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An Affordable Policy?

An Affordable Policy?Regular readers will know we have almost completely lost confidence in Fylde's emerging Local Plan.

Now we find yet another nail in it's credibility is about to be hammered home.

This is the same Local Plan that we reported being railroaded through a Council meeting in June 2013 (Local Plan: Preferred Options Consultation), when the Conservative Group used its majority to force through a version for consultation that they (and other councillors) knew was plainly wrong.

Whilst it had many issues with which one could disagree, the key issues of contention were the number of houses Fylde is said to need, and the overall area to be allocated for future employment.

These two matters are, of course, closely linked.

If you say there will be a big increase in future jobs, you can argue you need a big increase in the number of houses being built (and as a happy consequence Fylde can expect oodles of 'New Homes Bonus' cash from the Government).

Subsequent information has led us to the belief that for almost entirely political reasons, Fylde's majority party aspires to, and is creating, an delusionary 'growth agenda' to overstate the land needed for future employment. This, in turn, would have us believe there is a need for far more houses than is actually the case.

This supposed need threatens to adversely change the character of Fylde.

Many councillors saw through this delusion when it was presented, and 41% of them voted against adopting it even for consultation purposes.

They went on to publish a 'Minority Report' setting out some of the failures. We reported this in our article 'Minority Report' in August 2013.

In December 2013, in our article "Planning Matters' we reported how the ten main community groups concerned with planning in Fylde had put their name to an open letter.

That letter declared Fylde's Local Plan consultation unsound, and called on the Council "to suspend the current consultation and withdraw the Preferred Options until it is able to support it with its own declared housing requirement together with its related evidence and reasoned justification." They went on to say, "An amended Preferred Options, together with the housing requirement, should only then be re-presented for public consultation."  (Readers can follow this link for the full text of the statement )

Shortly after this, and although the plan had been put out to public consultation, we were told by councillors there had already been three or four 'versions' of the 'Preferred Options' document that quietly issued since June - and from what they believed, these versions were released *after* the one approved by Cllr Fiddler, and endorsed by the Council.

It was further said these versions were supposed only to involve things like typographical errors that had come to light, or where maps had since been incorporated and suchlike.

We're less sure about the changes being so minor, especially having seen what Fylde's officers appeared to have added at Newton - without even the Chairman knowing about it, let alone the Committee. (see The New Committees: Development Management Policy)

But if Cllr Fiddler had approved each of these revised versions for consultation, the technically, that was probably fine. As the (then) Portfolio Holder for Planning he had the authority to do that.

That said, we could find no reference to them being approved by him as 'Individual Member Decisions' (which is what should have happened), and the changes had not been a Cabinet or Council item, so we were puzzled as to whether he knew about them or not, and whether he was aware of all the changes in the different versions. (That also led us to wonder whether the changes had been lawfully made).

We reported this and other matters in 'Local Plan Update' just before the turn of 2013.

But by summer 2014, Cllr Fiddler had, alone, taken one of the most important decisions Fylde could take.

He approved a set of housing numbers for Fylde that expected to see housing growth in the range of 300 to 420 dwellings a year.

We consider this number to be ridiculous.

His approval was despite the fact that no individual development site in Fylde has ever built more than about 50 houses a year.

It is despite the fact that a report prepared jointly by (former) Council Leader David Eaves and himself said the historic rate of actual delivery (over all development sites in Fylde) had averaged only 195 a year over the last 10 years. (see our article 'Incredible Housing Numbers')

It is despite the fact that in the previous Local Plan - when the preposterous survey report commissioned by Fylde's (then) Chief Executive had said that Fylde needed 420 'Affordable Houses' (socially subsidised houses) every year, and the (then) Joint Lancashire Structure Plan said only 155 dwellings a year OF ALL TYPES were needed in Fylde Borough - and Fylde Council itself had said an annual average of only 254 dwellings per year of all types were needed.

Fylde's old, but actually still current, Local Plan (dating from 2005) actually sets this nonsense in black and white when it says at para 3.25 "The annual need for affordable dwellings found by the Survey very substantially exceeds the overall housing provision of 155 dwellings per annum for the borough made in the Joint Lancashire Structure Plan (2005)....."

And at Paragraph 3.26 it goes on to say "The policies of this plan must seek to reconcile this tension..."

Yes, really!

Cllr Fiddler's approval of 300 to 420 dwellings a year is also despite his own stated evidence to the contrary.

In the joint letter to our MP in August 2013 he said "The evidence from previous housing delivery, the current housing market provision, existing approvals and a static population would support a five year housing supply figure for Fylde of 1170. This is based on the average actually delivered for the last 10 years (covering both boom and bust) of 195 new dwellings that has more than met the need in the market evidenced by the current availably of new and existing dwellings. The figure includes the maximum 20% additional buffer and will be reviewed and republished with supporting evidence in September of each year."

So Cllr Fiddler's 'Individual Member Decision' of 300 to 420 dwellings a year stands up for ridicule, because it self-evidently stands no comparison whatsoever with what he believed in 2013, and it bears no sensible relationship to Fylde's historic need, nor to Fylde's demographics - nor even to common sense.

We believe it was driven by nothing more than a party political desire for a growth agenda that could well be based on the desire to attract funding via the Government's 'New Homes Bonus', but which disregards key wishes of local people to protect those green fields from which Fylde takes its name.

His 'Individual Member Decision' was, (unsurprisingly) 'called in' by Fylde's Independent councillors.

It was then 'reconsidered' at one of the worst Scrutiny Committee meetings it has been our misfortune to attend.

We detailed its proceedings in our article 'Not Fit For Purpose'.

Against all logic and common sense, the party dogma of the majority group prevailed at that Scrutiny Meeting (because they had the majority of the committee members), and Cllr Fiddler's Individual Member Decision remained unchanged at 300 to 420 dwellings a year.

Fylde's Independent Councillors and other minority parties were incensed, and subsequently published an unprecedented second 'Minority Report' setting out why his decision was wrong.

We published an article about their second Minority Report  which was due to be considered at a Fylde Council meeting ('Minority 2 at Council'). 

We also recorded that the majority party was seemingly unable (or at least unwilling), to muster arguments to defend the stance their Portfolio Holder had adopted. They simply voted not to spend the time needed to debate the issue.

We said at the time: "We watched Fylde Conservatives being wholly unable to convince other members of the council by the strength of their arguments.

We saw the Conservative hierarchy being so fearful that the future will show them to have been wrong, that they ran away from taking a decision.

To do this the Conservative group employed the last refuge of a scoundrel council - they delivered a 'guillotine' procedural motion which simply stopped the debate in its tracks and moved on to the next item of business without taking a vote on the item before them."

So the disaster that Fylde's local plan had become remained on its course to become 'Fiddler's Folly'.

Then in August 2014, we published the article 'Fylde's Local Plan: Re-Consultation'.  and in which we showed that Fylde had finally accepted that their original public consultation on the local plan was so flawed and inappropriate that they were going to do another consultation.

This announcement completely vindicated the publication of the Independent Group's Minority Report and the Planning Group's 'Statement of Unsound Consultation'.

Since then, Fylde has made fundamental changes to the structure of its Local Plan and to some of the content. It will now be a single plan rather than the two-part document that was envisaged, and it will be reconsulted on again, probably early next year.

But counterbalance, and several others 'in the know' about planning in Fylde, have more or less give up on what Fylde are doing with this Local Plan.

We have no confidence that any of its proposals will change significantly.

We regard the present process as a simple rebranding of the Local Plan to MAKE IT LOOK AS THOUGH THINGS HAVE CHANGED when in reality, it's the same old claptrap based on the same (quite possibly intentional) misconceptions about growth that are being trotted out.

So was no surprise to us when the widely respected Fylde Branch of the Campaign to Protect Rural England (CPRE) withdrew from membership of Fylde's Local Plan Consultative Group because (as we understand it) they didn't want to be associated with Fylde's overly ambitious growth proposals which in turn lead to the development of unwarranted acres of Fylde's greenspace.

Then in July 2015 (during the first of the Development Management Policy meetings under the new 'Committees System' at Fylde), we watched as 'Fiddlers Folly' - (the proposed Local Plan) - descended from chaos to farce, as officers asked the Committee to make any comments and propose changes to the revised draft version of the plan - only for Cllr Fiddler (who chairs the Committee), to say they couldn't make any changes!

Yes, Really! 

See our documentation of this stupidity in the meeting we reported in "The New Committees: Development Mgt. Policy"

What this meeting showed as far as we were concerned, is that 'Fiddlers Folly' is still steamrollering on, and still using its intentionally false assumptions and deluded growth projections that have more to do with Fylde's misguided desire to enchant us with clairvoyant prophesies and visions of the future than to impress us with their actual ability to plan.

But now.....

As we said at the outset, we understand yet another sizeable nail in Fylde's Local Plan credibility is about to be hammered home.

And again, we return to those Housing Numbers which are the cause of so much dissatisfaction.

You'll remember that Cllr Fiddler's 'Individual Member Decision' said he expected Fylde's need for dwellings to be in the range of 300 to 420 dwellings a year.

Well, because he took that decision, that's what you can expect to see in the next consultation version of the Local Plan. His decision gave the officers political direction as to the number they should be aiming for, and on which the public will be consulted.

This figure itself was based on a detailed piece of research done for three local councils called the 'Blackpool Fylde and Wyre Strategic Housing Market Assessment'. (shortened to SHMA and pronounced 'Shmaar').

Although we disagree with this report's conclusions for Fylde (conclusions that we believe FBC has strongly influenced), this document produced impressive research and has solidly reliable information at its foundation. The information it presents isn't wrong, but we believe the conclusions that have been magicked from that information are.

The SHMA research identified that Fylde needs between minus 64 and plus 436 houses a year. (We've no problem with this range - as we have previously explained in our article 'Not Fit For Purpose').

The wide range exists because it depends on which prophecies of the future you want to believe, and the extent to which you believe the need for dwellings in Fylde should meet the needs of the resident population and / or potential inward migrants to Fylde.

So, depending on which of the 220 or so alternative combinations of factors you select as being the most likely conditions that will apply over the next 15 years, the total number of dwellings needed in Fylde will be between -64 and +436 per year.

And it is from this range that Cllr Fiddler selected his preference for 300 to 420 dwellings a year.

(Readers will see that his choice is at the top end of the SHMA's estimate of need)

The same report also says that within this range, the number of 'Affordable' dwellings that are needed ranges from plus 4 to plus 207 dwellings a year.

Now - 'Affordable' houses - are not what most people think they are.

They are not - as the name is deliberately and confusingly intended to imply - inexpensive houses for local newlyweds to buy.

They are socially subsidised houses. They are chiefly rental properties, and are usually provided and operated by Registered Social Landlords such as (in this area) New Fylde Housing (as was), or Progress Housing (as it is now), or any of several other RSL's operating in the area such as the 'Muir Group' and 'Great Places'

Affordable houses can include shared equity schemes and so on, but in practice, the overwhelming proportion turn out to be socially rented property.

This range of 4 to 207 a year is, again, dependent on which of the combination of factors you believe will apply over the next 15 years.

Cllr Fiddler said that in his view of the SHMA conclusions, he sees a need for 207 affordable homes per year in Fylde.

Readers will see straight away that within a range 4 to 207, the 'need' for 207 must based on the more optimistic end of the assumptions made regarding migration, growth and employment.

In common with the chap from Warton who first saw the disastrous flaw in Fylde's ludicrous 'Affordable Housing' calculation, we have long maintained that 'Affordable' housing numbers of this sort are completely off the wall.

They hark back to the days of a former Chief Executive (who seemed to be believe that Fylde was far too socially imbalanced, and it needed to engineer a change in its social structure by aping Blackpool, and importing as many people in need of affordable housing as possible).

He could not understand why Fylde would not want to the area to be more like, say (as one reader who knew him quite closely told us), Skelmersdale.

So he instituted expensive professional research, the specification for which conflated housing need with housing desire. (If you say 'hands up who wants to pay less rent', you'll see a lot of hands). The ramifications of his foolishness are - as we can see - still with us.

Well, the real situation has now burst into the open, and blasted apart the deceit that says we need the maximum Affordable dwellings that the SHMA research could predict.

It comes about because the Registered Social Landlords operating in this area say they now find themselves in a pickle.

When they are building new houses for rent, the lion's share of the cost comes from commercial borrowing. From the banking system.

The repayment of these loans (and future housing maintenance costs) are met from the rents that are paid by the tenants of the additional (new) properties.

But, of course, that process depends on there being enough people to take up the tenancies.

And here's the rub.

It looks a s though there aren't enough people in Fylde Borough who want socially subsidised housing.

Because of this, the banks won't lend to the Registered Social Landlords for the construction of 'Affordable' properties for which they don't believe there are enough tenants.

(On a positive note, it does look as though the banks did actually learn something from the 2008 housing crash after all).

But suddenly Fiddler's Folly of a Local Plan looks increasingly like the overly-optimistic delusional clairvoyance that it really is.

And if he's wrong about the 'Affordable Housing' numbers, then because they derive from the same sort of logic, the chances are that he's equally wrong about the overall housing numbers.

We understand that finding a way out of his predicament has been exercising political minds at Fylde for several weeks.

Having figures that are shown to be the 'wrong' Affordable housing numbers in the Local Plan can't be allowed to happen - because it would bring the whole house of cards cascading down around his ears, along with those of the foolish virgins of the majority party that supported his insane numbers.

So what's being planned is an increase in the number of people who want Fylde's Affordable Housing.

Fylde is planning to 'import' them.

We'll pause at that idea for a moment, partly to let it sink in, and partly because we suspect our sharper readers will already be wondering how it can be that there are not enough people in Fylde looking for socially subsidised housing?

The answer to the second part of that statement is Meerkat Simple.

When Fylde agreed (and in the case of some borough councillors, reluctantly agreed) to merge aspects of its housing service with that of Blackpool and Wyre, they did so only if the new property in Fylde Borough could be let to people who have a provable connection with Fylde.

Fylde houses for Fylde people.

That was the idea.

More explicitly, the logic is that the socially subsidised housing cost that is paid by Fylde's taxpayers should be used to meet the needs of Fylde people. (This 'cost' may be funding via Central or by local Government direct to those in need, or by putting up with unpalatable market value housing developments to fund some additional social housing),

So there are now two slightly different sorts of social housing in Fylde Borough.

Firstly there are the old sort (chiefly the former Fylde Council Houses) which were transferred to the ownership of New Fylde Housing at a substantially discounted price (Typically 11,000 for a property that would have been worth 60,000 to 80,000 on the open sale market)

Then there are the new sort. The 'Affordable Houses' which have been provided because Fylde made a rule that when a developer builds some new (Market Value) property for sale in the Borough, he must provide a proportion of it at a heavily discounted price to a Registered Social Landlord who will (usually) let it to people who are not able to afford market value rents.

It is thus offered at an affordable rent as Affordable Housing. These are the so called 'Section 106' properties (because the power to provide them derives from section 106 of the 'Town and Country Planning Act 1990')

About 300 of the new type 'Affordable' houses have been delivered over the last 6 years.

For most purposes, the terms of comparative tenancies are virtually identical between the old and the new systems, but the old and new systems differ in one key respect.

The 'Old System' former council houses that were bought (albeit at a deeply discounted price) and are now owned by a Registered Social Landlord are first offered to people with a connection to Fylde Borough in each of the various grades of need. But if no-one from Fylde comes forward to take up the tenancy, these properties can be offered to people from Wyre or even Blackpool. This situation prevails because those were the terms of the sale that both Fylde Borough and 'New Fylde Housing' agreed at the time,

But that's not the case for the 'New Style' Section 106 Affordable Houses. In these, you may only become a tenant if you can demonstrate a Local Connection to Fylde Borough.

And this requirement was renewed and approved by Fylde's Cabinet on 25 March 2015 - after detailed consideration by the Policy Development Scrutiny Committee - so it has very recently been reviewed and approved

People from Blackpool or Wyre or elsewhere, may not become tenants of these properties because that's what FBC's policy says.

These Section 106 'Affordable Houses' are Fylde houses for Fylde people.

As one Councillor said "We don't want to be building houses in Fylde for Blackpool and Wyre"

But that principle of 'Fylde Houses for Fylde People' isn't actually as onerous a requirement as it sounds.

The criteria for the new tenancies are:

1). You must have an existing 'local connection', by having already lived in the area for the last 3 years (unless you are a current member of the armed forces or have served in the last 5 years, or are statutorily homeless),


2). You can gain a 'local connection' through having:

  • Permanent employment in the area
  • A close family association have a parent, adult child (over 18), adult brother or sister who is living in the area and has done so for the last 5 years.

and, in addition to the above:

  • Your household income must not exceed 60,000
  • And anyone under 55 must not have savings of more than 30,000.

Certainly these present criteria are wide enough to qualify for affordable housing any migrants from Europe who can show they have already lived in Fylde for 3 years.

And in addition, there is other legislation that allows people from existing socially rented property to move to Fylde in some limited circumstances.

So the requirement to have a 'Local Connection' isn't that hard to meet.

And once you do, it entitles you to socially subsidised Affordable housing if your personal means don't allow you to afford a market rent.

We think that having a connection to Fylde isn't as difficult to establish as you might think.

But even within these (quite generous) categories of local connection, it seems to us there are not enough people wanting affordable homes in Fylde Borough for the banks to feel secure in making loans to build new Affordable Houses.

The officers at Fylde disagree. They say the need for Affordable Housing is still there, but the banking system sees the 'local connection' requirement that Fylde applies as being an 'unacceptable risk' that there won't be enough people to take up the rentals and fund the loan repayments.

Specifically, an officer told last night's Committee "...The main source of income to fund the organisation, particularly the borrowing, is from rental income. Any risk to that rental income, whether it actually happens or not, is a significant issue in a business plan, and a risk to rental income is a significant risk, and the restrictive nature of these Section 106 agreements - whereby property is only ever made available to Fylde Borough residents is a potential risk to a disruption of rental income. So if they can't let a property for any reason because it's restricted Fylde, there's a potential risk - and that potential risk has meant that our provider partners [the Registered Social Landlords that FBC works with]  are becoming more reluctant to accept and take on new developments "

To us, this says that the banking system can see that Fylde's affordable Housing need figures overstate the need that exists in Fylde, and even the Registered Social Landlords themselves can see that there isn't as much need as Fylde's local plan says. It seems that the only ones to perpetuate the delusion are (most of) Fylde's Conservatives.

So what is Fylde doing about it?

Is it going to change the number of Affordable dwellings in its local plan to meet the real-life definitive local need - which is now being set by the banks' lending policies, and the business plans of the Registered Social Landlords- and which is probably closer to the 4 than to the 200?

Not a bit of it.

It's preparing the ground to widen the criteria for social housing in Fylde to accept people in need of social housing even if they have no local connection with Fylde.

In other words, Fylde is about to stop catering for the needs of its electorate and to start importing need from elsewhere - so it can continue to justify the fictitious housing numbers it says are needed for its Local Plan.

This is a policy that has already adversely afflicted Blackpool.

The 2009 Fylde Coast Housing Strategy itself says "The problem for Blackpool is that it is attracting many people who do not make a positive contribution to the town. An example of this is the finding in a 2007 survey of Incapacity Benefit claimants in Blackpool that 25% of claimants first received their Incapacity Benefit somewhere else in the UK, compared with a typical level in other towns of around 10% of IB claimants starting their claims somewhere else."

So removing the requirement for a local connection to Fylde Borough, and importing those in need of affordable housing from a wider catchment area could have all sorts of unintended consequences for Fylde residents, but we understand that's where Fylde's majority party wants to go.

At the meeting last night, most of the independent councillors on the committee spoke against it, and one of the Conservative councillors also spoke against it, but it was proposed by Committee Chairman Ben Aitken, seconded by Cllr Frank Andrews, and voted through by the Conservative majority on the committee.

We find it strange that a policy which could result in something akin to 'reverse gerrymandering' like this should be espoused by a Conservative administration, but the report proposing just that, - the lifting of this 'local connection' requirement was approved for onward transmission to the Development Management Committee by Fylde's Environment Health and Housing Committee last night.

We also find it surprising that Fylde's Conservatives would want to embark on a policy that will, in fact, make it more difficult for local people to get onto the local housing ladder (attracting people with greater housing needs to come to Fylde will depress the availability of subsidised housing for those in - comparatively - lesser need in Fylde, in the same way that some say the attraction of migrants from Eastern Europe is said to have shrunk the number of jobs available to existing UK residents)

But the report didn't talk about the Local Plan of course. It talked about the need for Affordable Housing and the fact that the Banks will no longer lend to Registered Social Landlords, especially since the recent Conservative budget introduced a requirement for RSL's to reduce their rents by 1% a year (compared to the previous formula of an inflation +1% position).

The report went on to say... "The announced [rent ] changes are to apply for 4 years and will lead to a minimum 12% decrease in forecast rental income. This change is very significant and RPs [we think this means Registered Social Landlords] are actively reassessing their business plans in the light of the changes. The issues described above in relation to the restrictive nature of s106 agreements will only add to the pressure on RPs to prioritise their development activity into places with the lowest risk."

In other words, there are not enough people in need of new Social Housing in Fylde  Borough for the lenders and landlords to be certain of receiving even the subsidised rent that would cover the repayment of the commercial loan to build the property and fund its future maintenance.

As a quick aside here, you can tell from the report's phrasing that every stop in Fylde's organ has been pulled out to justify the unjustifiable. In our book, a reduction of 1% a year for four years will amount to a little less than 4% (because of the compounding effect of the reduction), but at Fylde it seems to mean a loss of 12% because they're counting the 'loss' of the increases that might have been charged over the next four years as well.

So the report (unsurprisingly) concludes that a change in policy is needed, and it recommended a plan to disregard what they decided in March, and "adopt a position where all affordable housing, however provided, should be offered and allocated in accordance with the currently adopted Local Lettings Plan. The s106 agreements would be drafted to reflect this position. This would result in a single policy position applicable to all affordable housing. It is proposed that this single policy position would apply for a period of five years which would then be reviewed"

This deceptive and euphemistically obscure policy wording actually means 'we will remove the requirement for future tenants of Fylde's Section 106 social housing to have a local connection with Fylde Borough'.

It means Fylde will start importing people in need of social housing as the rationale to justify the 'Fiddlers Folly' argument to deliver a higher number of Affordable houses than is actually needed in practice for Fylde.

There are three factors which, in our opinion, make a mockery of Fylde's ridiculous statement of the need for 'Affordable Housing". They are

  1. The officer at last night's meeting said that a recent FBC survey of 200 lettings showed that under the 'Old Scheme' 14% of properties could find no tenant from Fylde Borough and had to be let to residents of Blackpool and Wyre. This alone shows that Fylde is overstating its need for affordable housing.
  2. Even more telling is the fact that irrespective of where the tenant comes from (whether it's Wyre, Blackpool or even Bulgaria), the rent paid for any given socially rented property is the same. So the concerns of the Registered Social landlords (and their lenders) about the rents not being able to meet the loans from the banking system can ONLY be because they don't think there will be enough people in Fylde in need of social housing to give the certainty of tenancy income to fund the loan costs.
  3. But most telling of all was the man who did the original research into Affordable Housing Need, when directly challenged at a Planning Inquiry in Fylde, said that the survey he had done showing a 'need' for 420 Affordable Houses a year in Fylde, (the one that started all this foolishness off back in 2006) was only undertaken for theoretical 'benchmarking purposes.' to compare Fylde against other districts in the UK. It was not an assessment of real need. He was reported to have told the inquiry that "the practical solution was actually trivial, only between one and ten percent of that figure" i.e. only a maximum of 42 'Affordable (subsidised) Houses' were actually needed each year at that time, as we showed in our article 'Affordable' Housing in 2007

On that basis, we argue that the REAL future NEED for affordable housing in Fylde is still within the SHMA report's range of  4 to 207 a year - probably at around to 20 additional houses a year.

Wake up and smell the coffee Fylde. It's not the housing policy that needs to change.  It's the useless, delusional nightmare of a policy that Fylde calls its Local Plan..

We're mindful of Sir Walter Scott's comment about being wary of the tangled web we weave when first we practice to deceive, and how apt a saying that is.

Dated:  9 September 2015


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