The Local Plan Inquiry will take place this summer under the supervision of a Government Inspector to approve Telford & Wrekin’s Local Plan.
Local Conservatives, under Leader Andrew Eade, do not agree with the number of houses proposed and will be taking part in the Inquiry and have requested to have a speaker there to put their case.
They have produced a very comprehensive report detailing their concerns regarding the amount of housing proposed by Labour.
T&W Conservative Group of Councillors Comments on the Published Version of The Local Plan
Policy HO 1
Housing requirement
The Council identifies a borough wide plan target of 15,555 net new dwellings up to 2031.
5.1.1.4 – “The housing requirement set out in Policy HO1 is higher than the objectively assessed needs identified in the Telford & Wrekin Objectively Assessed Housing Need report by Peter Brett Associates (March 2015), which identified an overall housing need of 9,940 dwellings up to 2031. The housing requirement is therefore not solely based on the overall housing need. It also allows for additional development of an appropriate scale, nature and location which will support delivery of the overall plan vision and growth strategy, including supporting the delivery of affordable housing. Further, the requirement also recognises Telford & Wrekin's key role as an Urban Powerhouse within the Marches Local Enterprise Partnership and as a competitive inward investment destination.”
Comment: -
The “Telford & Wrekin Objectively Assessed Housing Need” (OAN) report commissioned by the Authority was undertaken by Peter Brett Associates in March 2015. The report identified the Borough’s housing need to be 9,940 dwellings over The Plan period. (2011 - 2031)
The OAN further states that this housing figure is compatible with “a healthy economic future” and commensurate with the creation of 17,000 new jobs in the Borough during the plan period. This figure for the creation of new jobs over The Plan period is in line with national (Experion) forecasts.
However, the local Authority are proposing a figure of 15,555 new homes over The Local Plan period which will provide an additional 5,615 new homes, a figure which is approximately 50% above established need. This figure is above and beyond additional housing growth and is considered excessive over provision, and wholly unnecessary to support forecast employment growth. As such, the Local Plan’s suggested housing growth is unsustainable.
In addition to The Local Plan proposal of 15,555 new homes during the lifetime of the plan (15 years), other sites, including ‘windfall’ sites in both urban and rural areas, will increase this number further and place additional pressure to create sustainable employment.This will also put undue and unnecessary pressure on Greenfield sites across the Borough.
5.1.1.5 – “The Council has prepared a 'Housing Growth' Technical Paper, which draws together relevant technical evidence, takes account of the comments received during the previous consultation stages of the emerging Local Plan, and other obligations such as the Council's Duty to Co-operate with neighbouring local authorities.”
Comment: -
The over provision of new homes as set out in Policy HO1 has been recognised by neighbouring Authorities of Shropshire, Birmingham and the Black Country: -
Duty To Co-Operate Technical Paper January 2016
7.33 – “To coincide with the Regulation 18 consultation, Birmingham City Council confirmed that it did not object to the proposed housing and employment growth targets in the Local Plan but suggested that some of the in migration to meet the housing requirement in the Local Plan is likely to come from the Black Country which forms part of the Greater Birmingham Housing Market Area which, in turn, has a shortfall in housing provision.”
7.35 – “The Black Country authorities were consulted on the Local Plan. They did not object to it but, rather, made comments relating to the projected level of housing growth set out in Policy HO1. They stated that the extra housing planned for over and above the Objectively Assessed Need (5,615 homes) be assigned to the Greater Birmingham and Black Country HMA.”
7.37 - “On this matter, South Staffordshire Councilhave, similar to the Black Country, suggested that the Council assign all the extra housing planned for over and above the Objectively Assessed Need (5,615 homes) be assigned to the Greater Birmingham and Black Country HMA”
The result of the stated over provision of 5,615 new homes, plus additional windfall sites etc, is likely to result in an inward migration which will result in the Borough of Telford & Wrekin becoming, in part, a dormitory or ‘commuter town’ with residents of the borough travelling to work outside of the borough.
The figure of 15,555+ new homes is not founded on a robust or credible evidence base as it lacks testimony due to its dependency on an assumptive strategy. The Borough wide target of 15,555+ new dwellings threatens the credibility of the plan as it is inconsistent with the NPPF’s core strategy in achieving positive growth and sustainable development as per Paragraph 7.
Paragraph 14 of the NPPF states that Local Plans should meet objectively assessed need. As the Local Plan is proposing substantial over provision in relation to actual need, it cannot therefore be deemed an appropriate strategy as it is not consistent with National Policy or our Local Policy SP4. By definition the Local Plan is not aligned to the principles of sustainable development.
CONCLUSION: -
FOR THE ABOVE REASONS, POLICY HO 1 – HOUSING REQUIREMENT IS CONSIDERED TO BE UNSOUND AND INCONSISTENT WITH BOTH LOCAL AND NATIONAL POLICY
Policy EC 1
Strategic employment areas
The Council recognises the importance of the strategic employment areas throughout the borough. The areas, as shown on Map 2 and the Policies Map, are expected to deliver B Use Classes along with similar industrial uses and ancillary uses.
It is anticipated a minimum addition of 76 hectares of employment land will be required to be delivered over the lifetime of the Local Plan. To meet this need, the sites shown on the Policies Map and listed in Appendix B are allocated for employment uses to meet the needs of the employment sector within the borough.
To meet the stated housing over provision and achieve sustainability, the Borough must create an additional 6,700 new jobs over The Plan period which is 40% above and beyond national forecasts and that suggested by the OAN for“a healthy economic future.”
This excessive target for job creation is made more difficult as a consequence of Telford & Wrekin’s geographical location with regard to the West Midlands Combined Authority (WMCA) and the ‘Birmingham Power House’ with which it will have to compete.
Also, an additional difficulty exists in that the borough has a high proportion of jobs in the manufacturing sector; 17% of all jobs compared to 8% nationally. This is a sector which is losing jobs rather than gaining them. Losses, therefore, must be ‘made good’ in addition to the creation of new jobs to provide a sustainable level of employment which broadens the diversity of opportunity.
As a consequence, the actual figure of additional new job creation required to maintain sustainability against the proposed inflated housing growth of 15,555+ will need to be even higher the 6,700 new jobs already mentioned. This is of course on top of the 17,000 new jobs originally quoted by the OAN to meet a housing figure of 9,940 new dwellings.
Therefore, we run the risk of jeopardising the effectiveness of the Local Plan as the inherent danger with the Plan’s inflated housing target is that the lack of matching jobs will cause a serious imbalance which could result in either: -
a) Allocated building land not being taken up.
b) Housing remaining empty or hard to sell, thus prompting a downturn in the local property market with a matching reduction in equity in homeowner’s property, thus damaging wealth creation in the Borough.
c) Occupiers, without local jobs, being compelled to commute out of the Borough to find work in neighbouring areas such as WMCA, which is clearly unsustainable and does not comply with the NPPF.
4.1.1.2 - “A key part of the vision of the Local Plan is to make the borough a more prosperous place with new development. The vision aims to realise the economic potential of the borough. To deliver this the Council has recognised a minimum requirement for 76 hectares of employment land over the lifetime of the Local Plan until 2031. This growth will help facilitate and sustain the additional housing being delivered in the Local Plan.”
The reduced forecast requirement for the supply of employment land from a minimum of 110ha to 76ha in The Local Plan is incompatible with supporting the 15,555+ housing growth figure and potential reduction in manufacturing jobs.
CONCLUSION: -
FOR THE ABOVE REASONS, POLICY EC 1 – STRATEGIC EMPLOYMENT AREAS
IS CONSIDERED TO BE UNSOUND
General Comments
We believe that the ‘Super Growth’ option proposed by T&W Council in their Published Local Plan is ill conceived, unachievable and unsustainable when considered against requirements and core principles of the NPPF.
We are disappointed that not all of our concerns and proposals included in our initial submission for the Authority’s Local Plan has been given due weight and incorporated into the final published version.
As a result, we do not consider that the Authority’s proposals fully comply with policy as set out in the NPPF and are not considered to be ‘sound.’
On behalf of the Conservative Group*, we wish
to register one Member to speak at the Inquiry.