Wiltshire Council's response to the government's National Planning Policy Framework consultation

Question 15

Do you agree that Planning Practice Guidance should be amended to specify that the appropriate baseline for the standard method is housing stock rather than the latest household projections?

Answer: no

Please explain your answer:

The outcome of the revised standard method for assessing housing needs, particularly for Wiltshire, is objected to - 81% increase from the current figure of 1,917 to 3,476 homes. It is a simplistic method based on achieving aspirational targets without any explanation or evidence as to how the targets have been arrived at and whether practically they are achievable and can be delivered by the market. It results in in unrealistic and unjustified rates for some local authority areas without any understanding of the ability of those areas to accommodate growth. An adjustment should be made to take into account constraints within a local authority area, the importance of which continue to be recognised in the NPPF.

Wiltshire not only has three National Landscapes in its area (44%), but also heritage assets including the Stonehenge and Avebury World Heritage site, as well as substantial areas affected by zones of influence relating to protected habitats under the Habitats Regulations (65%). The presence of Salisbury Plain Military of Defence Training Area and the New Forest National Park further constrain the ability to accommodate growth. This severely constrains the geographical area within which development can be planned and/or the pace at which development can be achieved particularly where strategic scale mitigation is needed to address potential for adverse impacts on protected habitat sites. In total 83% of Wiltshire is affected by National Landscapes and/or zones of influence for protected sites illustrating the complexity and challenge of planning for growth in Wiltshire.

Notwithstanding this, the scale of growth and housing development to be planned for and delivered will need to be supported by timely delivery of strategic infrastructure. Evidence on the current emerging local plan indicates that substantial investment would be needed, for example in the following areas, which would have long lead in times and require a multi-agency approach and government support to deliver: the strategic road network, including motorway junctions, to satisfy Natural Highways.

Electricity grid capacity and connections to new areas of growth, as well as supporting decentralised energy systems. Waste water treatment and availability of water supply (direct relationship with protected habitats).

There is also no consideration of the market's ability to absorb such high levels of homes and whether the development industry has the capacity to deliver at the scale and pace that would be required.

The issue for Wiltshire is compounded by neighbouring authorities who also face extensive increases (e.g. BANES, Cotswold) which are also constrained due to the presence of National Landscapes, designated heritage assets). Given the proposed high housing numbers for many areas and their neighbours the ability to now respond positively to another authorities' need has substantially been reduced, which has the potential to increase the complexity of plan making and ultimately slow down progress.

If the proposed revised method is to be retained, the figures should be capped, like the current method to ensure any uplift in figures to be planned for is reasonable. See response to Question 17 also.

Question 16

Do you agree that using the workplace-based median house price to median earnings ratio, averaged over the most recent 3-year period for which data is available to adjust the standard method's baseline, is appropriate?

Answer: no

Please explain your answer:

Using variables of house prices and median earnings within the method produces a figure which is demand-led, not needs-led. Applying a demand-led factor results in a standard methodology which will follow market conditions, not the actual needs for an area. The housing market does not operate in the same manner as other goods, as demand is less responsive to supply, and more to economic factors such as borrowing costs and the ability of borrowers to service housing debt given other living costs. Similarly labour costs will typically respond quickly to market conditions, as workers respond to factors such as inflationary pressure on living costs.

The use of a 3-year average will dilute the impact of isolated events which affect the affordability factor in the short term. These could include global or national events (for example as has occurred recently, through geo-political activity or post-COVID pandemic trends). These may cause noticeable fluctuations to the Local Housing Needs figure, which will take local authorities time to respond to.

Using a 3-year average figure is a positive step however, overall, applying an affordability factor still links the assessment of housing need to demand-based factors that are outside of the local authorities' control which is not supported. This can disturb plan-making process and will take time for local authorities to respond to when carrying out their plan-making activity.

Question 17

Do you agree that affordability is given an appropriate weighting within the proposed standard method?

Answer: no

Please explain your answer:

No, the affordability adjustment factor is given too much weight and results in an excessive uplift for Wiltshire (as well as other areas) resulting in exceptional rates of growth that are unrealistic and unjustified. The resulting level of growth for Wiltshire is 3,476 homes per annum, which is 81% higher than the current standard method figure.

To illustrate how unrealistic this figure is we only need to look back to the 2016 Structure Plan, which planned for both Wiltshire County (equivalent to the current unitary authority of Wiltshire) and Swindon Borough. At that time 3,000 homes were planned for over the period 2006 to 2016, which included the whole of Swindon Borough and the large urban area of Swindon. Clearly Swindon is no longer a part of Wiltshire and the resultant figure for Wiltshire alone is substantially higher than what has been achieved.

While it is understood that there should be some uplift for affordability this needs to be set at a lower level, which is deliverable and achievable.

Question 18

Do you consider the standard method should factor in evidence on rental affordability? If so, do you have any suggestions for how this could be incorporated into the model?

Answer: no

Please explain your answer:

No, for the same reasons as set out in Question 16.

Question 19

Do you have any additional comments on the proposed method for assessing housing needs? Please provide any additional comments on the proposed method for assessing housing needs.

Answer:

Having regard to the Environmental Impact Assessment principles in relation to Greenhouse Gas Emissions, growth that does not align with the Paris Agreement 1.5oC compliant trajectory is likely to result in 'Moderate Adverse' / 'Major Adverse' impacts that would be a 'Significant Adverse' impact in EIA terms. The revised standard method for housing needs presents a risk of unchecked growth that might not accord with the UK's international agreements. This is particularly an issue for Wiltshire which will see significantly greater housing requirements and already experiences high levels of private vehicle use. The combination of these issues will likely create significant carbon emissions, not just from the new homes, but increased surface transport.

The outcome of the revised standard method for assessing housing needs, particularly for Wiltshire, is objected to - 81% increase from the current figure of 1,917 to 3,476 homes. It is a simplistic method based on achieving aspirational targets without any explanation or evidence as to how the targets have been arrived at and whether practically they are achievable and can be delivered by the market. It results in in unrealistic and unjustified rates for some local authority areas without any understanding of the ability of those areas to accommodate growth. An adjustment should be made to take into account constraints within a local authority area, the importance of which continue to be recognised in the NPPF.

Wiltshire not only has three National Landscapes in its area (44%), but also heritage assets including the Stonehenge and Avebury World Heritage site, as well as substantial areas affected by zones of influence relating to protected habitats under the Habitats Regulations (65%). The presence of Salisbury Plain Military of Defence Training Area and the New Forest National Park further constrain the ability to accommodate growth. This severely constrains the geographical area within which development can be planned and/or the pace at which development can be achieved particularly where strategic scale mitigation is needed to address potential for adverse impacts on protected habitat sites. In total 83% of Wiltshire is affected by National Landscapes and/or zones of influence for protected sites illustrating the complexity and challenge of planning for growth in Wiltshire.

Notwithstanding this, the scale of growth and housing development to be planned for and delivered will need to be supported by timely delivery of strategic infrastructure. Evidence on the current emerging local plan indicates that substantial investment would be needed, for example in the following areas, which would have long lead in times and require a multi-agency approach and government support to deliver:

• the strategic road network, including motorway junctions, to satisfy Natural Highways
• electricity grid capacity and connections to new areas of growth, as well as supporting decentralised energy systems
• waste water treatment and availability of water supply (direct relationship with protected habitats)

There is also no consideration of the market's ability to absorb such high levels of homes and whether the development industry has the capacity to deliver at the scale and pace that would be required.

The issue for Wiltshire is compounded by neighbouring authorities who also face extensive increases (e.g. BANES, Cotswold) which are also constrained due to the presence of National Landscapes, designated heritage assets). Given the proposed high housing numbers for many areas and their neighbours the ability to now respond positively to another authorities' need has substantially been reduced, which has the potential to increase the complexity of plan making and ultimately slow down progress.

If the proposed revised method is to be retained, the figures should be capped, like the current method to ensure any uplift in figures to be planned for is reasonable.