde. He said Fordham (the research company who predicted Fylde's 'need') had produced "fatuous figures" and the Council had been "Led by the nose to accept this fictitious figure."

We wanted to cheer at this point.

At last he - and possibly he alone - has seen the light. We hope others will follow his lead.

As we said way back in 2007 in 'Affordable' Housing and repeated in Interim Housing Policy in August 2008 and in CPA Inspection Due in November 2008, Fylde were the recipients of a huge con trick undertaken (we believe) by a former Chief Executive. He sold the idea of using Fordham Research - what Cllr Fiddler likened to a wildly left-wing think tank promoting egalitarianism rather than housing.

We have made this point repeatedly and don't apologise for making it again here because it has still not been corrected. We think this is because the Council is frightened to admit they were conned and they won't come clean over it, so they're slowly backtracking from it. But not fast enough so as to make sense of what they are doing today.

For example, the current SHLAA methodology at 'Stage 4 (p17)' acknowledges that the Government's Regional Spatial Strategy gives Fylde a requirement of 305 housing units a year. Many locals (us included) think this is a ridiculously annual high figure. However, the SHLAA document goes on to say that there is, at the same time, according to Fylde's housing survey, a need for 600 affordable units a year! You could thus never meet the so called 'affordable' need!

Clearly, needing 305 units of all types of housing, and 600 socially subsidised houses in the same paragraph is an absolute nonsense. But that's what it says.

There is actually nowhere near the *need* for 600 'affordable' units (although the desire to avoid paying a market value rent by paying a lower, subsidised rent to a Registered Social Landlord will no doubt create such a 'need' in the minds of those households currently paying the market rent)

Bravo! Cllr Fiddler. Bang the drum of common sense in the faces of your colleagues as loudly and as often as you can.

But as the officer said.... well, we've accepted the figure of 306 houses a year. We negotiated it down from the Government's original target of 333 a year. It went to Cabinet, was agreed, and we wrote to Government Office North West to say we have no problem with it. It is a settled figure.

This shows two things. Firstly, there is, as we have said before, insufficient depth and breadth of knowledge available in a decision making body of only seven (and now only six) people that make up the Politburo Cabinet. If the housing numbers and full details of their preparation had been reported to the experience, wisdom, and capability of a full Council meeting of 51 members, we suspect a different view might have been taken.

Secondly, we guess the officer concerned isn't aware of the challenges being made by Councils in other parts of the country who have used (and are using) judicial reviews (see: East of England) to challenge housing numbers they have been saddled with by Government edict.

Moving on to a different topic, Cllr Ben Aitken brought up the issues of high quality farmland and biodiversity, pointing out that the WAGs group at Wesham had recently shown that the farmland proposed for housing by Metacre was of a higher grade than the Council or the developer had believed.

We suspect Cllr Aitken was heading toward a creditable proposition to exclude high grade farmland and biodiverse sites from the SHLAA, but he didn't get chance to do so because the officers cut off his route by saying that the classification of agricultural land was very expensive to determine accurately, and whilst there were broad descriptions of grades, individual fields may differ and need individual soil analysis to prove or disprove that.

Whilst this may be right at an individual planning application level, we fail to see how such detail is necessary at the SHLAA stage. The SHLAA is about strategic planning to inform the Core Strategy, not about individual planning applications.

It would be akin to the SHLAA requiring a full blown chemical survey on every previously-developed site in case of contamination. It is entirely unnecessary at this broad brush stage. But such is the inexperience of well-meaning councillors that they don't feel able, or sufficiently confident, to challenge such generalisations made by officers.

At this point Cllr Fiddler weighed in again saying he agreed with Cllr Aitken, taking employment land out now would mean the Council would be restricted in its options and forced to turn to greenfield sites outside the settlement boundaries to meet the numbers.

The officer agreed, saying the problem existed because there wasn't enough brownfield land anyway so some greenfield would be used in any case (we know that CPRE have a different view on the brownfield numbers and have figures to show it). But, he said, the Committee could change the policy on employment land at a later date if they wanted to. (And pigs might fly, we thought).

Sensing a pivotal moment, the Chairman weighed in saying he thought they should protect employment land, although there may be a possible compromise on some sites and they could, of course, revisit the decision later on. (There goes another pig).

The argument was settled

Other Councillors tried a rearguard action to effect smaller changes about removing the threat of urban extensions for villages, counting existing empty properties and looking at the number of properties over shops that could be used for housing.

Again the officer was dismissive, saying that work was not part of this exercise.

We think this missed a vital point. The whole of this process is a theoretical nonsense. If the Government wants tickbox accommodation to meet the needs of 300 plus theoretical residents a year, then Fylde should be providing as many as possible as accommodation over shops and in empty properties (even if they are equally theoretical) to meet the imaginary need, instead of building lying down and accepting the rape of Fylde's countryside as inevitable.

That said, the whole of this is about to change anyway.

As we reported in Snippets - June 2009 the probability is that the land around the M55 will be seen as the salvation of all Fylde's green spaces. There is a strongly growing opinion that putting our eggs in the 'M55 Hub' basket will remove the threat to many other green spaces, and that's going to be popular with a Council election due in 2011.

So what did the Committee decide on the SHLAA?

Yep, you guessed right.

1. Exclude employment land
2. No need to independently verify what officers have decided
3. No public consultation

We thought you'd like to know - even if you're not being consulted.

And do have a look at the plans if you have time.

Dated:  5 August 2009

UPDATE: 5 August
A reader who had a copy of the Wrea Green Urban Extension map has kindly sent us a copy. It can be downloaded from this link as a jpg image

UPDATE TWO:  6 August
A little bird told us today that Queen Elizabeth had been wondering about having this decision called-in for review by a scrutiny committee, but couldn't because the recommendations will go to the Portfolio Holder. We hope and trust Cllr Fiddler will do the right thing here.

UPDATE THREE: 6 August
Added a link to the Judicial Review  that is challenging the RSS numbers in the East of England


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