DM Rejects Policy
In 'An Affordable Policy?' we reprised some problems with Fylde's Local
Plan, and focussed on a proposed change to Fylde's 'Affordable Housing' policy that the Environment Health and Housing Committee decided to approve.
At present, new houses provided in Fylde as 'Affordable Housing' may only be let to residents of Fylde Borough.
They are socially subsidised Fylde houses for Fylde people.
But the change proposed at Fylde's Environment Health and Housing Committee would see the Affordable Houses that developers built in Fylde being offered to people on the waiting list from elsewhere - especially Blackpool and Wyre - if there were no
takers from Fylde.
Now, if you believe what Fylde says about the number of people in Fylde Borough who 'need' Affordable Housing, this should never be a problem.
The huge numbers that Fylde says are in need of Affordable Housing means that they would never need to be offered to anyone from outside the Borough.
Fylde says there is a desperate need for affordable housing, especially in St Annes.
Our trouble is that we don't believe what Fylde says.
Not for one minute.
Nor (it appears) do the Housing Associations that Fylde works in Partnership with ('Progress Housing', 'The Muir Group' and 'Great Places').
They say that the banks won't lend them money to build the houses unless FBC removes the restriction that requires tenants to have a local connection.
The only reason this can be the case is that both the Housing Associations and the banks realise that the REAL number of people who need 'Affordable Housing' in Fylde is too few to give landlords the certainty of tenancy income that will repay
the loan costs to build the houses for rent.
Furthermore, because of a quirk in the arrangements, this option to offer property to tenants from elsewhere already applies to Fylde's former Council Houses that were bought by new Fylde Housing (now merged into Progress Housing), and a recent
Fylde survey showed that in 14% of the lettings, there was no tenant in Fylde Borough that wanted the Affordable property that had come available, so it was let to someone from elsewhere.
So for these (and other historic reasons), we argued that in practice, there simply cannot be the level of demand that Fylde says there is within the borough.
But Fylde's Conservative majority on the Environment Health and Housing Committee forced through a decision to recommend Fylde's Development Management Policy Committee - firstly to note the change, then secondly to build it into the future agreements
they have with developers who provide the Affordable Houses.
They wanted the Development Management Policy Committee to use the same letting criteria that are applied to the old Council houses, and to tell developers and Registered Social Landlords that in future, if there are no people in need of the
Affordable Housing in Fylde, the Affordable Houses must be provided for people outside Fylde Borough.
When we first reported this story in 'An Affordable Policy?' we regret that we gave some incorrect information. - Or more particularly, we gave information that that was slightly out of date.
Fylde published a revision to its housing numbers last November and it further corrected them again in May 2015 which we hadn't noticed.
With so many updates and corrections to its proposals, and a complete public re-consultation on its Draft Local Plan now imminent, it's actually difficult to keep track of what is the current version, and we apologise to readers for the outdated
information in our previous article.
Sadly however, the latest revised figures make Fylde's Affordable Housing prophecies even worse than before.
They say the net annual affordable housing need in Fylde has gone up from the ridiculous 207 Affordable Houses a year we reported in our last article, to an even more ridiculous 249 'Affordable Houses' a year.
The updated projection arrives at this figure by projecting forward an assumption for the number of what it calls the 'annual gross rate of household formation'.
That happens when a new household comes into existence, either by splitting an existing one (eg by children leaving home or divorce and separation), or by net in-migration of people who want to move here, but can't afford a place to live without
The report itself says "...the higher level of gross household formation results in an estimated increase in the number of newly forming households unable to access owner occupation or the private rented sector within their own financial means,
without help from Housing Benefit or Universal Credit."
Put more simply, this says: When more new households form, then there will be an increase in the number who can't afford to buy or pay the market rent, and that's why the number in need of Affordable Housing has increased.
Readers will see this process to assess affordable housing need seems to be a lot more theoretical a process than the process the banks and social landlords seem to have in mind.
Theirs is much closer to common sense.
We said in our previous article (as we have often said before), that we agree with what the author of Fylde's original 'Affordable Housing Survey' subsequently told a Public Inquiry - that Fylde's real and practical need for Affordable Houses
is 'trivial' and lies between 1% and 10% of the figures produced in his Benchmarking Survey that was intended to compare Fylde with other areas.
Since publishing our article 'An Affordable Policy?' we've also had some comments from readers which were of interest.
One was from a reader in Southport, who tells us that Southport is already providing a number of immigrants with accommodation in two older failing large four star hotels. Our reader wondered if the same sort of thing might be happening in Blackpool
and if so, whether at some point in the future more affordable houses will be required - not only for EU citizens but those from the war torn Middle East .
The email goes on to worry that with no new job prospects in sight, the area may be facing an increase in population irrespective of housing availability and without regard for the social cohesion problems that might arise, and that without adequate
employment and financial planning being in place now, there may be trouble ahead.
We also had an interesting observation a reader who noted an interesting situation regarding the proposed Whyndyke Farm development.
It seems that the likely main site entrances off the Blackpool to Preston road are technically within the Blackpool Boundary, and Blackpool Council objected to the plan. They argued that that the 'affordable housing contribution' made by the
developers of Whyndyke Farm should be provided off-site, and that while additional affordable homes should be made available to Fylde residents, they should be located within central Blackpool.
The Fylde officer's report on this matter commented that Blackpool also said that a number of lettings in the south of Blackpool could be reserved for applicants with a Fylde connection and this would correspond to the number of affordables that would
be delivered at Whyndyke each year, adding that appropriate homes could be made available as soon as financial contributions are made, and there would be no need to wait for new affordable housing developments were completed before affordable homes
were made available. Blackpool listed what they saw as other advantages to this plan as well.
We say what a cheek!
And now Fylde's Environment Health and Housing Committee want to open Fylde's new Affordable Houses to Blackpool residents as well.
Thankfully (and, we thought, surprisingly), it looks as though some sense is beginning to dawn though.
We had hoped to attend the Development Management Policy Committee meeting on 16th September to see what they made of Cllr Aitken's proposal to open Fylde's future Affordable Housing to those living outside the Borough, but in the end, a diary problem meant we couldn't
go. However, we have since spoken to some who were there.
To be honest, we expected the Conservative majority on the Development Management Policy Committee to rubber stamp Cllr Aitken's proposal.
But they didn't.
We understand Cllr Redcliffe did his best to persuade the DM Committee to support his fellow Ward member - Cllr Aitkin's - proposal, and he suggested trying it for 6 months to see how it went.
But Queen Elizabeth led the opposition to the idea and she was supported (by what we were told was an overwhelming majority of the committee) in her proposition not to support it.
So the DM Committee decided to reject the recommendation of the Environment Health and Housing Committee to change the Section 106 tenure arrangements and to continue to decide them on a 'per application' basis.
The actual minute says ".. future Section 106 agreements entered into by Fylde Borough Council to secure affordable housing should not reflect the occupancy restrictions as set out in the Local Lettings Policy."
It also goes on to say that the DMC Policy Committee will "engage with representatives of registered social landlords to help feed in to a review of policy for truly affordable housing."
We're pleased with both these decisions.
And we're pleased on two counts.
First, that the silly idea of bowing to pressure from the Registered Social Landlords has been rejected. As Cllr Jacques said at the Housing Committee, it's not Fylde's job to 'sort of subsidise' what the officer report itself described as
multi-million pound Housing Association businesses.
Secondly, we're even more pleased that this is (we think) the first important decision for a long time that seems to have had its basis in common sense rather than single party Cabinet politics. And to us, it shows that the recent change to the
Committee system of operation at Fylde has - at last - brought some hope for the future of decision making here.
One swallow does not a summer make of course, but to us it seems a step in the right direction.
So what are the repercussions of this decision?
Well, interestingly it creates a conflict in the decisions of two committees.
It's possible, (but probably unsatisfactory), that the conflicting decisions can remain as they are.
The usual resolution to resolve this sort of thing would probably be to have a vote at full Council to sort it out - and that might still happen.
But to us, there seems to be another possibility. One of the councillors might have caused a problem with the first decision.
Councillor Willder is Vice-Chairman of the Environment Health and Housing Committee under Ben Aitken, and at that meeting she declared a personal interest in item 4 - (Affordable Housing Provided through Planning Obligations) because she was a
member of the board of Progress Housing Group Ltd.
A personal interest allows councillors to stay in the meeting, take part in the discussion and vote.
Probably the best example to illustrate this that we could give is to look at a councillor who is a member of Fylde Rugby Club, (along with another few thousand people). If a matter concerning the club comes up, as long as you declare your
interest as a club member, that's fine. But it would be a different case if you were, say, the club's Treasurer, or even if you were a member of the Board of Directors. That's likely to be seen as being a 'prejudicial interest' - and you should leave
the room for that item.
Cllr Willder did declare a prejudicial interest in one item (Item 5: Proposed Compulsory Purchase Order of Property to Deliver Affordable Housing) of the Environment Health and Housing Committee, She left the room and took no part in the
debate or vote on that item.
This was perfectly proper.
We wondered at the time why she declared a Prejudicial Interest for one item and only a Personal Interest for the other. As far as we could see, both of them had the potential to affected the financial wellbeing of Progress Housing of which she is a
But declaring interests are a matter for the individual Councillor to decide.
At the Development Management Policy Meeting this week (where Cllr Willder was substituting for Councillor Barbara Nash) we understand she was asked about her
remuneration as a board member of Progress Housing. We're told by someone who attended the meeting that she confirmed she was paid as a Board Member, and she subsequently declared a Prejudicial Interest and left the meeting whilst the Affordable
Housing matter was debated.
Given that she had NOT done this for exactly the same item at the earlier committee, we wondered whether the previous decision by Cllr Aitken's committee was sound. The result of the vote on that matter was tight (we think it was 4:3 from
memory) and if she had declared a prejudicial interest at that meeting - and thus had not been one of the '4' who voted to support Cllr Aitken - then the result might have been different.
We're told that Cllr Aitken (who was said to be present in the public gallery of the DM Committee meeting) appeared to be less than pleased with the decision of the Development Management Committee.
Fylde's officers may yet be called on to set out the definitive advice on the matter. So it may not be over yet.
But there's another - and probably more important- aspect of this matter that came up at the DM Policy committee though.
And that's in the second part of the DM Policy Committee resolution. The bit where the Committee wants to "review the policy for truly affordable housing'.
That's the first time we have seen the word 'truly' added to 'affordable' in this context
This resolution is about establishing just what number of 'Affordable Houses' Fylde actually needs.
If, as may be the case, there is a growing realisation within Fylde, that (what we regard as) the totally fallacious number of people said to be in need of Affordable Housing may not be factually correct, then this review opens the possibility
of a change in the number.
We suspect that will come about (if it comes at all) after the public consultation on the recently published 'Revised Preferred Options', on which Fylde is about to consult.
Even if the number does change, we don't hold out any great hope of it being a sensible change - (because that change would need to be in the region of just 10% of what Fylde has recently been insisting it needs),
Sadly, we await a change on that matter more in hope than with a realistic expectation, but it might go some way toward a smaller number.
And if that happens, there will be pressure for, and the possibility of, change in Fylde's other inflated prediction - the total number of houses needed.
We've covered matter this ad-nauseaum before. We believe the numbers Fylde is ready to adopt as its future aim are hopelessly wrong. They're in the realms of fantasy. They're now talking about the need for 370 houses a year overall. We think it should
be less than 200 overall.
That's because we (in common with almost half of Fylde's councillors who supported the two Minority Reports that have been published on this matter) don't believe Fylde has drawn sound conclusions from the employment land data their consultants
provided (There were 6 methods of calculating future need that said there was enough or too much employment land at present, and just one method said they needed a big increase. They chose the last one).
We believe the figures for total housing need are also inflated because far too much emphasis has been given to the needs of inward migrants to Fylde, when this is actually a local plan seeking to meet a local need for housing.
It should not be Fylde's role to ape the disaster that unfolded when Spain's development 'gold rush' (to meet the pressure they were experiencing from inward migration) almost completely destroyed the character and identity of large tracts of
Spanish land and the pre-existent communities that made the area attractive in the first place and eventually caused the collapse of the Spanish property market which - is only just starting to recover.
It's this overall housing number that is at the root of nearly all the trouble with Fylde's Local Plan.
It's one of the main reasons that a Government Minister has just granted an appeal for up to 360 new dwellings to be built at Blackfield End Farm at Warton.
The underlying problem - that no-one seems to be able or willing to resolve - is that Fylde is said not to have a 'five year supply of houses' as required by the Government's National Planning Policy Framework.
Hours of work have gone into trying to make Fylde's figures look better: all to no avail.
We believe it is impossible to resolve this matter so long as Fylde continues to insist it 'needs' the fantasy land number of houses that it presently says it does.
We believe that's because the developers can't or won't build the existing planning permissions they have.
In turn, that's because building all the permissions which developers now have in place would saturate the market for housing. It would drive down the prices of new (and probably existing) houses, and make the new homes they build unviable. So
in effect they are 'banking' land with planning permissions for gradual future development when demand is greater or there are less houses being built.
That alone should tell anyone with an ounce of common sense that too many planning permissions have already been granted.
This matter hinges around which houses, (and which planning permissions) Fylde is (and more especially, is not), allowed to count within its five year housing supply. We've previously described the calculation process (set out by the
Government) as 'smoke and mirrors' and 'alchemy'
We say, when you can't count planning permissions that you've granted because they've no realistic prospect of being built within the next five years, the only way to solve the problem is to review and re-interpret the way you arrived at the number
needed in the first place.
That seems to be just what Fylde are about to do for their 'Affordable Housing' numbers.
We can only hope they see the light and do the same for their overall housing numbers.
We're grateful to one of our readers for relaying a story to us that perfectly illustrates this problem.
The story concerns a statement which originated at a workshop for Planning Officers that was hosted by the Government's 'Planning Advisory Service' to launch their Technical Advice Note on 'Objectively Assessed Need and Housing Targets'.
The guest speakers at the technical Advice Note Workshop included a Planning Inspector who specialised in the examination of Local Plans.
A delegate to the workshop asked him a question about the extra 5% the Government says must be added to the housing numbers for those councils who are not able to demonstrate that they have a five year housing supply.
A delegate from the floor asked how it made sense to impose this 20% 'buffer' (as it's called) to the 5 year housing land supply for those councils who have a large number of unimplemented planning permissions?
The Inspector replied that the existence of so many unimplemented planning permissions indicated that the estimated need for housing was too great, and the estimate of need in the Council's Strategic Housing Market Assessment should be adjusted
downwards accordingly, making it possible to comply with the 5 year housing land supply rule.
In a subsequent 'one-to-one' conversation with the delegate, we're told he was asked to confirm this view, and he did so.
And when you think about it, it's obvious.
What that Inspector said at the workshop is obviously sensible Ė if there are lots of permissions not being taken up, it's not because the planning permissions are insufficient to meet the rate of building!
So until Fylde changes the number of houses it says it needs, it is extremely unlikely to be able to meet the five year supply.
But that's not going to happen easily. There would be a considerable 'loss of face' on Fylde's part to backtrack to the sort of numbers that are really needed.
But worse than that, the Government itself (who have used housing debt to create the illusion of restored financial stability and created a huge debt bubble that is yet to burst), want there to be even MORE houses.
They have issued what they call 'Practical Guidance' on this matter and said councils must monitor the stock and flows of land allocated, planning permissions granted, and conversion of those permissions into completions.
They suggest a complicated formula which, bizarrely, says that if what is supposedly required is not being built, then you should increase the requirement!
It's believed the Government's thinking behind this view is that increasing the number of sites that have planning permissions will give developers more choice of sites to develop, and this, in turn, will increase the amount of development that takes
That's utter tosh of course - unless your real aim is to help developers by creating conditions for them to establish a land bank where the site value goes from £10,000 an acre to £1,000,000 an acre (or more) whenever land changes its permitted use
designation from agriculture to housing.
The real situation in Fylde is that we now have a huge number of permissions which canít be turned into built homes within 5 years, because of market conditions and developer constraints.
Furthermore, year-on-year, if developers in Fylde do not build anything like the 370/year that Fylde (currently) says are needed- and the shortfall has to be made up within 5 years as Government requires - the only way they will ever show a 5 year
supply is to reduce the annual requirement.
It's a real mess, brought about chiefly by the Government, who decided to use housebuilding to create the illusion of wealth that we previously created (properly) from manufacturing.
But much of the 'extra money' in the UK economy at present is not wealth or added value, it's nothing more than an inflated illusion of money based on housing debt, perceived changes in land values, and the printing of billions of pounds of so called
'Quantative Easing' for which no sound justification exists in terms of assets or increased national productivity or exports.
The other driver for housing is Fylde's own 'Vision' as set out in the draft Local Plan.
Prodded in this direction by the bribe that Government offers councils (The New Homes Bonus) which, for Fylde, is now heading toward 20% of its overall income, Fylde's 'vision' has been crafted so as to produce an illusory a 'need' for both
employment land and housing numbers.
This then feeds into the Government's scheme to use housebuilding as the process by which the country can 'borrow our way out of debt'.
But the real world of Affordable Housing has just sharply intruded into this bubble as far as Fylde is concerned.
We hope it bursts, and we hope that the fantasy overall housing numbers Fylde says are needed here gets the same treatment.
But just before we finish, we have to mention one further repercussion that we can see from the Development Management Committee's decision not to meet the Registered Social Landlord's request to widen the letting criteria. We wonder whether, by
pushing for Fylde to change its Affordable Housing policy, they might just have shot themselves in the foot.
We could imagine that if they are saying they can't afford to borrow to build houses to let at subsidised rentals, then Fylde could well decide the rental market has less need than they previously believed. That could convince Fylde to switch its emphasis from
providing future social rented 'Affordable Housing' and focus much more of its Section 106 housing money subsidy toward the provision of 'Low Cost Housing' which would involve providing smaller, lower cost houses - typically suitable for those at the
start and ends of their lives, and on shared equity housing where the tenure is part ownership and part rental.
So we don't think the 'fat lady' in charge of Fylde's Local Plan is singing yet.
And to offer a smile until she does sing, we're grateful to the reader who sent us a copy of a page with an unfortunate typo from the latest draft of the Local Plan concerning Freckleton in the Local Plan.
We have previoulsy used 'stazi-style' to describe an awful planning committee meeting run by Cllr Fiddler, and we know Freckleton does have a 'Bunker Street', but our reader wondered if the small isolated industrial estate mentioned
in the page might be near Swastika Road. Readers can follow this link to see the page
Dated: 1 October 2015