The Local Plans Progress
It's a while since we looked at progress on Fylde's Local
In fact, our last actual update was in December 2013, (although we made comment on the matter of
Fylde's Local Plan: Re-Consultation in August 2014).
So this article takes a look at recent developments in this area.
It also take a brief look at a change the Government is planning for defining how many houses a council must permit to be built.
And eventually, it looks at what we think are some of the underlying causes of the housing crisis.
We begin with two introductions to planning today, one At the national level and another At the local level, before considering the latest position with the
Key issues of the
Local Plan, but we start with a note of the 'Duty to co-operate' - one of the bigger 'Side Issues'
In the main section we look at Key Issue 1: Employment Land, where Fylde are over-stating the scale of employment land that will be needed.
Then we look at the disaster that
Key Issue 2: Affordable Housing has been allowed to become after getting it wrong for the last 15 years.
Finally in the main section we look at the vexed and complicated
Issue 3: Housing Need which has also been over-stated (possibly to generate more cash in New Homes Bonus payments from the Government).
Next, we reveal how that the cat was put amongst the pigeons as Government Changed the basis for calculating housing need for any area and shows that Fylde's present plan
will build a lot more dwellings than it needs.
Then we, look at What this change will mean for: The Five Year Supply; and for
Resisting applications and appeals, before
considering The possible Political fallout and what is likely to happen in Fylde, in Wyre, and in
Finally, we draw some Conclusions about all of this for Fylde and Elsewhere, before considering
the Bigger Picture overall, and the impact for Renting and for Buying a home, all of
which could most likely see us
continue with the charade of 'Alice in Wonderland' planning until something explodes.
At The National Level
When the Government introduced the National Planning Policy Framework ('NPPF' or just 'The Framework') it abandoned the wealth of accumulated detailed technical knowledge -
built up and refined over many years - in favour of an online offering of what is, in effect, a loose-leaf plan (so it can be changed easily).
This NPPF is so (intentionally) vague as to be almost meaningless compared with the technical detail it replaced, and the very idea of having an advance planning
that is designed so it can be changed easily comes close to denying the purpose of a long term plan in the first place
Local Plans are typically prepared to address a period of decades.
Fylde's runs from 1 April 2011 to 31 March 2032, a 21 year period overall, and a period of 14 or 15 years from the expected date of adoption in 2017 (as was planned) or 2018
(as is now expected).
Local plans must, by law, conform with the requirements of the NPPF, but when the NPPF changes within a Local Plan timescale, it causes chaos in the planning system - which
envisages much longer horizons.
Part of the problem here is that typically, the Government's perspective is only the time remaining before the next election, so the (expensive) alteration of existing plans
consultants, new calculations, new proposals, new public consultation on the plan and so on) tends to be undertaken for the short term electoral imperative.
And that situation could torpedo Fylde's latest plan even before it is adopted, because the Government is about to change the basis on which housing need is calculated.
That's going to change the number of housing units Fylde is said to need, and we'll look at this shortly.
At The Fylde Level
Readers will know we've been very critical of Fylde's Local Plan.
It is vastly over-optimistic in its assessment of the need for housing and for employment land.
We have tried to effect a change of heart by making people aware through these pages, and by responding to consultations when Fylde asked for them.
But broadly speaking that
had no effect. So, together with others who had interests in this matter we attended the first of the Examinations into Fylde's Local Plan and spoke as a member of the public to
oppose the plan's claim to 'soundness' (more later).
At the end of the first examination session, we came to the view we were wasting our time.
The Examiner listened politely, but appeared to pay scant attention to anyone who was not a qualified planning professional.
As a colleague said to us, 'when the public speak, she puts her pen down.'
So we didn't bother going to the second set of Examination Hearings, and neither did a colleague who, in planning terms, we regard as probably the most able Fylde resident
we know who is not a professional planner.
As a small aside at this point - although we didn't go to the second session of the Examination, one of our readers did go to listen, as an interested member of the public,.
later told us that in the thick of arguments about housing numbers, they spotted a familiar brown screen displayed on the laptop being used by one of the barristers who was
sitting just in front of
them. (They thought it was Fylde's barrister but were not sure).
If our reader was right, we might even claim that counterbalance does seem to reach parts that other publications cannot reach and, if so, we hope
the barrister found what they were looking for.
Fylde's examination process is now concluded, and the Examiner is considering what was said.
Her report was expected to set out a number of matters that Fylde had to address
before the plan could be considered sound enough to be adopted as Fylde's new Local Plan.
But before the Examiner's report (and any changes she required) could be published, Fylde jumped the gun and changed their plan yet again, apparently in anticipation of what
they thought the Examiner might say on a number of matters.
We've no idea why they did this. Perhaps it was simply to hasten/ short circuit the process, or perhaps they wanted to appear better than they have been, and say they had
almost no changes to make when the Examiner's report was published.
But for whatever the reason, they made several revisions that anticipated the Examiner's report.
Since then there have also been a number of planning appeals affecting Fylde. Most notable of these was a huge 'combined' set of four housing appeals - which were all heard at one single
inquiry - regarding sites in Wrea Green, each with their own barristers and technical experts and with local people trying to make their own case.
But in reply to an inquiry that Wrea Green's Cllr Frank Andrews raised with our MP regarding housing numbers, the Government's Housing Minister said the way housing need was going to be
calculated was going to change. We'll come back to this later.
As far as we are aware, and at the present time, the lady examining Fylde's Local Plan is holed up somewhere, trying to decide what to make of the changes Fylde has already
made and what other changes she thinks might be needed.
We're told she has found something she thinks is quite significantly procedurally wrong with Fylde's treatment of the EU Habitats Directive.
'CAPOW's latest newsletter about the situation in Wrea Green says that on 10th May, Fylde's Local Plan Examiner wrote to FBC concerning what she sees as a lack of compliance
with an EU Habitats Directive.
It seems that she thinks (and we agree) that it is necessary to consider avoidance and mitigation measures for potential environmental damage that impacts on 'Special
Protection Areas' and other EU Designated sites *at the screening stage* of a planning application (ie they should be considered when deciding whether an Environmental Impact
Assessment (EIA) is needed or not).
Whereas Fylde seems to believe they only need to be considered if the result of the screening exercise says an EIA *is* needed.
We're told the Examiner is asking for this matter to be reconsidered by Fylde, and for adjustments to be made to the plan process as necessary.
This is quite a fundamental problem, and as yet, we understand Fylde has been unable to provide a response.
Perhaps even more especially, and given what took place during the Wrea Green appeals, the Examiner might also be wanting to assess the implications of the new way of
calculating housing need before she is content to publish whatever her report will say.
That again could require changes to Fylde's draft plan.
Frankly it's a mess.
Planning Chairman Cllr Trevor Fiddler once said we were engaged in Alice in Wonderland Planning these days
Well, it's just become The Mad Hatters Tea Party.
LOCAL PLAN: THE KEY ISSUES
But First, A Note Of One of the Side Issues
We don't have time to look at them all here, but there are a great many smaller 'side issues' regarding Fylde's proposed Local Plan. Chief amongst these is whether,
(and if so how much),
Fylde needs to comply with the relatively new 'Duty to Co-operate.'
Broadly, this says that if, (like Blackpool), your planning has been so awful that you've build on almost every bit of green land you had and, for example, you have decaying
'inner city' type middles (like the Central Drive area for example), you don't necessarily have to adopt the more expensive option of demolishing and redeveloping the decayed
parts, you can simply require neighbouring councils (who have better managed their planning), to let you build Blackpool's housing quota in THEIR borough.
We've used Blackpool as an example here, but in reality they're not asking Fylde for housing land. Their claim on Fylde is for a lump of employment (industrial) land.
However WYRE, who have as much - if not more - green space than Fylde has, (and whose local plan isn't even as far advanced as Fylde's), ARE suggesting that they should be
allowed to build a large number of houses (we've heard numbers like 500 and 1,000 properties) in Fylde.
And Fylde's Local Plan Examiner seems to expect Fylde to take this ridiculous claim seriously.
That's probably because it's happening elsewhere, since the Government introduced this - what we regard as a foolish - concept.
And that matter is only one of the smaller side issues!
The main Local Plan issues are the scale of employment and the scale of housing that Fylde needs.
Key Issue 1: Employment Land
The rough and dirty explanation regarding Employment Land is that Fylde has intentionally inflated its supposed need for employment land.
It had some complicated surveys and modelling done.
Six of the seven results said Fylde hade enough land, or actually needed a bit less employment land, than it had now.
The basis for this view was firstly the enormous growth in working from home, both through self employment and use of teleworking and the internet.
Working from home now accounts for 23% (and growing) of all workers in Fylde. These folk don't need any 'additional' land - they use their existing homes. (In fact it
justifies a REDUCTION in the need for employment land if they previously worked in Fylde but not from home).
And secondly, the nature of employment is changing - as evidenced by the so-called gig economy, zero hours contracts, the mushrooming of technology based businesses, and
the change taking place as the UK economy shifts emphasis more and more to service industries (as opposed to industrial and manufacturing businesses).
This means that the older, land-extensive industries (like aerospace and fabrication) are declining, and the new knowledge-based industries (such as IT) that are replacing
them, all need far less space per employee than traditional industries like fabrication did.
So six of the seven models said the present level of employment land did not need to be significantly increased.
But the seventh used a completely different basis for its calculation, and *that* said Fylde needed to almost DOUBLE the amount of Employment land that was in use at
And that's the one Fylde has adopted.
Our readers will no doubt wonder how such a vast difference can exist.
Well, Fylde had originally had a vision about where it wanted to be by the end of the Plan period.
In effect this was a Conservative Group political decision written into the Local Plan by officers. (we've done word by word comparisons of each iteration of Fylde's 'Vision
Statement' for its local plan, and when you do that, the changes in direction become easy to spot).
Late in the day of preparing the plan, politicians at Fylde decided to 'go for growth' and changed their Vision to reflect this.
They decided they wanted to build a lot more houses (for which Government would pay them a large sum for five years called the 'New Homes Bonus')
And to increase the number of houses still further, Fylde created what we believe to be a totally fallacious prophecy of future growth.
Then they used that false growth in employment to bolster the supposed need for EVEN MORE houses - on top of what was needed for population and migration changes.
So that's the rough and dirty overview/explanation of where we are with the Local Plan in respect of employment land.
For a more precise account, readers can download the second of two 'Minority Reports' produced by Councillors outside the Conservative Majority who
dissented from the proposals for employment land. We reported this in Minority 2 at Council.
And readers who want even more details of Fylde's awful plan for employment land can follow this link to download the consultation response of Mr Guest, whose thorough and
detailed analysis of the situation with Employment Land is, simply, brilliant, if very technical.
Key Issue 2: Affordable Housing
As with employment land above, this is the rough and dirty version of what's going on in 'affordable housing'.
For historic reasons of self-preservation, Fylde's supposed need for affordable housing was manipulated to ensure the Council’s political survival when Government Inspectors
were about to take over the operation of Fylde's Housing department around the year 2000.
Government said Fylde was not paying enough attention to social rented housing. But Fylde's relatively affluent, predominantly owner-occupied electorate had not placed social
housing high on Fylde's agenda, and councillors of the day had followed suit.
However, for Government, it had become a central policy aim, and they were about to force change onto Fylde.
Their threat was heeded and, as a result (in 2002), the then (new) Chief Executive embarked on a plan to 'rebalance' Fylde's population, by creating vastly more social
rented ('affordable') housing.
He engaged a company called Fordham to research housing in Fylde.
The pre-study description of this research was an "Assessment of Housing Need and Desire".
The post-study name dropped the "and Desire" bit, and the survey became erroneously known as Fylde's 'Survey of Housing Need'.
There's actually a big difference between 'need' and 'desire'.
The survey found the overriding need was for social rented housing (which it claimed was a massive 97% of identified need for ALL housing in Fylde).
The conclusion was that only 3% of house-building here was needed for traditional housing. The rest needed to be socially subsidised housing.
Fordham subsequently conceded that the "Survey of Housing Need and Desire" Fylde had commissioned him to undertake was not intended to be a measurement of practical need for
'affordable' housing, it was intended for benchmarking purposes - to put Fylde into context with other Councils who had used the same particular methodology for similar
He admitted his study was not a survey of practical housing need and said the real practical need was probably not more than one tenth of the 420 affordable houses year he
said was 'needed or desired' in Fylde.
That meant the REAL need for 'affordable' houses in Fylde would be not more than about 42 dwellings a year.
But to ensure its political survival, Fylde adopted the 420 number to impress Government. However, this number had nothing to do with practical reality.
For more than 15 years, Fylde has perpetuated this myth and consistently over-estimated the need for affordable housing in the borough.
Worse, it went on to apply the same modelling and calculation process to *update* the fallacious need for Affordable Housing, eventually saying an impossible 600 affordable
(socially subsidised) homes per year were needed.
Then in 2013, as part of the work to produce the forthcoming revised Local Plan, Fylde commissioned and received a new version of the "Fylde Coast Strategic Housing Market
This was said to have produced an assessment of the local housing market that was now compliant with the requirements of the NPPF
In effect this study replaced all the previous data on affordable housing need, and it was said to be compliant with the latest legislation at the time.
It found that - despite previously saying they needed 600 affordable houses a year - “Less than 40 affordable dwellings were delivered in Fylde in 2015/16, with a long term
average of 38 units per annum”
And, amazingly, just as Fordham had predicted, this actual provision - less than 10% of what Fylde said they needed - had produced an accumulated backlog of ........ just 4
(yes, really) affordable houses a year in the new study.
In terms of the need that would arise in the future, (and including the backlog of 4 houses a year), Fylde was now said to need 207 'affordable' houses a year, not the 600 a
year they had previously calculated.
But even to produce this many affordable homes, using the '30% affordable homes per site' requirement that Fylde was trying to impose on developers - it meant that Fylde would need
to build at least 3,455 dwellings over a five year period. (That's equal to 691 houses a year).
But incredibly, Fylde's draft Local Plan disregards the requirement of the NPPF which says that Fylde's affordable housing number must meet the full, objectively
assessed need for affordable housing.
It goes on to argue that this 3,455 is extremely unlikely to be realised and therefore this level of provision for affordable housing should not be
reasonably expected to be realised - and it suggests plucking the figure of 130 affordable dwellings a year out of thin air.
This is utter nonsense.
Either the affordable housing need calculation is STILL wrong, or Fylde needs to downwardly adjust the percentage of affordable housing that they say developers must
We struggle to see how that process can get anywhere near 'meeting the objectively assessed need in full' that is required by the NPPF
We hope, (but, sadly, with not a lot of confidence), that this is one of the matters which Fylde's Local Plan Examiner might be cogitating on.
As we said, this is the rough and dirty version of what's going on. Readers who would like chapter and verse can follow this link to download this response to consultation
with all the details.
(NB: In the download, the section on Affordable Housing begins partway down the front page, and is preceded by the end of a section on employment land which says much the
same (but far less well), than Mr Guest's response which is mentioned in the Employment Land section above).
Key Issue 3: Housing Need
This is the more difficult of the key issues because there are so many variables in play at the same time.
Back in the days of the Joint Lancashire Structure Plan, Fylde's annual housing need (for all types) was said to be 155 dwellings a year.
In the (now defunct) Regional Spatial Strategy, (published after Fylde's foray into affordable housing) that number had become 306.
In the final stages of the draft emerging Local Plan for Fylde, the Council agreed it should be 415 (Although arguments for alternative numbers had ranged between 195 a year
and a fluttering of around 250 to 280 a year as various individuals and committee meetings deliberated what it should be).
The most recent number attributes the increase needed to two main factors.
- Demand for residential in-migration to Fylde from elsewhere in the UK, and;
- To meet the prophecy of economic growth that Fylde's Mk3 'Vision Statement' hopes to see.
But there are two 'beggaration factors' that come into play when converting 'need' to houses being built.
The first is that legislation imposes a 'penalty clause' if a council's housing numbers have a backlog of unmet need.
Where this happens, you have to build more houses than are actually needed at the time (based on the - in our view false - assumption that the unmet backlogged need still
exists going forward and must still be met years later).
This beggaration factor is further complicated because two different ways to calculate and rectify the backlog exist.
One assumes it will be met within the first five years of the local plan after adoption, and the other spreads the unmet need over the remaining lifetime of the plan. We've
addressed the detail of this matter in several previous articles under their more better known names of the 'Liverpool' and 'Sedgefield' methods.
There are constant arguments about which method may be used. The NPPF is (in our view intentionally) unclear about how it should be done.
So when a Council claims it has already met its 'five year supply' figure, and refuses a planning application, developers often say the council has used the 'wrong' method
of calculation, and argue (often successfully) at appeal that the Council does NOT demonstrate it has a 'five year supply' of land with deliverable planning permissions if the
other method is used. And so it wins its appeal.
This is worse than trying to plait fog, and produces outcomes that are inconsistent, but in our experience, they usually favour the developer (which up to now at least, is
what the Government seemed to want).
The second beggaration factor is that the number of houses built (to meet the quota), depends not on the council granting planning permissions, but on the speed at which
developers IMPLEMENT the permission they have been given.
This is because the Government says the 5 year supply calculation may only count houses that the developer says will be built within the next five years.
So if, as a developer, you get a 1,000 site permission (like Queensway in St Annes or some of the Warton housing), but you were to decide you will only build and sell say, 50 houses a year, then only 250 of the
1,000 houses you have given permission for can be counted to be part of the Council's 'five year supply'
We say it is entirely ridiculous for any council to be required to meet a need that ultimately depends on the build-out rates chosen by developers.
Developers or their agents can effectively bank something like a 100-fold increase in agricultural land value when planning permission is granted for residential use, whilst choosing to build it over periods much greater than five years.
This prevents councils from being able to demonstrate that they hold a five year supply of deliverable planning permissions, which in turn allows developers to secure further 'landbanking' permissions at appeal - simply because they may have chosen to adopt slow build-out rates on sites for which they've already been granted planning permission.
It is a ridiculous situation.
The most recent housing number in Fylde's Draft Local Plan was settled at 415 dwellings a year for quite a while.
But after (we think) they identified a bit more developable land for another 5 or 6 homes a year - it is now a figure of 420 dwellings a year from 2016 to 2032.
But that was before the latest change that Government is making to how the calculation must be done.
GOVERNMENT TO CHANGE THE NUMBERS?
We mentioned earlier that Cllr Frank Andrews contacted our MP before the 'Super Inquiry' was held at Wrea Green to ask about housing numbers.
On 20 Feb 2018, the Minister for Housing replied to Mr Menzies and said that the Government expected to introduce a new way of calculating the numbers (which is to be called
'Local Housing Need' and will become the standard and universal method of calculating need).
In effect, this uses different 'evidence' (facts) from which to calculate the need for housing in any local authority.
And under this new system, Fylde is said to need just 296 homes a year.
He did also say that individual councils could exceed their figure if they wanted to do so.
Readers can follow this link to download a copy of the detailed letter from the Minister.
SO WHAT DOES THE CHANGE MEAN?
The Five Year Supply
Our friends at the Campaign to Protect Rural England (CPRE) have done some calculations and analysis with the new formula.
We can provide more details of the calculation if needed, but they say (and CPRE Fylde Branch are the most reliable independent source of such figures locally) the
Government's changed method of calculation immediately changes Fylde's 'Five Year Supply' number from 5.1 years to a massive 8.9 years supply of deliverable planning
The impact of this will be to enable Fylde to defend future planning refusals at appeal much more easily.
That's because whilst there is 'wriggle room' to argue the toss around whether it's 4.9 or 5.1 years when the numbers are close, a deliverable supply of more than 8 years
isn't going to give developers much prospect of successfully winning appeals.
That might be the Government's idea of course.
They have recently said they want to see more competition to drive down house prices, and less 'landbanking' by developers - so maybe this new housing number is how they
hope to effect such changes.
Resisting Applications and Appeals
Using the new numbers, the scale of the 'five year supply' has changed so much that, in future, Fylde can be more relaxed about saying 'No' when it thinks there are valid
reasons to refuse a planning application.
Up to now, we've watched Fylde repeatedly back down in the face of appeals by developers - because of the likely award of significant costs against the Council if it
lost the appeal.
And because of the utter stupidity of the 'five year supply' concept (which, with its previous numbers, and a clear message from Government that the Planning Inspectorate
should more or less automatically approve appeals where a council could not demonstrate a 'five year supply' of deliverable planning permissions) developers were more or less
guaranteed a win at appeal - So Fylde were unlikely to contest appeals. (Just ask the folk living at Wesham and Warton about this. They saw it happen time after time.)
But now, Fylde has already started to use the new numbers in planning appeals.
In his proof of evidence to the four Wrea Green appeals in March 2018, one of Fylde's officers said
"4.26. To provide the appropriate context the standard [LHN] method provides a new OAHN for Fylde of 296 dwellings per annum (based on 2016 to 2026). This is in marked
contrast to the current OAHN of 415 dwelling per annum; an initial reduction in housing requirement of 29%. Although I have not set out in figures the consequential
calculations of five year supply I consider the potential impacts to be clear."
(LHN is the new acronym for 'Local Housing Need' and OAHN is the previous acronym for 'Objectively Assessed Housing Need')
He actually went further, and suggested that although (on the basis of the previous way of calculating the numbers) Fylde had originally agreed with the developers they had
less than a five year supply, he wanted to retract that agreement, saying
"If matters of housing land supply are to be considered on the basis of the annual requirement now not being a matter agreed between all parties but rather a matter in
dispute, I wish to reserve my position to adduce evidence on housing land supply using this figure (296) to give appropriate context."
So we think we should now see a Council much less fearful of losing planning appeals and having costs awarded against it.
The CPRE analysis we spoke of earlier shows that compared with latest Fylde Coast Strategic Housing Market Assessment (SHMA), using the new Local Housing Need, the annual
housing requirement for each Fylde coast authority is lower
|Blackpool: (Plan Adopted Jan 2016)
||250 to 400
|Wyre: (Plan Currently being examined)
||400 to 479
|Fylde: (Plan has been examined, modifications being considered)
||410 to 430
||415 or 420
'Range' is the range said to be needed using the old system.
'Chosen Number' is the number the Council selected within that range
'Revised Number' is the Government's new way of calculation that need
The implications of this change are very significant.
Up to now, Fylde (and others) have been able to blame the Government's requirements for having to build so many houses.
But not any longer.
So how's this going to pan out?
If Fylde decides the keep the 415/420 number it has provisionally settled on, its decision to build an 'extra' 124 dwellings a year will be shown to have been made by Fylde's
And in particular, by the Conservative group on Fylde Council.
That's because Fylde's councillors outside the Conservative group did not support the proposed housing numbers.
They issued separate Minority Reports setting out their opposition to the number of houses and the extent of employment land that the Conservative group said was needed.
That leads us to the view that in communities like Warton and St Annes and Wesham and Kirkham and Elswick (where large percentage increases are in train) the electoral
consequences of unpopular building permissions will be seen to have fallen on the shoulders of Conservative councillors - because the housing numbers they have adopted will be
identified as the cause of the growth in unpopular and excessive housing development.
To see this, you have to read the very small print of Fylde's emerging Local Plan, but you can work out that the Conservative vision for growth translated into an extra 57 to 81
dwellings a year. (In fact it's not even in the main SHMA, it's buried in a SHMA Addendum Document - Number 3, in table 6.1).
So even if Fylde's number for 'employment land' is right (and we think it's already grossly inflated anyway), it means Fylde still expects to build 43 to 67 dwellings a year
more than the new Government figure says.
Even using these reduced figures, over Fylde's remaining plan period of 15 years, it means Fylde is heading toward something like 650 to 1,000 dwellings more than the
Government new methodology now says is needed.
The top-end of that estimate is the more or less equivalent of not building the Queensway development in St Annes at all, or something like halving the number of houses that
are scheduled for (or being built) at Warton.
There was a great deal of local anger in Warton and in Wesham - and also Kirkham and Elswick - about the scale of development they were being required to absorb, and unless
Fylde's ruling Conservative group changes their overall numbers as a result of what the Government now says, we think they will become exposed as the ones who are responsible for all the new houses.
Whether Fylde will change their numbers remains to be seen, but we also expect the Examiner to have something to say about it in her report on the test of soundness of Fylde's
We don't follow Wyre as closely as Fylde, but the reduced numbers over the plan period ought to substantially weaken the arguments Wyre has used for putting large numbers of
houses within Fylde under the 'Duty to Co-operate' regulations.
The Wyre plan runs to 2031 which leaves 13 years of the plan still to run.
If you multiply (even just) this period by the change in numbers, for Wyre it means a reduction in 'need' of 166 dwellings a year for (at least) 13 years.
remaining plan period, that's a reduction of over around 2,000 dwellings.
This number is far more than anything Wyre have claimed Fylde should provide land for under the 'Duty to Co-operate' regulations, so it might completely wipe out the claim Wyre is
making on Fylde.
Like Fylde, we get the impression Wyre's majority Conservative group are keen to build houses.
In response to comments in their formal consultation on their emerging Local Plan at least one respondent suggested they should use the new numbers to calculate need.
Wyre's response to that was:
'The government’s document “Planning for the right homes in the right places” is a consultation document on identifying local housing need. The methodology and the actual
figure may change before the document is finalised and published. The transitional arrangements within the document itself advise that Local Plans which will be submitted
before 31 March 2018 should continue on the basis of the current figures. As such the Council is unable to give any weight to the draft document as a basis for the Local Plan.
The OAN figure is based on a robust methodology which itself follows current Government guidance. This is set out in the Strategic Housing Market Assessment and Addendums 1,
2, and 3. Need is assessed on a Borough wide basis not for individual settlements. The methodology suggested for calculating need is not in line with Government Guidance.'
In other words, on this trajectory, they expect to disregard the new numbers for a while longer.
We think readers will be able to work out why that might be (but we don't think they will get away with it!), and we think they will have to either admit they are exceeding
the number of houses required, or they will have to change it.
We think both of these are likely to wipe out the claim they have made on Fylde.
Blackpool was ahead of the other Fylde Coast authorities in getting its Local Plan completed, and it runs to a different period (fifteen years from 2012 to 2027)
It has already completed its Examination hurdle and been found to be 'sound' so it was formally adopted in January 2016.
But Blackpool too now has a lower number for its Locally Assessed Need for housing.
Rather than the 280 dwellings a year Blackpool settled for, the new figure says they need only 93. That's the biggest difference of all three Fylde coast councils and, over
their plan period, it suggests they need in the region of 2,800 dwellings less than their plan expects to provide.
Local Plans are supposed to be reviewed every five years and updated if there are good reasons to do so.
That puts Blackpool's Plan in line for review around 2021, but it's not clear to us whether they will wait until then to catch up with the changed numbers, or whether they
will do something in the interim.
We suspect they will wait.
Fylde's Local Plan
The immediate situation means that, if the Examiner requires it, Fylde might have to rework its plan for housing, and might possibly have to consult the public again over
new housing numbers.
That's going to mean more delays and costs for taxpayers before the plan can be adopted. But at least it looks as though - if they choose to do so - Fylde can say 'No' to
developments more easily than they could in the last few years.
Whether Fylde will want to recalculate their housing numbers we're not at all sure. Given the ruling Conservative approach to date, we think it's unlikely.
We also think it means Wyre could lose the argument it has made that Fylde should provide it with space for large numbers of houses under the Duty to Co-operate regulations.
Wyre will also face the same dilemma as Fylde in that their Examiner is likely to have something to say about what Wyre's housing numbers should be for their plan to be
considered to be 'sound'
And at some point, Blackpool will have to review its plan and consider changing the numbers
THE BIGGER PICTURE
But mostly what all of this shows is the complete lunacy of today's planning system
Using political ideology to drive development planning is shown to be a complete disaster
The documentation and consultation that is now required is so complex and expensive that - (and we haven't tracked Fylde's cost, but we wouldn't be surprised to find £2m or
more has been spent on preparing their new plan so far, and that's roughly £25 per head for every man woman and child in the borough) any change to the fundamental evidence
(like this change to the way 'Need' is calculated) causes delays and additional cost on a huge scale.
But the biggest problem of all is that (in our view) Government is using entirely the wrong levers to try to fix the UK's housing problem.
It's not so much planning that needs to change, it's social and taxation policy
The fundamental causes of expensive housing in the UK is rooted in the social policy that all shades of Government have either encouraged or allowed over the years, and in
- the almost complete abandonment of social and financial policy that hitherto supported the nuclear family unit - where two adults (rather than one) supported and provided
for their family. A single parent trying to fund a family on their own inevitably finds it far more difficult to afford the housing costs;
- the decline of the socially benign and cohesive influence of the church in favour of increasing secularisation and individualism - a change that has taken place over many
years, but especially in recent times -, all of which has led to a slow burning but vigorous surge in marriage breakdown across the UK. This phenomena doubles the need
for separate accommodation as one household becomes two, and each former partner requires their own accommodation. The impact of this family fragmentation on housing,
benefits and taxation, is simply enormous;
- a perceived need (mistaken for many reasons) to house large numbers of migrants to the UK - especially following the accession of eastern European countries to the EU, and in particular New
Labour's enthusiastic support for the mobility of cheaper labour that helps to control inflationary wage pressures.
All of these factors have driven demand for houses up to unprecedented levels.
And in future, the immigration issue is set to compound it even further - because although in the early 2000's, the UK birth rate had fallen below replacement levels, younger new
residents from abroad moving to live in the UK have tended to have a higher birth rate per household. This is changing the longer term demographic, so the number of people
needing houses in, say, 20 years, is set to continue to increase.
This is not simply opinion,
- In 2002 there were 668,777 children born in the UK - the lowest birth rate since records began in 1924.
- In 2012, there were 812,970 children born in the UK
- That's an increase of around 21% over a decade
But there are other social factors that drive up housing costs as well.
The scale of housing benefits that become payable as a result of failures to support and promote family policy has spiralled.
It is, by its nature, 'out of control' (it is a reactive payment depending on individual family circumstances - which vary from family to family and over time).
- In 2003/04 we were spending £13.3 million a year on housing benefit.
- Just twelve years later, in 2015/16 it had become £24.2m
The availability, scale and scope of Housing Benefit has pushed up housing rents in both the private and public rented sectors - making affordable rents further and further
beyond the reach of those who are not eligible for rent support.
For those seeking to buy (rather than rent) a house, another big driver pushing up costs is the well intentioned, but ultimately futile, process that has required developers
to provide 30% (or more) of everything they build as 'social housing'.
In Fylde, this policy requires social and market value housing to be built with no differences between them, but the policy transfers the social cost of providing 'Affordable
Housing' to developers. (Rather than have the council build them as they used to do, from capital borrowings and repayments met from taxation).
Fylde's policy requires developers to provide social housing to a Registered Social Landlord Housing Association (or occasionally to first time buyers) at a discount of
(usually) 20% (or more) from the market value price.
The obvious and entirely logical outcome of this policy, is that to be able to afford to offer 30% of the houses you build at a 20% below the price you are going to sell
most of them at, you will begin by inflating the price of those you will sell at market value. (So as to be able to recover the 'cost' of the 20% discount on the 30% of socially
subsidised houses you must provide).
The entirely inescapable logic is that by implementing this policy, the Market Value houses on the site become considerably more expensive and less affordable for those
trying to buy without the benefit of a social subsidy.
And there's more. Another change that has driven up house prices is that developers are now required to provide the physical infrastructure that was once provided by
Government or the
local authority out of taxation.
For example, at one time, Councils use to be given an area within a development site and they would lay it out and look after it as a park or play area or open space for
residents as they moved in.
Over time, that changed so developers had to lay out the land for public use first, before the council took it over for maintenance.
Then that changed again - to the developer providing and maintaining it for two years before the Council would take it on.
Then that changed again to maintain it for 5, (then later 10) years before the council took it on.
Then Councils agreed to take it on once the developer had laid it out - PROVIDED they were also given a cash sum equivalent to ten years maintenance costs.
Then it was 10 years of maintenance costs to include the projected cost of inflation.
Then it became 'You have to provide it and make your own arrangements to maintain it, but if you want us to take it over you must give us a capital sum that will generate
interest sufficient to cover inflation and the annual maintenance cost' - in effect a very large endowment that would fund all future maintenance in perpetuity.
And that's only for parks and recreation.
Lots of other public facilities became added into the mix, most notably the cost of building the roads, street lighting, sewers and drains and now even schools (or at least
sites for schools) all have to be met from the cost of the development.
The new Moss Road associated with the Queensway development was estimated to cost about £22 million. With around 1,000 homes being built you can extrapolate an average cost
of £22,000 per house that has to be recovered for the road's cost from the price housebuyers will have to pay.
And that's only to cover the cost of the one road across the moss.
The most recent cost loaded onto developers is called 'Section 106 Monies'. They have to provide a sum of money that might fund all manner of things from public artwork, to
bus services, to providing councils with cash to pay for social housing off-site (if it can't be accommodated on their site).
When developers have to find the sort of money that was once part of the taxation we paid - (but presumably is now being used for something else), it' is wholly inevitable
that the cost of the houses they build is going to be more expensive.
And the logical consequence is that they must sell their houses at a higher price to remain in business.
We don't buy the argument - advanced by some - that costs to developers only depress the price developers have to pay for the land in the first place. That cost is so
small as to be almost negligible in the bigger picture
So we think it will be obvious to all our readers that these changes in social policy and the benefits system, and the costs loaded onto developers, have all conspired to
increase demand and, at the same time (and separately from the demand-side increase in prices), they have pushed up the house prices that developers have to charge at the same
Increased demand and higher house prices, means less people able to afford to buy houses - which means more people looking to rent. So affordable rented property also
becomes harder and harder to find and the Government's spending on housing benefit increases yet again as average house costs in the area increase and local wages fail to keep
pace with them.
It's clear to us that simply building more houses (which was how the Government expected to solve it) isn't going to solve this problem.
The real worry we have is that there is no obvious solution.
The issue has become so big and so enmeshed in the fabric of society as we know it today, that to make the changes required will take nothing short of a very unpopular
revolution that would likely cause riots and/or civil strife.
That's not a choice any Government will take, so we will probably continue with the charade of 'Alice in Wonderland' planning until something explodes.
Dated: 15 June 2018