Object

Representation ID: 8712

Received: 28/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

3.16 Paragraph 61 of the NPPF2021 confirms that minimum annual local housing need calculated in accordance with the government’s standard method provides the starting point for assessment of the number of homes to be provided through plan-making. Positive plan- making should address those circumstances where it may be appropriate to make provision for a higher number of new homes than indicated by the result of the standard method (with a non-exhaustive list of potential reasons summarised in the Planning Practice Guidance at ID: 2a-010-20201216.

3.17 It is apparent from paragraphs 1.11 and 3.1 to 3.3 of the Council’s consultation proposals that the Council has not considered potential reasons to plan for a higher housing number as part of the current process. Instead, it has only tested an arbitrary 10% uplift to the calculation of LHN within the draft Sustainability Appraisal process. This approach is contrary to material considerations (including the Council’s own evidence base) that require more detailed assessment before selecting options for the submission draft Plan and setting the housing requirement in the Plan.

Reasoning
3.18 Paragraph 3.4 of the consultation document ‘Creating a Vision for the Oxford-Cambridge Arc’ refers to the importance of the role of the NPPF to deliver the economic pillar of objectives for the corridor. In principle this reflects use of the standard method as the expected starting point to identify housing needs within the Arc but further reflects observations in the initial consultation and the role of the PPG that may necessitate delivery of higher levels of housing, setting out considerations such as:

□ “developing an Economic Strategy, supported by strong economic evidence, to identify the policies, locations and investment needed to deliver the Arc’s potential for sustainable and green economic growth; and
□ setting policies to make sure growth is felt by all communities and the Arc becomes a better place to live and work for all, such as by providing more housing in the right places, making sure people can move around by public transport and other infrastructure, and enhancing the Arc’s natural capital”

3.19 The main implication of this component of the Arc Spatial Framework reflects circumstances where the calculation of local housing need will not result in sufficient workers in the right locations to achieve the full potential of sustainable patterns of economic development.


3.20 In relation to the Council’s evidence base there appear to be significant issues with their assumptions for labour demand and labour supply techniques to forecast future changes in jobs and the requirement for additional workers.

3.21 In-particular, the Council’s Employment Topic Paper:

□ Does not use a range of economic forecasts (utilising only the East of England Forecasting Model (EEFM2019) baseline scenario only)
□ Does not consider a past take-up scenario for jobs growth and delivery of employment floorspace
□ It is likely to significantly over-estimate the number of jobs associated with the increased working-age population based on the LHN (the Council’s employment land scenarios set out no assumptions on economic activity rates or commuting - the baseline EEFM assumptions are not dissimilar to LHN in terms of additional dwellings and persons required to meet the jobs forecast).
□ It takes no account of engagement with the LEP or forecast Spatial Framework scenarios (that may result in a higher demand for labour)


Remedy
3.22 Failure to take account of these factors means that the Local Plan 2040 is more likely to result in conflict with the emerging priorities of the Arc Spatial Framework and it is recommended that a range of jobs-led scenarios are tested prior to determining the housing requirement for the Local Plan 2040 and selecting an appropriate strategy.