The Society submitted the following response to the July 2016 consultation:
Response of the South Hams Society to the consultation on a new local plan for Plymouth, West Devon and the South Hams
As a comment on process, the consultation period of six weeks over the holiday period is too short. This is particularly worrying given that people in the South Hams felt they had not been properly consulted on the last round of housing allocations.
Total housing numbers and distribution
The society is concerned about the methodology used to justify the total housing numbers which form the basis of the allocations and the logic behind the distribution of the houses around the Housing Market Area.
Housing number forecasting.
Our major concerns are in the assumptions about net migration; about allowances for vacancy rates; and most importantly about the "housing market uplift".
The Peter Brett report quotes "Planning Practice Guidance is explicit that the 2012 based household projections are the most up-to date estimate of future household growth." This shows an increase of 19,456 households for the Housing Market Area (HMA) and a population increase of 32,600. The subsequent revision of the population forecasts based on 2014 increases population by 2,400 people, equivalent to just over 1000 households, giving a revised household increase of about 20,500. (NB, the 2014 based household forecasts released on 12 July 2016 give an increase of 20,464)
The report then argues that as the national forecasts are based on "short term trends" and they don't reflect "the growth agenda being pursued within the city of Plymouth" a different rate of net in-migration based on the past 10 years is used. This gives a population increase of 50,661, 15,000 greater than the 2014 national forecasts. The report doesn't give the associated household increase but we estimate it to be about 6,500 based on the 2014 relationships between population and household numbers.
Other migration periods (20 years and 30 years) are dismissed because "they show a smaller overall population and dwelling growth than both the official household projections and the 10 year trend". The official forecasts use a 5 year trend. It seems a 10 year trend figure has been chosen because it gives the biggest increase.
Allowance for vacancy rates and second homes.
In converting a forecast increase in households into a dwelling figure it is accepted that allowances have to be made for the vacancy rate that is evident at any time, about 2.5%. It is less acceptable to make adjustments for the proportion of the new dwellings that could become second homes, about 10% in the South Hams. It is unlikely that the houses being built on the Plymouth Fringe are going to be popular for second homes and as most of the new houses are going to be built in Plymouth or nearby it is unreasonable to inflate the dwelling numbers by a "second home" factor.
Allowance for Housing Market Uplift
It is even less acceptable to apply a "housing market uplift" of 25% in the South Hams due to the high house prices and low average wages. The argument for this uplift is that building more houses will depress their price. In the South Hams, particularly the southern towns and villages, any houses built will be sold and prices will not come down to affordable levels for those on lower wages. No amount of "uplift" will reduce prices.
The Peter Brett report "Testing and establishing the Plymouth Housing Market Area" has in section 4 a map showing mean house prices across the area. It states in paragraph 4.8 "In South Hams house prices vary considerably and on the coast the mean house price is approximately £622,000. In Plymouth this is just £198,000 and to the north it is £268,000. This situation and variation occurs around all the coastal areas and the variation within South Hams district is over £352,000 just within this single district. With such a variance, it is difficult to suggest that housing in one part is a reasonable substitute for housing in another." This statement is at odds with the assumption that increasing the total number of dwellings across the whole of the HMA by 13.4% will reduce house prices in the coastal areas of the South Hams or the attractive rural parts of West Devon.
It is our opinion that there should be no "housing market uplift" to the calculation of the number of dwellings.
Other means need to be found to provide housing at affordable levels for local people rather than building more and more open market housing.
Based on these comments we think a more reasonable dwelling forecast would be as follows, based on the Peter Brett paper:-
Official housing projections (2014 based) 20,464
Adjustment for 2.5% vacancy (rounded) 21,000
This compares with the JLP figure of 30,300 and shows what the effect is of using the alternative migration assumptions, the allowances for second homes and the illogical housing market uplift. Should a higher figure be required to cater for the "Plymouth Growth Agenda" then this should be used only in Plymouth and the Plymouth Fringe allocations.
Should a lower total figure for housing need be used across the HMA, the 5 year land supply will be more likely met and a lower need for housing allocations will be required in the towns and local centres in the South Hams.
Distribution of houses across the HMA
If the forecast number of dwellings are to cater for a "Plymouth Growth Agenda" then we think that a larger proportion of the dwellings should be allocated to Plymouth and the Plymouth Fringe.
Increasing the numbers in the areas further away from Plymouth will only serve to increase commuting, something that is contrary to the objectives of the NPPF. It will also place extra traffic on roads for the upgrading of which there appears to be no provision. The A379 between Kingsbridge and Torcross is already very congested and the proposed development of 93 houses in Chillington would put even more strain on it. The plan seems to envisage development on four car park sites without providing alternative places for parking, which is also likely to create future problems with unintended consequences.
Provision of housing for people currently living and working in the district must be the first priority of the local plan. New dwellings must be in places where there is adequate infrastructure, where commuting distances are short and, most importantly, where they will be sold at a price that local people can manage. Proposals for housing development in Salcombe and the coastal region should be unacceptable on all of these grounds. The plan should stipulate a minimum percentage of affordable houses to be provided in any development of more than five dwellings, together with a test which ensures affordability into the future.
for the South Hams Society