Agenda item

The government published a consultation paper seeking proposed changes to the planning system that it believes will help meet the objectives set out in the Housing White Paper, published at the end of last year.

In addition to the proposals themselves, the government has also published indicative housing need figures for every planning authority in England – these being based on their proposed methodology.  The figure they have indicatively identified for Epsom & Ewell is significantly higher (39%) than the scale of need identified in our own evidence.  These matters are of concern.

The report includes draft comments that could form the basis of the Council’s response to these proposals

The Committee:

(1)          Considered the draft comments to the government’s proposals and, subject to the amendments discussed at the meeting, agreed that these forms the basis of the Council’s response to the consultation.

(2)          Agreed that the Borough Council’s formal response to the consultation be published as part of the current Local Plan consultation process in order to inform local residents and communities of the fact that the government is driving the scale of growth proposed for Epsom & Ewell. 

Note: For clarification, the Borough’s current housing target is 181 new homes per annum: the Borough Council’s objectively assessed housing needs calculation identifies demand for 418 new homes per annum, whilst the government’s figure raises that assessment to 579 new homes per annum.

The government had published a consultation paper seeking proposed changes to the planning system that it believed would help meet the objectives set out in the Housing white paper, published at the end of 2016.  The proposals included a standard national methodology for calculating the Borough Council’s objectively assessed housing need which when applied produced a figure of 579 new homes per annum compared to 418 new homes, the scale of need that was identified through the Council’s own evidence.

The Committee was asked to consider a report detailing a draft response to the government’s consultation which was to be published as part of the current Local Plan consultation process.

The government’s formula for assessing housing need was discussed in comparison to the Council’s formula and the Committee were informed that the government’s simplified formula utilized far less data to calculate the figure, in essence:

Local housing need = (1+adjustment factor) x projected household growth

It was noted that the figure of 579 homes calculated using the above formula could not be revised downwards by applying evidence produced for the Council’s Local Plan, and whilst it was likely that the figures would be revised every five years, the ‘one size fits all’ approach where specific local constraints could not be factored in would result in an unviable housing need figure for the Borough.

The scope to transfer part of the requirement for new homes to other boroughs was discussed and it was noted that the Council had a duty to cooperate with neighbouring boroughs.  However whilst we were required to demonstrate that discussions on cross boundary strategic issues had taken place, it was likely that our neighbouring boroughs were in the same position as Epsom & Ewell, namely that our neighbours also have a limited supply of available housing sites and will not be able to meet their own housing needs.  In order to address the shortcomings of the current policy of Duty to Cooperate the government were proposing that local authorities pursued a ‘statement of common ground’ instead with the aim to provide a road map and a record of cross-boundary co-operation. To that end, it was noted that the Council were already in discussion with its three Housing Market Area partners (Elmbridge, Kingston and Mole Valley) in conjunction with whom the borough’s original objectively assessed housing need was calculated, to agree an approach which would likely exceed that being handed down though this current consultation.  It was noted that it was important to provide evidence to the Planning Inspectorate that other boroughs had been consulted, in order to minimise the risk of intervention.

It was subsequently agreed to add a comment to the question 9 response as follows:

‘However the Borough Council notes that while the use of a limited number of statements of common ground between authorities that collectively comprise a HMA may be logical, a more extensive usage may ultimately prove onerous.  The Borough Council understands that the DCLG envisages scenarios where neighbouring and related local planning authorities potentially become signatories of multiple statements of common ground.  Such an approach is not welcomed.’

With regard to the subject of neighbourhood planning referred to in question 11, it was agreed to amend the first part of the response to more accurately reflect the facts, as follows:

‘In Epsom and Ewell to date there has been no interest in bringing forward a neighbourhood plan, however the borough has been a residents association lead council since established in the 1930s and, as such, embodies the principles of true localism.’

Regarding the process to ensure that infrastructure providers, including housing associations were engaged throughout the exercise, it was agreed to amend the response to question 15, as follows:

‘…The Government should place a legal/mandatory requirement upon providers to engage with the local planning authority.

With regard to the required contributions to affordable housing that developers were obligated to make, the Committee discussed the current viability schemes which were regarded as unsatisfactory by the Council, and ‘claw back’ arrangements that to date Planning Inspectors had taken a hard line against local authorities implementing.  As part of the decision making process for local planning applications it was common practice to add a condition regarding the claw back process, and the possibility of including a viability statement in the Local Plan was discussed.  It was agreed that officers would consult with the legal team and respond by email to members of the committee by Friday 3 November.

It was also agreed to add more detail to the response in question 12 to include more of the information included in the response of question 16.

Three further minor amendments were identified as follows:

It was also agreed that the Borough Council’s formal response be the subject of a press release as well as being published on the Council’s website.

Accordingly, the Committee:

(1)            Considered the draft comments to the government’s proposals and, subject to the amendments detailed above, agreed that these form the basis of the Council’s response to the consultation.

(2)            Agreed that the Borough Council’s formal response to the consultation be published as part of the current Local Plan consultation process in order to inform local residents and communities of the fact that the government is driving the scale of growth proposed for Epsom & Ewell.