MATTER 2 HOUSING AND EMPLOYMENT REQUIREMENTS … Hallam Land Mgt Matter 2.pdfHousing and Employment Requirements (Core Policy CP2) Hallam Land Management (Savills) (R62) (David Lock

Hallam Land Management

For and on behalf of Hallam Land Management

MATTER 2 HOUSING AND EMPLOYMENT REQUIREMENTS (Core Policy CP2)

Prepared by

Roland G Bolton

Strategic Planning Research Unit DLP Planning Ltd

February 2014

Prepared by:

Roland Bolton

Approved by:

Roland Bolton

Date: February 2014

DLP Planning Ltd 11 Paradise Square Sheffield S1 2DE Tel: 0114 228 9190 Fax: 0114 272 1947

DLP Consulting Group disclaims any responsibility to the client and others in respect of matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence. This report is confidential to the client and DLP Planning accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. As such party relies upon the report at their own risk.

Housing and Employment Requirements (Core Policy CP2)

Hallam Land Management (Savills) (R62) (David Lock Associates) (R75)

\\Dlpsheffield\sheffield job files\Gloucestershire\N-GL113-1\DLP_Matter2_HousingEmployment_Stroud v3.docx 3

HOUSING AND EMPLOYMENT REQUIREMENTS (Core Policy CP2)

HOUSING REQUIREMENTS:

The Plan proposes to provide at least 9,500 dwellings (2006-2031), including at least 2,450 new dwellings on strategic and other sites (2013-2031).

a. How has the Council undertaken an objective assessment of housing requirements for the relevant housing market area based on a sound analysis of the relevant evidence?

1.1 The approach taken is summarised in the February 2014 Background Paper this quotes the recommendation of Dr Woodhead (paragraph 3.8 PS/B10) which supports the use of a single target rather than the range it is pertinent to note that during his analysis that leads to this recommendation Dr Woodhead does not address

a. The requirement of the Framework requirement to significantly boost the supply of housing this is not referred to in either of his reports – this is important as the level he proposes is the same as average over the last 20 years

b. Dr Woodheads consideration of the 2011 Household Projections (CDB8) which is used to support his recommendation for the lower figure in the range does not take into account the fact the 2011 projections reflect the result of historic under-supply and worsening affordability of housing in the previous decade. It is noted that in their advice concerning the choice of assumptions for objectively assessing housing need the Cambridge Centre for Housing and Planning Research state that:

Given that the 2011 census results are a snap-shot taken after a period of severe economic and housing market volatility, it would be reasonable to expect that the numbers of households that formed in the years running up to the census were significantly below the long term trend.

1.2 The “Objectively Assessed Need for Housing” report by the Strategic Planning Research Unit at DLP (appendix 1) does model the impact of the 2011 Sub National Population Projections to 2031 by holding constant the last year of migration in these projections at 2021 for the period 2021 to 2031. The projection also allows a recovery from the suppressed levels of household formation back towards long term trend (the 2008 household representation rates by 2031). This would suggest a demographic projection the 11,145 dwellings for the period 2011 to 2031 would be in accordance with the Framework. (appendix 1 table 16 - 2011 interim SNPP (2011/2008HHRR) last year Mig PA adjustment).

b. Does the Plan fully meet the objectively assessed needs for market and affordable housing within Stroud district over the Plan period, along with any unmet housing requirements from neighbouring authorities; and are there any adverse impacts of fully meeting objectively assessed housing needs which would significantly and demonstrably outweigh the benefits when assessed against policies in the NPPF, including any development constraint policies?

1.3 No




1.4 For the reasons set out in the report in appendix 1 the dwelling requirement is set too low.

1.5 The SA Options Appraisal Report (January 2013) considered the distribution of 3,250 additional dwellings (SA January 2013 paragraph 2.1.4) although a number of strategies considered the impact of the same level of development in different locations:

a. Strategy A - 2,000 dwellings concentrated at either Cam, Eastington, Sharpness or west of Stonehouse.

b. Strategy E – Rural Combination Strategy considered the impact of a 1,000 dwellings at six different locations and

c. Strategy H – Hybrid Strategy of A, B and D actually considered the impact of up to 4,000 dwellings (SA January 2013 paragraph 5..9.1)

1.6 The conclusion of the SA Options Appraisal Report (6.1.1) as that in sustainability terms there are both benefits and disbenefits to the approaches of concentrating and dispersing development and that a combined approach such as Strategies E or H, which have elements of both a concentrating and dispersing approach, would be most favourable. None of the assessment highlighted that there were any impacts that were so server which would prevent the levels of dwellings being proposed at the various settlements.

1.7 Table 11.2 of the SA (Sept 2013) provides a summary appraisal of the broad spatial strategy alternatives. This table appears to suggest that options 4 and 5 would provide for the higher level of housing of 11,500 dwellings.

1.8 It is noted that option 4 which promotes 11,500 dwellings including development on the edge of Gloucester delivers more significant positive benefits than any other option (SA pages 79 to 87) and these significant positive benefits include:

a. Community and wellbeing,

b. Economy and employment,

c. Housing,

d. Transport and accessibility

1.9 There is only one significant negative effect predicted on the loss of greenfield. This is due to the quantum of housing being provided and there is no alternative location suggested for these dwellings which would not require a similar level of greenfield release.

1.10 In terms of the impact it is noted that options which provide housing on the edge of Gloucester has been considered to have a potential negative impact because there are air quality issues in Gloucester although these are not adjacent to the potential location of development. This appears to be a counter intuitive finding as it is clear wherever new development is located there will continue to be commuting and other movements into Gloucester as such locations which allow the present public transport system to extend easily and cheaply into a new neighbourhood would actually likely to have a greater positive impact on air quality issues.

1.11 In light of the evidence I would invite the inspector to conclude that a higher level of dwelling provision is not to be constrained in terms of the scale of the likely adverse impact. I would further invite him to conclude that the provision of 11,500 dwellings




including provision on the edge of Gloucester would deliver significant positive benefits when considered across all aspects of sustainability.

c. What is the basis, justification and methodology for the proposed level of housing provision, and are the assumptions robust and justified:

i. Does it have sufficient regard to the supporting and other relevant evidence, including the various SHMAs & SHLAAs;

1.12 There is no coherent explanation as to why a level of housing provision of 380 dwellings a year can be reasonably considered to represent the “objectively assessed need” in the context of the Framework. The fact that it is described as a “minimum” is an implicit acceptance that the actual level of demand may exceed this level of provision.

1.13 Constraints to development should not be taken into account in terms of determining the objectively assessed need (Hunston High Court Decision Appendix 1 page 30). The results of the SHLAA are only relevant if the district is considered to be significantly constrained and there is no evidence in the SA that this is the case.

ii. Does it take account of recent population and household projections, including the 2008-based population/household projections, 2010/2011-based ONS population projections and DCLG 2011-based interim household projections;

1.14 No.

1.15 Dr Woodhead rejects the 2008 Household projections out right as being “clearly out of date” (CDB8).

1.16 Dr Woodhead states in paragraph 3.54 that the evidence suggests that, in Stroud’s case at least, the 2010 based SNPP provides the most realistic current population projection.

1.17 Table 1 and 2 in appendix 1 (page 32) highlight that the 2010 SNPP have the lowest level of migration assumptions of all recent DCLG projections with the recent 2011 interim SNPP suggesting a higher level of net migration. The reason that the 2011 DCLG household projections appear similar to the 2010 Keith Woodhead projections is because the DCLG projections have a higher level of migration and they assume different household representation rates which reduce the number of dwellings required by the population. The changes to the DCLG assumptions are set out in the chart below:




Chart 1: DCLG migration assumptions for official SNPP

Source DCLG

iii. How does it take account of the inter-relationship of Stroud with the wider housing market area, including Gloucestershire/ Gloucester/ Cheltenham / Tewkesbury, and how does the Plan effectively address cross-boundary housing issues, in line with national policy (NPPF; 178-182); is the proposed review of the Local Plan in Policy CP2 an appropriate way of addressing the possible need to make provision for unmet future housing needs from surrounding areas?

1.18 The SA took into account the impact of providing development on the edge of Gloucester and found the options including development in this general location added to the higher level of dwelling provision (11,500) to provide the most significant positive benefits of all options (SA appendix 2 pages 79 to 87) .

1.19 Table 7 and 8 (appendix 1 page 44) suggest that there are strong economic links between the district and Gloucester in terms of travel to work patterns and the table below indicates that there are large migration inflows from a number of locations both within the HA (like South Gloucestershire and Gloucester) as well as from outside of the HMA like Bristol.




Table 1: Top flows into area STROUD 2010-11 inflow: number of people Gloucester 780 South Gloucestershire UA 360 Bristol, City of UA 300 Cotswold 290 Cheltenham 260 Wiltshire UA 160 Tewkesbury 150 Forest of Dean 110 Bath and North East Somerset UA 70 Cardiff 70 Plymouth UA 60 Swindon UA 60 Cornwall UA 60 Birmingham 50 Wychavon 40 North Somerset UA 40 Leeds 30 Warwick 30 Malvern Hills 30 Camden 30

iv. How does it take account of other key economic and social factors, including the employment strategy and the need to provide affordable housing (SHMA 2013 estimates a need for 578 affordable dwellings/year)?

1.20 There is a clear disconnect between the author of the report on the objectively assessed need and the aspirations expressed in the plan in terms of the future level of employment growth. This is set out in paragraphs 3.53.5 to 3.53.9 and rejects Cambridge Econometrics LEFM model used by Gloucestershire CC on the grounds it shows identical rates of growth 2006-26 as those produced by CE in 2008 for the RSS on a pre-recession trend (page 42). It goes on to state that the employment projections DLP used i.e. Cambridge Econometrics and Oxford Economics are “highly questionable”. I would strongly disagree that the work of these two well respected organisations is highly questionable as over my 30 years of presenting similar evidence I have found that the results from these organisations to have been acceptable as evidence. Likewise the Chelmer model is a recognised model for undertaking such scenario testing. There is no similar pedigree for the methodology being advanced to justify the approach presently taken to justify the level of housing being put forward by the council.




1.21 Of particular concern is the complete disconnect between the employment policies (apparently based upon “highly questionable” evidence according to CDB7), the affordable housing requirement and the objectively assessed need. According to paragraph 159 of the Framework these matters should be considered together in a single document for the whole of the HMA.

1.22 In respect of the Draft 2013 SHMA, Figure 5.1 and 5.2 set out the calculation of the 578 affordable dwellings a year. This figure is translated to a different level of requirement in the appendix page 210 as follows:

The housing needs assessment model requirement does not equate logically with the planned new homes per year in the Authority area. This is because the CLG needs assessment model is a technical exercise that presents an assessment of the requirement for affordable housing. This brief section considers the impact of changing two of the assumptions used in the model to help rationalise what is a very large figure, however it is not suggested that the figures used in this section are reflective of the real level of housing need.

1.23 On page 211 the draft SHMA explains that by adjusting the affordability threshold to 35% of gross income on rent (which better reflects the prevailing market conditions in Stroud) then there would be 84 fewer households in gross need each year. Furthermore if the private rented sector via LHA is considered to represent a supply to meet the housing need then the gross annual supply increases by 390 dwellings. The impact of changing both of these assumptions is that the need for new affordable units reduces to 104 per year.

1.24 It is important to note in relation to the lower figure the SHMA states:

The figure of 578 remains the overall need figure, because it is calculated in accordance with the approach set out in the Practice Guidance and is therefore comparable with historical estimates and figures derived elsewhere. The additional analysis is provided for illustrative purposes and it is not implied that the need is in fact just 104, or indeed has fallen recently. The figure of 578 remains the absolute level of housing need.

1.25 Given the clear guidance in paragraph 159 of the Framework as to the role of the SHMA and the need for there to be a consistent evidence base there would appear to be a significant disconnect between this document and the Objectively Assessed Need which has been calculated separately (a point made on a number of occasions in the SHMA). The next section of the SHMA rescales the calculated need back to provide a total is effectively repressed in order to conform to the selected level of dwelling supply. This is not a sound approach.

1.26 In light of the above there appears to be a concern amongst the Council’s own consultants as to the reliability and compatibility of the evidence base.




d. Various alternative estimates of housing requirements have been put forward. Should the Plan make provision for a higher or lower housing requirement, and if so, what is the justification for such an alternative figure and what alternative approaches and methodologies should be used to establish housing requirements?

1.27 The “Objectively Assessed Need for Housing” report by the Strategic Planning Research Unit at DLP (appendix 1) has utilised the nationally recognised ‘Chelmer model’ which is a variant of the official government projection methodology and is identified as an appropriate tool for determining future housing requirements in the Communities and Local Government Strategic Housing Market Assessments Practice Guidance (Version 2).

1.28 The stating point of this approach is the 2011 interim SNPP and the 2011 interim Housing Projections 2011 to 2021. However in this case there is credible evidence to suggest a departure from this figure in order to respond appropriately to the Framework. This evidence suggests that the basic projection of 409 dwellings a year needs to be adjusted upwards for the following reasons:

a. It is not considered appropriate to extend the household representative rates in the 2011 interim household projections throughout the whole of the plan period. These suggest low rates of household formation for the under 35’s, which is not considered to properly reflect the Framework’s requirement (paragraphs 50 and 159) to widen the opportunity for home ownership. A policy decision to provide sufficient housing to accommodate the increase in the household representation rates back to the 2008 rates in order to meet these aspirations is an appropriate policy response to the requirement of the Framework. This would suggest a housing requirement of about 560 dwellings a year (11,200 for the period 2011 to 2031).

b. In SPRU’s assessment (appendix 2 page 68) the level of dwelling proposed will not provide for any increase in the labour force in the remainder of the Plan period this considered incompatible with the Framework. The dwelling requirement should be compatible with the employment projections and the stated employment aspirations of the plan. A modest increase in the available labour force for the period from 2011 is considered to be a more appropriate response to the evidence. Even maintaining the lower headship rates and increasing economic activity of the 60 to 69 age groups there would be a requirement for between 510 and 880 dwellings a year to meet the range of job forecasts of between 2,200 jobs to 5,200 jobs in the period 2011 to 2031. The highest of these figures is based upon the Oxford Economics forecast in (paragraph 10.13 Employment Land Study Stroud District Council) while maintaining the existing pattern of net out commuting while the lower projections match the Cambridge Econometrics job growth (appendix 1 page 58). It is noted that previous inspectors have found little evidence to justify assumptions that change existing patterns of commuting (South Worcestershire and Vale of Aylesbury Plan Inspectors letters)




c. The level of housing proposed of 376 dwellings per year will not address the issue of affordability, high mean house prices and the high affordability ratio (Appendix 1 pages 51 7 52). While the Practice Guide suggests that the Strategic Housing Market Assessment (SHMA) should address the impact of the chosen policy on affordability there appears to be no background evidence that addresses this matter. The Draft Planning Practice Guidance (appendix 1) would suggest that when considering the objectively assessed need then provision above the trend based projections would be justified to address the issue of affordability.

d. The level of housing proposed, 376 dwellings per year would also suggest that the area is to accommodate fewer migrants than the nationally consistent projections are expecting and as such this lower level of housing provision may have implications for the surrounding parts of the Housing Market Area (appendix 1 section 4 page 48).

e. Given the evidence of emerging undersupply in locations which export migrants into Stroud (appendix 1 pages 45 & 46) it would be inappropriate to conclude that past rates of migration into the District will remain close to previous levels. There is a strong indication that the rest of the region as well as the West Midlands and especially the South East are likely to significantly undersupply housing. As this under provision has not been modelled in the CLG projections then the resulting levels of out migration from these areas have been under represented. It is therefore appropriate for the Local Plan to assume higher levels of in migration from these regions. The general approach in the rest of the South West would also seem to be one of undersupply as such it is unlikely that the District can offset higher levels of in migration with higher levels of out migration to the rest of the county or the wider Region.

1.29 Taking these considerations into account it is was suggested in this report that a dwelling requirement of around 560 dwellings a year would be a more appropriate requirement. This would require some 11,200 dwellings for the period 2011 to 2031. It was recognised that this level of provision was below the requirement that would be required to meet the higher forecasts for new jobs especially if account is taken of the existing pattern of commuting, the potential for improved access to housing for the under 35 age groups or the higher rates of vacancy assumed by the Council and suggested by the 2011 census.

The Requirements of the Framework in Scenario testing 1.30 I would argue that the Framework does provide an appropriate background against

which to approach the choice of assumptions as part of the objective assessment of needs for housing. The following sets a clear framework in which to approach and take these decisions:

a. The objective is to provide a supply of housing to meet needs of both this and future generations (paragraph 7);

b. There is also the requirement to increase the opportunity for home ownership based upon not just current but also future demographic trends, market trends and the needs of different groups in the community (paragraph 50);




c. The planning system does everything it can to support sustainable economic growth. Planning should operate to encourage, and not act as an impediment, to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system (paragraph 19).

d. Finally the general approach is for plans to be positively prepared.

1.31 These principles should not be applied to the outcome of the projections but should inform the choices of assumptions made as part of the process of modelling the objectively assessed need. The consequence of applying these principles to the modelling process are as follows:

a. Where there is a choice of reasonable alternatives regarding the future propensity of persons to form households then the requirement to increase the opportunity for home ownership and plan positively requires one to choose the more favourable assumption that would allow more, rather than less, persons to form their own households and achieve home ownership (Framework paragraphs 7 and 50).

b. Where there are a number of reasonable projections of future employment growth then one should plan to accommodate the highest of these projections as to fail to do so might actually contribute to these higher levels of growth not being achieved (Framework paragraphs 14 and 19).

c. As confirmed in the Hunston decisions, once an objectively assessed need has been arrived at following these principles, then the housing requirement maybe set at less than the need if:

i. Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole; or specific policies in this Framework indicate development should be restricted and

ii. The Council has engaged the duty to cooperate (Framework paragraphs 178 to 181) so that these needs are met elsewhere so as to fulfil the core principle of the delivering the homes the country needs (paragraph 17).

1.32 In light of the above I would reject the approach taken by the council in its approach to define the objectively assessed housing needs as it provides only a very limited opportunity for those persons excluded from housing during the decade of the growing housing crises to enter the property market. I would also argue that simply tracking the long term rates means that future housing provision will constantly lag behind these long term rate by the same amount all the way to 2031.

1.33 In contrast I am of the opinion that not only is effective demand returning to the housing market but that those who have been excluded from the market by past conditions as well as those entering into the age of potential home ownership are not wishing to offset their housing aspirations for a decade or more as implied by the 2021 interim projections.

1.34 I therefore consider that the use of a household representation rate that simply tracks the long term trend but does not make any attempt to return to this rate effectively builds under provision and exclusion in long term. Such an assumption while a reasonable option in terms of a statistical approach the assumption does not fulfil the requirements of the Framework, in particular paragraph 17 meeting the housing needs of the country, or increasing the opportunity for home ownership.




1.35 In respect to meeting the needs of the economy it is important that the level of housing proposed does not impede economic growth and recent decisions support this approach. In finding the Vale of Aylesbury Plan unsound the inspector stated (paragraph 37 of letter):

In simple terms there is a clear and substantial mismatch between the level of housing and jobs planned

1.36 In requiring additional work to be undertaken to address the issue of soundness the inspector at the South Worcester criticised the demographic approach to establishing the Objectively assed need as follows:

However, each of these scenarios is essentially trend-based and does not include the necessary additional step of factoring in the effect of future employment growth on in-migration.

1.37 In light of the above three additional scenarios have been undertaken two are employment led and the last is based upon the level of dwelling provision resulting from the Plan. The approach adopted makes the following assumptions:

a. It assumes, in accordance with market indicators, that the depressed rates of household formation contained in the 2011 interim projections will start improving from 2016 onwards (providing of course there is the increase in supply to accommodate this demand);

b. It assumes that there will be an adjustment back towards the long term trend from 2016 onwards so that the household representation rate (HRR) reaches the midpoint between the 2011 HRR and the 2031 HHR by 2031.

c. In terms of the modelling of economic activity rates I have taken into account both the changes that the ONS suggest have occur to 2011 and a further increase in the 60 to 64 age groups (2.5% for each of the two 5 year periods 2011 to 2021 and then held constant) and 65 to 69 age groups (5% for each of the two year periods 2011 to 2021 and then held constant)

d. That employment growth will be at least 3,800 jobs (Experian projection 2014 appendix 3).

e. That the commuting ratio will remain constant at 0.69 (workers/jobs)

f. A vacancy rate of 3% has been used rather than the higher rates used in the councils work.

1.38 The results of these projections, undertaken with the Chelmer model, are set out in Appendix 3 but suggest that the employment led projections are between 11,576 and 12,694 dwellings for the period 2011 to 2031.

1.39 This equates to between 579 and 635 dwellings a year compared to the residual build rate of just 376 dwellings in the plan.

1.40 There is no evidential background to suggest that the worker job ration maybe changed and therefore the higher to the two projections is preferred.

1.41 This approach takes a more positive approach to accommodating the obvious long term demand for household formation and, in some cases, home ownership to be accommodated. Such an approach would appear to be not only in accordance with the Framework but in my opinion required by it.




1.42 In light of the Framework, to plan positively would be to plan for the higher of these two projections.

1.43 While I recognise the risk of planning to meet economic projections which are liable to fluctuation, this risk is offset by the fact that if these projections are overly optimistic then the planned level of provision will provide for development for a further period beyond the end of the plan. This in itself is an advantage given the relative inflexibility of the UK planning system to respond to future change.

1.44 In light of these considerations I have a preference for an annual rate of 635 dwellings a year for the purposes of future long term planning, as it is more compliant with the aims and objectives of the Framework. In addition it provides flexibility to respond to changing markets. I consider the risks of planning for this level of housing are outweighed by the benefits of additional certainty provided by long term planning.

1.45 It is worth noting in passing that given the propensity for residents to work outside of the district then locating some of the difference between the two employment projections which can be attributable to this factor (in this case some 1,000 additional units) adjacent to, or on good transport links for, Gloucester as this is by far the most important commuter destination. I note that such an allocation has previously been considered in the context of the former RSS and appendix 3 highlights the sustainability of such an approach.

1.46 Further details of the input and outputs of the Chelmer model run are available on request.

e. What is the current and future 5, 10 & 15-year housing land supply position, in terms of existing commitments, future proposed provision, allowance for windfalls and other provision, phasing and housing trajectory; and how will the proposed housing provision (including market and affordable housing) be effectively delivered in terms of the strategic site allocations and other provision?

1.47 I note that at the recent appeals at Land off Elstub Lane, Cam, Dursley, (APP/C1625/A/13/2199963 & APP/C1625/A/13/2201703) this inspector rejected the councils approach to the calculation of the level of housing requirement as being untested. He also expressed concerns, as I have, regarding the 2011 interim household projections that they reflect recession and a stagnant economy. He therefore considered the five year requirement against both 2010 and 2008 based projections finding that there was a shortfall in the five year supply (paragraphs 22 and 25).

1.48 The “Review Of Stroud District Council’s Five Year Housing Land Supply” CDB6 suggests that in the next five years there may be in the region of some 2,215 dwellings completed a build rate of 443 dwellings which is only a marginal increase to that which has occurred in the past two years. Such a rate of anticipated completions while emerging from a recession would suggest that the 374 dwelling a year requirement is not an objective assessment of need.

1.49 The extent to which the supply represents a 5 year requirement is dependent upon the objectively assessed need which is arrived at. In terms of my recommended figure of 557 dwellings a year it would be just under a 4 year supply.

1.50 A further cause for concern is that even against the low requirement the trajectory in appendix 1 of CDB6 only meets or exceeds the annual requirement 3 times in the first five years and only 4 times in the period to 2026/7 highlighting in my view at least the




need for the release of additional land in the short term to meet the objectively assessed needs of the district.

f. How does the Plan address the need for a 5/20% buffer to 5-year housing land supply, as required by the NPPF (para 47) to significantly boost housing supply, and address any past shortfalls in provision of housing?

1.51 The plan does not propose to boost the supply of housing but simply to continue the same level of building as that which has occurred over the last 20 years.

1.52 Although the SHMA appears to identify a backlog of affordable housing need the approach to the objectively assessed needs assumes that the housing market in the district is currently in balance with no backlog of demand for either social or market housing.

1.53 In terms of whether a 5 or 20% buffer should apply this is dependent upon which target is used against the then adopted Structure Plan (1991 to 2011) requirement of 9,400 dwellings for Stroud (policy H2). This equates to 470 dwellings a year and this has only been achieved 6 times out of the last 20 years and as such the plan will need to address the 20% shortfall.

g. What alternative levels of housing provision have been considered, having regard to any significant and demonstrable adverse impacts of proposing increased levels of housing provision within Stroud district?

1.54 As set out above the SA failed to explicitly consider different levels of dwelling provision contrary to the guidance that accompanied the original European Legislation however as the strategies effectively assessed a number of alternatives within each strategy and identified no overwhelming negative impacts then there would appear to be no justification not to consider a combination of these strategies as a way of delivering a higher level of dwellings. The combination of strategies is actually suggested in the conclusions to the SA.




Appendix 1: The Objective Assessment of Housing Need




Contents Page 0.0 Executive Summary 17 1.0 Introduction 19

The purpose of this report 19 2.0 The Policy Background 20

National Planning Policy Framework (The Framework) 20 The National Planning Practice Guidance 22 Past decisions regarding issues of assessment of housing need and the duty to cooperate 28 Concluding comments on approach to objectively assessing housing demand and need 30

3.0 The evidence base and assumptions 32 The Sub National Population Projections (SNPP) 32 Commentary on the suitability of the 2011 household representation rates as contained in the 2011 Interim household projections as a basis for plan making 34 Economic and Employment evidence and assumptions 39 Migration 46 Vacancy Rates 48 Conclusion 49

4.0 Indicators of Market Demand and the Housing Market Area 50 The definition of the appropriate area to be covered by a SHMA 50 “The Geography of Housing Market Areas” (DCLG, 2010) 50 Evidence of need in the wider HMA 51 House prices and affordability 53

5.0 The conversion of SNPP to dwelling requirements using the Chelmer Model 55 Introduction 55 The modelled scenarios 56 The results of the scenario testing 59

6.0 Conclusion 68




0.0 Executive Summary 0.1 This report has been commissioned by Hallam Land Management Ltd to provide an

assessment of the approach that Stroud Council is taking towards planning for housing in the Pre Submission Local Plan for Stroud District.

0.2 The proposed level of housing in the Pre Submission Draft of the Local Plan of 9,500 dwellings between 2006 and 2031, which equates to 376 dwellings a year taking into account completions 2006 to 2011. This level of housing is below the latest 2011 Sub National Population Projections extended to 2031 which requires some 409 dwellings a year. The projection for 409 dwellings a year is itself based upon extending the lower household representation rates contained in the 2011 interim projections across the whole plan period.

0.3 If the suppressed household representation rates in the 2011 Interim Projections are assumed to return to the below long term trend rates of the 2008 household projections then the annual requirement based upon the 2011 Sub National Population Projections 2011 to 2031 raises to 557 dwellings per year or 11,145 dwellings.

0.4 It is recognised that the starting point for the level of dwelling provision should be the 2011 Sub National Population Projections 2011 to 2021. However in this case there is credible evidence to suggest a departure from this figure in order to respond appropriately to the Framework. This evidence suggests that the basic projection of 409 dwellings a year needs to be adjusted upwards for the following reasons:

a. It is not considered appropriate to extend the household representative rates in the 2011 interim household projections throughout the whole of the plan period. These suggest low rates of household formation for the under 35’s, which is not considered to properly reflect the Framework’s requirement to increase home ownership and therefore a policy decision to increase the household representation rates back to the 2008 rates in order to meet these aspirations as an appropriate response to the requirement of the Framework. This would suggest a housing requirement of about 560 dwellings a year (11,200 for the period 2011 to 2031).

b. It is considered incompatible with the Framework that the proposed level of dwelling provision does not provide for any increase in the labour force in the remainder of the Plan period. The dwelling requirement should be compatible with the employment projections and the stated employment aspirations of the plan. A modest increase in the available labour force for the period from 2011 is considered to be a more appropriate response to the evidence. Even maintaining the lower headship rates and increasing economic activity of the 60 to 69 age groups there would be a requirement for between 510 and 880 dwellings a year to meet the range of job forecasts of between 2,200 jobs to 5,200 jobs in the period 2011 to 2031. The highest of these figures is based upon maintaining the existing pattern of development while the lower projections match labour force growth to job growth.




d. The level of housing proposed of 376 dwellings per year will not address the issue of affordability, high mean house prices and the high affordability ratio. While the practice guide suggests that the Strategic Housing Market Assessment (SHMA) should address the impact of the chosen policy on affordability there appears to be no background evidence that addresses this matter. This evidence would suggest that when considering the objectively assessed need then provision above the trend based projections would be justified to address the issue of affordability.

e. The level of housing proposed, 376 dwellings per year would also suggest that the area is accommodate fewer migrants than the nationally consistent projections are expecting and as such this lower level of provision may have implications for the surrounding parts of the Housing Market Area.

f. It would not be appropriate to conclude that past rates of migration into the District will remain close to previous levels. There is a strong indication that the rest of the region as well as the West Midlands and especially the South East are likely to significantly undersupply housing. As this under provision has not been modelled in the CLG projections then the resulting levels of out migration from these areas have been under represented. It is therefore appropriate for the Local Plan to assume higher levels of in migration from these regions. The general approach in the rest of the South West would also seem to be one of undersupply as such it is unlikely that the District can offset higher levels of in migration with higher levels of out migration to the rest of the county or the wider Region.

0.5 Taking these considerations into account it is suggested that a dwelling requirement of around 560 dwellings a year would be a more appropriate requirement. This would require some 11,200 dwellings for the period 2011 to 2031. It is recognised that this is below the requirement that would be required to meet the higher forecasts for new jobs especially if account is taken of the existing pattern of commuting, the potential for improved access to housing for the under 35 age groups or the higher rates of vacancy assumed by the Council and suggested by the 2011 census.




1.0 Introduction 1.55 This report has been commissioned by Hallam Land Management Ltd to critically

consider the published background evidence supporting the proposed housing policies in the Pre Submission Local Plan for Stroud Council. In particular the report considers the proposed level of housing provision of 9,500 dwellings for the period 2006 to 2031, which is an average of 376 a year taking into account completions in the period 2006 to 2011.

The purpose of this report 1.56 This report is to provide a critique of the approach that Stroud District Council is taking

towards planning for housing. In particular it will consider:

a. The strength of the evidence to support the chosen level of housing provision at 376 dwellings a year; and

b. Evidence to support alternative levels of provision within Stroud.

1.57 This report has been produced to be submitted as part of the response to the consultation on the Pre Submission Local Plan for Stroud. It recommends an alternative level of provision is included in the Core Strategy to ensure that it is sound.

1.58 The issues raised in this report have been previously raised in DLP’s earlier report to the Council on the consultation on the Core Strategy titled “Population and Housing Report” (February,2012). Like the “Evidence Review Update” Keith Woodhead April 2013 this report also considers the new evidence including the 2011 Sub National Population Projections and the Interim Household Projections as well as the draft National Planning Practice Guidance. The report produces a number of projections using DLP’s Licenced copy of the Chelmer Model which is recognised by the government as a model suitable for such purposes.




2.0 The Policy Background

National Planning Policy Framework (The Framework)

The test of soundness 2.1 The approach that should be adopted to the preparation of a Local Plan is best

explained by the tests that the Inspector must apply during the Examination (Framework paragraph 182), which are that a plan should be:

a. positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

b. justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

c. effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

d. consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

2.2 The next section considers how each of the above points should be addressed in terms of the proposed policies including how the selected policies will deliver the required level of housing to meet the housing need, as required by paragraph 47 of the Framework, and setting the housing requirement.

Positively prepared 2.3 The 12 principles of the planning system identified in the Framework (paragraph 17)

which should underpin decision-taking include:

2.4 Planning should be genuinely plan-led, empowering local people to shape their surroundings, but that Plans should be kept up‑to‑date, and be based on joint working and co‑operation to address larger than local issues.

2.5 Planning should proactively drive and support sustainable economic development to deliver the homes that the country needs. The Framework requires that every effort should be made to objectively identify, and then meet, the housing needs of an area and take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking account of these needs.




2.6 The Government requires that Local Authorities should significantly boost the supply of housing (Framework - paragraph 47) and should use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area (Framework - paragraph 47), as far as is consistent with the policies set out in the Framework.

2.7 When considering alternative development scenarios the requirement for plans to be positively prepared requires that planning should act as an enabler rather than an impediment to sustainable growth (Framework - pparagraph 19) and that it should be proactive in meeting the needs of the economy. This means that decision makers and, more importantly, researchers generating scenarios should not plan for the most conservative levels of growth that maybe are justified from the evidence base or those scenarios that reflect a prolonged period of very slow economic recovery. Likewise, future planning decisions should not be based upon the exclusion of longer term aspirations regarding homeownership by many of the population or the long term repression of housing demand for the younger age groups.

Justified 2.8 This requires the strategy to be the most appropriate when considered against

reasonable alternatives and based upon proportionate evidence (Framework - paragraph 182).

2.9 The Framework identifies that the evidence base for the objective assessment of housing needs should be adequate, up to date and relevant (paragraph 158) and paragraph 159 states that local planning authorities should have a clear understanding of housing needs in their area. To do this they are, according to paragraph 159 of the Framework, required to:

• Prepare a Strategic Housing Market Assessment to assess their full housing needs, working with neighbouring authorities where housing market areas cross administrative boundaries. The Strategic Housing Market Assessment should identify the scale and mix of housing and the range of tenures that the local population is likely to need over the plan period which:

o meets household and population projections, taking account of migration and demographic change;

o addresses the need for all types of housing, including affordable housing and the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities, service families and people wishing to build their own homes); and

o caters for housing demand and the scale of housing supply necessary to meet this demand.

• prepare a Strategic Housing Land Availability Assessment to establish realistic assumptions about the availability, suitability and the likely economic viability of land to meet the identified need for housing over the plan period.

2.10 The Local Planning Authority should also have a clear understanding of business needs within the economic markets operating in and across their area (Framework - paragraph 160). To achieve this, they should (Framework - paragraph 60):




a. work together with county and neighbouring authorities and with Local Enterprise Partnerships to prepare and maintain a robust evidence base to understand both existing business needs and likely changes in the market; and

b. work closely with the business community to understand their changing needs and identify and address barriers to investment, including a lack of housing, infrastructure or viability.

Effective 2.11 For a plan to be effective the proposed allocations must be based upon realistic

assumptions regarding a site’s availability, its suitability and likely economic viability to deliver completions over the plan period (Framework - paragraph 160). This assessment includes a consideration of the timescale that will be required to deliver the necessary consent and legal agreements together with an assessment of likely build rates given the location and nature of the proposed development.

2.12 To be effective the Council also has to demonstrate it has met its statutory duty for local authorities to cooperate on planning issues.

2.13 Paragraphs 178 to 181 of the Framework sets out how this is to be achieved. Paragraph 178 states that public bodies have a duty to cooperate on planning issues that cross administrative boundaries, particularly those which relate to the strategic priorities set out in paragraph 156 of the Framework, including housing and migration. The Government expects joint working on areas of common interest to be diligently undertaken for the mutual benefit of neighbouring authorities.

2.14 Paragraph 181 of the Framework requires evidence to demonstrate effective cooperation to plan for issues with cross-boundary impacts when their Local Plans are submitted for examination. This evidence can consist of:

a. Preparation of plans or policies by a joint committee;

b. a memorandum of understanding; or

c. a jointly prepared strategy which is presented as evidence of an agreed position.

Consistent with national policy 2.15 Generally there is a requirement for the strategy to deliver sustainable development in

accordance with the Framework. This requires an assessment of the plan as a whole in terms of its ability to actually deliver sustainable development across all three dimensions of sustainability, social, economic and environmental.

The National Planning Practice Guidance 2.16 This guidance has been subject to consultation and it is worthwhile considering this

guidance as it is likely to be in place in an amended form at the time of the examination of the plan. The following are extracts from the guidance which deal with the assessment of housing need:

What is the definition of need? Need for housing in the context of the guidance refers to the scale and mix of housing and the range of tenures that is likely to be needed in the housing market area over the plan period – and should cater for the housing demand of the area and identify the scale of housing supply necessary to meet that demand.




Need for all land uses should address both the total number of homes …. needed based on quantitative assessments, but also on an understanding of the qualitative requirements of each market segment.

Any assessment of need should be realistic in taking account the particular nature of that area (for example geographic constraints and the nature of the market area). Assessing development needs should be proportionate and does not require local councils to consider purely hypothetical future scenarios, only future scenarios that could be reasonably expected to occur.

Can local planning authorities apply constraints to the assessment of development needs? The assessment of development needs is an objective assessment of need based on facts and unbiased evidence. Plan makers should not apply constraints to the overall assessment of need, such as limitations imposed by the supply of land for new development, historic under performance infrastructure or environmental constraints. However, these considerations will need to be addressed when bringing evidence bases together to identify specific policies within development plans.

Can local planning authorities use a different methodology? The use of this standard methodology is strongly recommended because it will ensure that the assessment findings are transparently prepared. Local planning authorities may consider departing from the methodology, but they should explain why their particular local circumstances have led them to adopt a different approach where this is the case. The assessment should be thorough but proportionate, building where possible on existing information sources outlined within the guidance.

Please note that there is no one methodological approach or use of a particular dataset(s) that will provide a definitive assessment of development need

How can housing market areas be defined? Housing market areas can be broadly defined by using three different sources of information as follows.

House prices and rates of change in house prices

Housing market areas can be identified by assessing patterns in the relationship between housing demand and supply across different locations. This analysis uses house prices to provide a ‘market-based’ reflection of housing market area boundaries. It enables the identification of areas which have clearly different price levels compared to surrounding areas. The findings provide information about differences across the area in terms of the price people pay for similar housing, market ‘hotspots’, low demand areas and volatility.

Suggested data sources:

Office for National Statistics, House Price Index, Land Registry House Price Index and Price Paid data (including sales), Department for Communities and Local Government Statistics including Live Tables on Affordability (lower quartile house prices/lower quartile earnings), Neighbourhood data from the Census.




Household migration and search patterns

Migration flows and housing search patterns reflect preferences and the trade-offs made when choosing housing with different characteristics. Analysis of migration flow patterns can help to identify these relationships and the extent to which people move house within an area. The findings can identify the areas within which a relatively high proportion of household moves (typically 70 per cent) are contained. This excludes long distance moves (e.g. those due to a change of lifestyle or retirement), reflecting the fact that most people move relatively short distances due to connections to families, friends, jobs, and schools.


Census, Office for National Statistics Internal Migration Statistics, and NHS registration data. Data from estate agents and local newspapers contain information about the geographical coverage of houses advertised for sale and rent.

Contextual data (e.g. travel to work area boundaries, retail and school catchment areas)

Travel to work areas can provide information about commuting flows and the spatial structure of the labour market, which will influence household price and location. They can also provide information about the areas within which people move without changing other aspects of their lives (e.g. work or service use).


Office of National Statistics (travel to work areas), retailers and other service providers may be able to provide information about the origins of shoppers and service users, school catchment areas.

What methodological approach should be used? Establishing future need for housing is not an exact science. No single approach will provide a definitive answer. Plan makers should avoid expending significant resources on primary research …. They should instead look to rely predominantly on secondary data (e.g. Census, national surveys) to inform their assessment which are identified within the guidance.

What is the starting point to establish the need for housing? Household projections published by the Department for Communities and Local Government should provide the starting point estimate of overall housing need.

The household projections are produced by applying projected household representative rates to the population projections published by the Office for National Statistics. Projected household representative rates are based on trends observed in Census and Labour Force Survey data.

The household projections are trend based, i.e. they provide the household levels and structures that would result if the assumptions based on previous demographic trends in the population and rates of household formation were to be realised in practice. They do not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour.




The household projection-based estimate of housing need may require adjustment to reflect factors affecting local demography and household formation rates which are not captured in past trends. For example, formation rates may have been suppressed historically by under-supply and worsening affordability of housing. The assessment will therefore need to reflect the consequences of past under delivery of housing. As household projections do not reflect unmet housing need, local planning authorities should take a view based on available evidence of the extent to which household formation rates are or have been constrained by supply. Can adjustments be made to household projection-based estimates of housing need? The household projections produced by the Department for Communities and Local Government are statistically robust and are based on nationally consistent assumptions. However, plan makers may consider sensitivity testing, specific to their local circumstances, based on alternative assumptions in relation to the underlying demographic projections and household formation rates. Account should also be taken of the most recent demographic evidence including the latest Office of National Statistics population estimates.

Any local changes would need to be clearly explained and justified on the basis of established sources of robust evidence.

Issues will vary across areas but might include:

migration levels that may be affected by changes in employment growth or a one off event such as a large employer moving in or out of an area or a large housing development such as an urban extension in the last five years

demographic structure that may be affected by local circumstances or policies e.g. expansion in education or facilities for older people

How should employment trends be taken into account? Plan makers should make an assessment of the likely growth in job numbers based on past trends and/or economic forecasts as appropriate and also having regard to the growth of the working age population in the housing market area. Any cross-boundary migration assumptions, particularly where one area decides to assume a lower internal migration figure than the housing market area figures suggest, will need to be agreed with the other relevant local planning authority under the duty to cooperate. Failure to do so will mean that there would be an increase in unmet housing need.

Where the supply of working age population (labour force supply) is less than the projected job growth, this will result in unsustainable commuting patterns and could reduce the resilience of local businesses. In such circumstances, plan makers will need to consider increasing their housing numbers to address these problems. How should market signals be taken into account? The housing need number suggested by household projections (the starting point) should be adjusted to reflect appropriate market signals, as well as other market indicators of the balance between the demand for and supply of dwellings. Prices or rents rising faster than the national/local average may well indicate particular market undersupply relative to demand. Relevant signals may include the following:




Land Prices

Land values are determined by the demand for land in particular uses, relative to the supply of land in those uses. The allocation of land supply designated for each different use, independently of price, can result in substantial price discontinuities for adjoining parcels of land (or land with otherwise similar characteristics). Price premiums provide direct information on the shortage of land in any locality for any particular use.

House Prices

Mix adjusted house prices (adjusted to allow for the different types of houses sold in each period) measure inflation in house prices. Longer term changes may indicate an imbalance between the demand for and the supply of housing. The Office for National Statistics publishes a monthly House Price Index at regional level. The Land Registry also publishes a House Price Index and Price Paid data at local authority level.

Rents

Rents provide an indication of the cost of consuming housing in a market area. Mixed adjusted rent information (adjusted to allow for the different types of properties rented in each period) shows changes in housing costs over time. Longer term changes may indicate an imbalance between demand for and supply of housing. The Office for National Statistics publishes a monthly Private Rental Index.

Affordability

Assessing affordability involves comparing house costs against the ability to pay. The ratio between lower quartile house prices and the lower quartile income or earnings can be used to assess the relative affordability of housing. The Department for Communities and Local Government publishes quarterly the ratio of lower quartile house price to lower quartile earnings by local authority district.

Rate of Development

Local planning authorities monitor the stock and flows of land allocated, permissions granted, and take-up of those permissions in terms of completions. Supply indicators may include the flow of new permissions expressed as a number of units per year relative to the planned number and the flow of actual completions per year relative to the planned number. A meaningful period should be used to measure supply. If the historic rate of development shows that actual supply falls below planned supply, future supply should be increased to reflect the likelihood of under-delivery of a plan. The Department for Communities and Local Government publishes quarterly planning application statistics.




Overcrowding

Indicators on overcrowding, concealed and sharing households, homelessness and the numbers in temporary accommodation demonstrate un-met need for housing. Longer term increase in the number of such households may be a signal to consider increasing planned housing numbers. The number of households accepted as homeless and in temporary accommodation is published in the quarterly Statutory Homelessness release.

How should plan makers respond to market signals? Appropriate comparisons of indicators should be made. This includes comparison with longer term trends (both in absolute levels and rates of change) in the: housing market area; similar demographic and economic areas; and nationally. Divergence under any of these circumstances will require upward adjustment to planned housing numbers compared to ones based solely on household projections. Volatility in some indicators requires care to be taken: in these cases rolling average comparisons may be helpful to identify persistent changes and trends.

In areas where an upward adjustment is required, plan makers should set this adjustment at a level that is reasonable. The more significant the affordability constraints (as reflected in rising prices and rents, and worsening affordability ratio) and the stronger other indicators of high demand (e.g. the differential between land prices), the larger the improvement in affordability needed and, therefore, the larger the additional supply response should be. Market signals are affected by a number of economic factors, and plan makers should not attempt to estimate the precise impact of an increase in housing supply. Rather they should increase planned supply by an amount that, on reasonable assumptions and consistent with principles of sustainable development, could be expected to improve affordability, and monitor the response of the market over the plan period. The list of indictors above is not exhaustive. Other indicators, including those at lower spatial levels, are available and may be useful in coming to a full assessment of prevailing market conditions. In broad terms, the assessment should take account both of indicators relating to price (such as house prices, rents, affordability ratios) and quantity (such as overcrowding and rates of development).

2.17 While it is accepted that the Guidance is draft it nevertheless suggests that the use of up to date projections as a starting point is important, and that there is an expectation that in response to the requirement of the Framework to consider market signals the Government is expecting Local Authorities to increase housing provision.

2.18 It also comments generally with regard to the issue of the recently published household representation rates and their use which will be considered in more detail later in this report.




Past decisions regarding issues of assessment of housing need and the duty to cooperate

2.19 The importance of the matters highlighted above have been confirmed by Inspectors’ decisions in the following cases:

Bath and North East Somerset Core Strategy 2.20 Requirement of SHMA to cover the whole housing market area not just the LPA

(Inspector’s letter paragraph 1.9).

2.21 The relationship between economic growth and housing is important but is not a justification for undersupplying housing.

2.22 Alternative projections, as in the case of BANES (2008 household projections), do not constitute a SHMA as required by paragraph 159 of the Framework and such projections do not allow the Inspector to conclude what the housing requirement should be (Inspector’s letter paragraph 1.30).

2.23 In the absence of the SHMA for the whole Housing Market Area and the shortcomings of the Council’s approach, the Inspector concluded that the plan was unsound and contrary to the Framework.

2.24 The Sustainability Appraisal of the plan was criticised for not considering the full range of potential requirements (section 5) and is likely to have to be reworked as a result of the review of the housing requirement.

East Hampshire 2.25 The requirement for local planning authorities to ensure that their plans are based on

adequate and up to date evidence and that they should have a clear understanding of the housing needs in their area and how this is to be met. However, the last SHMA was produced in January 2008 and later assessments of need do not provide an update on the full housing needs of the District (Inspector’s letter paragraph 6).

2.26 As the plan period extended to 2028 the Inspector stated that it was to be hoped that pre-recession projected levels of economic growth would be achieved well before the end of the plan period. However, the Inspector was concerned that the level of housing proposed in the Joint Core Strategy (added to an aging population) would limit the supply of local workers, prejudicing existing businesses and making the District less attractive to new employers, which could also lead to increased levels of in commuting (Inspector’s letter paragraph 8).

2.27 Again, this emphasises the need for the SHMA to be both up to date and to consider implications beyond the boundary of the district.

Rushcliffe 2.28 The approach adopted in Rushcliffe was to set a level of provision to meet the needs of

the existing population, whilst allowing for continuing in migration to the area, albeit at a lower level than that experienced in the past. This was not considered by the Inspector (paragraph 2.3 of letter) to “boost significantly the supply of housing”.




2.29 In paragraph 2.4 the Inspector’s letter she agreed with representations that it is difficult from the evidence base to know what the Council considers to be the full need for housing. In reaching this decision that the proposed level of housing was insufficient to meet objectively assessed needs. The Inspector considered both independently produced projections and the 2011 interim SNPP.

2.30 In paragraph 2.5 the Inspector’s letter she emphasises the importance of meeting the overall needs of Greater Nottingham given the Framework’s emphasis on planning strategically across local boundaries (see paragraphs 178-181 of the Framework) and stated that this was not an issue that the Core Strategy could sidestep.

2.31 The Inspector stated in paragraph 2.6 of her letter that the Council should explain what it considers to be the objectively assessed level of housing need clearly, and demonstrate how this can be met in full. Furthermore, the Inspector stated that there should be an audit trail of evidence to indicate how the housing policy and numbers have been derived.

2.32 This decision again confirms the requirement for the SHMA to address the needs of the whole Housing Market Area. More importantly the Inspector makes it clear that meeting the needs of the district without addressing the wider need is not in conformity with the Framework.

Ribble Valley 2.33 The Inspector was concerned that the 2008 based SHMA was out of date (Inspector’s

letter of 23 November 2012).

Coventry 2.34 In his letter advising the Council that they had failed in their duty to cooperate; the

Inspector highlighted that the Council’s attempt to discharge this duty through the production of The Strategic Policy Framework for the West Midlands was inadequate as this had nothing direct or specific to say about housing numbers in the Plan.

2.35 The Inspector in paragraph 30 states that the lack of broad consistency in the way housing need was being calculated between the various local planning authorities in the Coventry Housing Market Area called into question the statement that they are all capable of meeting their housing requirements within their borders and that consequently there is no requirement for any local authority to meet any part of its housing requirements in another area.

North Warwickshire 2.36 The Inspector (in his letter of 22 March 2013) highlights that the Framework requires

evidence to be adequate, up to date and to assess the needs of the wider housing market area. The plan was found to be unsound.

Kirklees 2.37 In his letter of the 26th April 2013 the Inspector states that the duty to cooperate

requires more than consultation between local authorities. He stated that given the timing of the submission of the Core Strategy after the revocation of the Regional Spatial Strategy (RSS) he found it difficult to reconcile the Council’s claims that it has met its duty to cooperate as a participant in the Regional Assembly against a Core Strategy that proposed a significantly different approach to housing than that set out in the RSS and adopted by other authorities (page 2).




Hunston Properties Ltd vs Secretary Of State for Communities and Local Government & St Albans City and District Council

2.38 Although this high court decision concerned the refusal of planning permission for a housing development in the Green Belt the Judge is very clear on the approach that should be taken to the objective assessment of housing needs, which is of relevance in the interpretation of the Framework, both for development management decisions and development plans.

2.39 In paragraph 20 of the decision the Judge finds that the reasoning of the Inspector in Planning Appeal X1165/A/11/2165846 to be entirely convincing. The Inspector in that appeal is quoted in paragraph 47 of the decision:

"… constraints do not bear upon the actual need for dwellings … the stage at which growth constraints should be taken into account is when assessing how the identified need can be addressed …they cannot reasonably be used … simply to reduce the number of dwellings calculated as necessary to meet housing need".

2.40 In paragraph 30 the Judge states that the proper course in determining a housing requirement would be;

a. assessing need;

b. then identifying the unfulfilled need having regard to the supply of specific deliverable sites over the relevant period; and

c. then to decide on the policy implications of meeting this need.

Conclusion from recent decisions 2.41 The above highlight the need to take into account up to date information, to plan

positively for the needs of the economy and to consider the needs of the wider housing market area in terms of housing and employment needs.

Concluding comments on approach to objectively assessing housing demand and need

2.42 In light of the above the following is a summary of the key elements in terms of objectively assessing housing demand and need in the context of the Framework:

a. Evidence should demonstrate how the plan will significantly boost the supply of housing (Framework - paragraph 47);

b. Evidence on housing demand and need must be up to date (Framework - paragraph 158) – it is noted that Inspectors have rejected levels of housing provision based on the older 2004 or 2006 based household projections (see Ribble Valley and North Warwickshire Inspectors’ letters);

c. Evidence on housing demand and need must assess the needs and demand including migration in the housing market area as a whole (Framework - paragraphs 47 and 179);

d. This evidence needs to take a consistent approach so as to confirm that the proposed level of housing will, in collaboration with the other authorities, result in the full housing needs are met (Framework - paragraph 47);




e. Future labour supply is a consideration (Framework - paragraph 158) in terms of considering future patterns of migration and there is an expectation in the guidance that housing provision should be increased in order to meet labour shortages;

f. Plans should consider the market trends and plan to widen the opportunities for homeownership in their areas (Framework - paragraph 50). The draft Guidance again suggests that there is an expectation for plans to deliver above trend where there is evidence of increased market demand.

g. The approach to the duty to cooperate requires that local planning authorities should work together to meet development requirements which cannot wholly be met within their own areas (Framework - paragraph 179).

h. The need to take account of wider areas is explicit in paragraph 180 of the Framework and includes the need to consider travel-to-work areas.

i. The Government expects that cooperation should be a continuous process of engagement from initial thinking through to implementation, resulting in a final position where plans are in place to provide the land and infrastructure necessary to support current and projected future levels of development (Framework - paragraph 157).

2.43 In this report DLP have sought to assist the Council by highlighting these issues and providing a suitable evidence base to determine the future level of dwelling requirement.




3.0 The evidence base and assumptions

The Sub National Population Projections (SNPP) 3.1 The most recent projections are the interim 2011 Sub National Population Projections

(SNPP). The results for Stroud of recent projections are summarised in the two tables below.

Sub National Population Projections for Stroud 2011 to 2029/31 Table 1Date of Projection 2004 2006 2008 2010 Stroud 2009 to 2029 2011 to 2031 2011 to 2031 2011 to 2031 Population at 2011 111,600 114,000 111,700 112,100 Natural change -5,000 -3,000 -2,100 -2,100 Migration 14,500 20,000 16,000 12,200 Ave migration 725 1,000 800 610 Final population at 2029/2031 121,900 130,800 125,300 121,800

ONS

Sub National Population Projections for Stroud 2011 to 2021 Table 2Date of Projection 2004 2006 2008 2010 2011

2011 to 2021

2011 to 2021

2011 to 2021

2011 to 2021

2011 to 2021

Population at 2011 112,520 114,000 111,700 112,100 113,100 natural change -1,700 -500 -500 -200 700 migration 6,200 9,500 6,800 5,500 5,800 ave migration 620 950 680 550 580 final population at 2021 117,620 122,400 117,900 116,900 119,700

ONS

3.2 The first table shows the projections for the period to 2029/31 and suggests that the natural change projected from the population has changed over the different projections with a move from a population which was not renewing itself to one that is marginally growing. In terms of migration all the projections suggest a level of in migration which has varied over time ranging from 550 to 1,000 migrants a year.

3.3 Subnational population projections by age and sex are usually produced every two years by the Office for National Statistics (ONS).

3.4 The primary purpose of the subnational projections is to provide an estimate of the future size and age structure of the population of local authorities in England. These are used as a common framework for informing local-level policy and planning in a number of different fields as they are produced in a consistent way (ONS Statistical Release: Interim 2011-based Sub National Population Projections for England 28 September 2012) (Appendix 18).

3.5 Examples of uses made of population projections include:

a. The Department for Communities and Local Government (DCLG) when calculating the allocation of central government resources to local areas.

b. Locally they are used to inform planning of healthcare, education and other service provisions.




c. Subnational projections also form the basis for other products such as household projections, and by researchers and other organisations that also produce their own projections.

d. Projections become increasingly uncertain the further they are carried forward due to the inherent uncertainty of demographic behaviour. This is particularly so for smaller geographical areas.

3.6 For the purposes of establishing the future dwelling requirement then the starting point should be the most recent Government population projections.

3.7 The Interim 2011 Sub National Population Projections published by the Office for National Statistics (ONS) on 25 September 2012 are based on the 2011 mid-year population estimates, which are rolled forward from the 2011 Census.

3.8 The ONS state that these projections provide the best estimates of the future population of English regions and local authorities currently available (ONS Statistical Release: Interim 2011-based subnational population projections for England).

3.9 The 2011 interim projections assume a continuation of the estimated trends in fertility, mortality and migration as used in the 2010-based projections and are constrained to the assumptions made for the 2010-based national population projections. The trends from the 2010-based projections have been used because a revised historic data series is not yet available to update the assumptions. The impact on the projections is described in more detail in the User Guidance section of the Statistical Bulletin: 2011 Interim Sub National Population Projections.

3.10 While the Sub National Population Projections are usually produced every two years the 2011 interim projections are not in the usual schedule of releases but have been produced to meet specific user requirements for an updated set of projections which incorporate data from the 2011 Census but projections are only provided to 2021.

3.11 These projections are not forecasts and do not attempt to predict the impact that future government or local policies, changing economic circumstances or other factors might have on demographic behaviour.

3.12 The advice from the ONS is that these projections are known to over-project the number of births at a national level. This particularly affects some areas where the 2011 population estimates have higher numbers of women aged 16-44 than in the 2010 estimates. Therefore caution should be used in the application of these projections for planning purposes at the younger ages. As these are only a 10 year projection to 2021, it is not considered that this will impact on the projected requirement for housing as children born during that period will not be forming separate households within the first ten years of their life.

3.13 It is important to consider the context of these projections both in terms of the impact of the housing boom and subsequent recession on household formation rates but also in terms of recent patterns of migration. During the recession total house sales fell by almost 50% which is a strong indication of the impact on the ability of households to move. This the lack of the opportunity to move is going to have an impact on the past rates of migration that have been used to inform these projections. It is likely that migration rates will have been underestimated as a result of recent trends. As discussed later the inability to form households will also have had an impact on the age and sex of migrants in recent times.




Conclusion on the SNPP 3.14 The 2011 Interim SNPP has the clear advantage of reflecting some of the results of the

2011 census most notably the age and sex of the current population. While other inputs have not been updated it remains the most up-to-date evidence and therefore represents a starting point for the calculation of future need.

3.15 The two obvious shortcomings of the 2011 interim projections need to be addressed. These being the short term nature of the projections (to just 2021) and the implications of the recession on migration movements.

3.16 To arrive at an assessment of the housing requirement this report has modelled the future housing requirement arising from both the 2010 SNPP and 2011 SNPP using the Chelmer model. It has also considered future alterative levels of migration required to meet the needs of the local economy. The next section will discuss the issues arising from the use of the new household representation rates contained for the 2011 interim household projections.

Commentary on the suitability of the 2011 household representation rates as contained in the 2011 Interim household projections as a basis for plan making

3.17 One of the key elements to the household projections is the projection of future household representation rates.

3.18 Not all the information is available from the Census 2011 with regard to household representation rates, but the information that was available suggested that the previous projections were overestimating the rate of household formation and this finding is supported by the evidence from the Labour Force Survey (LFS) that household representative rates for some (particularly younger) age groups have fallen markedly since the 2001 Census. By imposing the change in household representative rates by age from the LFS onto the aggregate Census point in 2011 the projections are assuming that the trends observed in the LFS by age are correct. It is possible that the full results from the Census 2011 reveal that the trends by age group were different to those observed in the LFS, but at this stage CLG state that it is not possible to quantify the differences.

3.19 In national terms, growth in couple households (with or without other adults) makes up forty per cent of the total increase in households between 2011 and 2021. Over a quarter (28 per cent) of the increase in households is accounted for by one person households. This contributes to a decrease in the average size of households from 2.36 persons per household in 2011 to 2.33 persons per household in 2021. By 2021, 13 per cent of the private household population in England is projected to live alone, unchanged from 2011.

3.20 A further 15 per cent of the growth in total households is due to the growth in ‘other’ households. This group includes multi-person households including student households and adults sharing accommodation. Both of these household types experienced a large increase between the 2001 and the 2011 Census.

3.21 Lone parent households are projected to increase by 23 per cent between 2011 and 2021.




3.22 At the aggregate level the 2011-based projections show a lower growth in households compared with the 2008-based projections, equating to 24,900 fewer households per year between 2011 and 2021 in England. This is despite the fact that adult household population growth is larger under the 2011-based projections than the 2008-based projections. The difference therefore largely reflects lower household representative rates (household formation) compared with the previous projections. Between 2001 and 2011 average household size increased in many areas, rather than falling as projected in the 2008-based projections, which leads to a higher starting average household size for the projection period.

3.23 It should be recalled that the 2008 projections themselves discounted some 290,000 households from the final projections to reflect the impact of the recession. These most recent interim projections take into account the inability of younger persons to form households due to increasing unaffordability and more recently lack of access to finance.

3.24 What neither the 2008 nor the 2011 interim projections provide is an indication as to whether the changes in household representation rates especially amongst the younger age groups is something that is a permanent change in aspirations of those younger age groups in terms of household formation or whether it is a short term reaction to the economic circumstances of the preceding decade.

3.25 The projections model forward the impact that the under provision of housing in the past decade has had on both affordability of and accessibility to housing.

3.26 The level of under provision in the country is illustrated in Chart 1 below, which compares the net additions to the housing stock since 1991 with the projected level of housing requirement from the official current projections .

Chart 1: Net additions to the housing stock compared to the most current projections




3.27 The unresponsive nature of the planning system and the chosen policy emphasis by the

Government during this period are both contributory factors to this increasing gap between supply and demand as well as impacting adversely on labour mobility (OECD Housing and the Economy: Policies for Renovation). The consequences of this under provision are well documented in terms of increased issues of affordability that have occurred over the last decade and are illustrated in the chart below which illustrates that when the economy started emerging out of recession in the mid 1990’s the inability of the planning system to respond quickly to the increase in demand for housing resulted in an increase in issues of affordability.

3.28 In this period of time the affordability ratio increased from just over 3 times earnings to over 7 times earnings and that despite the impact of the recent recession the ratio remains at over 6 times earnings.

3.29 While it may appear to be counter intuitive that affordability ratios would rise at the same time as the output from the housebuilding industry increased, however if one considers the potential backlog of unmet demand as modelled by the difference between the projected level of need and the actual level of completions since 1991 then it becomes very apparent that the increase in output was not only meeting the level of projected demand at that time but also displaced or delayed demand from these earlier years.

3.30 The relationship between the increase in the affordability ratio and the cumulative shortfall in provision against the most recent projections is illustrated below:

Chart 2: Comparison of the cumulative undersupply of dwellings against latest projections to changes in the Affordability Ratio




3.31 These increased problems of affordability and the subsequent recession have not however reduced the desire for home ownership as the 2010 opinion survey undertaken by YouGov for the Council of Mortgage Lenders found that more people than ever before want to be home-owners in the long term. In the survey 85% of people cited home-ownership as the tenure they hoped to be living in a decade from now .i.e. before 2021. This suggests that the home-ownership aspiration remains firmly rooted in the population. The same question about home-ownership aspirations has been asked periodically since 1975 and last time the survey was undertaken, in 2007, the proportion who expected to be home-owners in ten years' time was 84%.

3.32 The survey did find that over the short term, the desire for home-ownership has dipped with only 76% of those surveyed considered that home-ownership was their ideal tenure in two years' time. This was down from 78% from the previous survey (2007). This result was strongly influenced by the much lower short-term appetite (42%) for home-ownership among adults aged 18 to 24. This corresponds to the 2011 interim projections that models household representation rates in these younger age groups as reduced. What is pertinent is that while this younger age group are recognising the short term difficulties in household formation they are actually an age group with the highest ten-year home-ownership aspirations (88%).

3.33 The table below shows the summary findings for all adults.

Percentage of GB adults preferring to live in owner-occupied homes Table 3 Date of YouGov Survey 2007 2010

In two years’ time 78% 76%

Ten years from now 84% 85%

3.34 This survey would tend to support the analysis of demand that emerged from the previous recession in that most people see home-ownership as their tenure of choice over the long term. The unintended consequence of planning for low levels of housing formation based upon the 2011 interim household projections is that it will make it more difficult for people - especially young people - to fulfil their housing aspirations in the future.

Population Growth and Housing Requirements Woodhead 2012 3.35 It is noted that this report on page 42 criticises the earlier submissions by DLP. This

states in part b) that it is illogical to extend the plan period to 2031 but it is noted that the author appears to recommend an extension of the period to 2031 in his later report “Evidence Review Update”.

3.36 In part c) of the reports response to DLP’s earlier submission higher levels of housing provision suggested are higher than that achieved in the past. While the report makes no reference to the need to significantly increase housing supply (Framework paragraph 47) it cities the dangers of over supply as demonstrated by the examples of the Republic of Ireland and at Wichlestowe in Swindon as justification for rejecting higher levels of provision. It is also suggested that there is an inability of the construction industry to deliver these higher rates. The increasing number of starts in recent months and past builds rates previously achieved within this policy constrained district all suggest that these general criticisms are not substantive reasons for rejecting higher levels of dwelling provision.




Evidence Update: Incorporating updated material from DCLG Interim 2011 – based household projections Woodhead (April 2013)

3.37 This document updates the advice to the council in light of the 2011 interim household projections. In notes in paragraph 3.4 that the projections are a consideration in the setting of the housing requirement for the council (paragraph 3.4) and suggests that the findings support the earlier findings of the 2012 Stroud Housing Requirement report that the local plan housing target should now be between 9,500 and 11,500 dwellings. Taking account of completions this translates into a range of 7,500 to 9,500 dwellings in the period 2011 to 2031.

3.38 In making the recommendation for a minimum level of housing requirement to be 9,500 the report provides no commentary on the implications of using the 2011 interim household projections on matters such as increasing access to homeownership or improving affordability which are matters for consideration in the Framework and the Strategic Housing Market Assessment Guidance.

Conclusion on the appropriateness of utilising the 2011 household representation rates as set out in the 2011 Interim Household Projections

3.39 There are clear advantages of utilising the 2011 Interim Household Projections as these do provide a nationally consistent picture for the country and can assist in making sure that the housing needs of the country are met (Framework - paragraph 12).The same could also be argued of utilising the underlying SNPP’s without modelling in the negative impacts of the last decade in terms of affordability.

3.40 In general terms the 2011 Interim Household Projections would indicate a minimum level of provision, as to only provide this level of housing in the HMA would exacerbate the already high affordability ratios and continue to force younger households to postpone their housing aspirations.

3.41 To arrive at an objectively assessed housing need this report utilises both the 2008 and 2011 household representation rates.

3.42 In terms of the 2011 rates in the post 2021 period two approaches have been used. One is to change these rates proportionally in accordance with the change from 2011 to 2021. The other approach has been to increase these rates back to the higher but still below long term trend level projected by the 2008 household projections.

3.43 The suitability of these projections needs to be tested against future patterns of migration and economic factors before reaching an assessment of the level of housing need. Once a level of need has been established then the duty to cooperate has to be considered in terms of whether there are unmet needs within the Housing Market Area that will require to be met as part of setting the final level of housing requirement.

Economic and Employment evidence and assumptions

The Pre Submission Draft 3.44 Core Policy CP2: Strategic growth and development locations states that Stroud District

will accommodate at least 9,500 additional dwellings and 6,200 additional jobs for the period 2006-2031.

3.45 Paragraph 41 of the Pre Submission Draft state that the projections suggest a need to plan for around 5,100 net new jobs (2006-2031) and a need to provide about 37 ha of additional employment (B1-B8) land from 2012 to 2031, based upon past take-up rates.




3.46 In the introduction to the strategy it states that the strategy in the plan is based upon the provision of 6,200 jobs (paragraph 2.10).

3.47 Paragraph 2.42 of the Pre Submission Draft explains further the Council’s position stating that a range of forecast models suggest that the District has a significant oversupply of employment land to meet the 6,200 jobs. However, these models take no account of pent up demand, failures in the property market or the need for a range of sites and locations to provide for choice and a continuum of supply beyond the Plan period.

3.48 Paragraph 2.51 highlights the 2 to 1 jobs to homes ratio.

“Housing Trend Analysis & population and Household Projections” (May 2011) 3.49 The background paper “Housing Trend Analysis & population and Household

Projections” (May 2011) which has been produced by Gloucestershire County Council (GCC) explores the evidence on housing provision and employment growth.

3.50 Paragraph 2.5.5 highlights that Stroud District is the third largest economic centre in Gloucestershire and that while jobs did reduce in 2009 the overall trend for job creation has been upwards.

3.51 The evidence suggests that out commuting has remained constant since 2001 to 2008, but that in commuting from outside of the county has increased (also Figure 2.5.14).

3.52 Table 8 sets out the travel to work patterns from the census results and highlights that in total there were 40,613 workers in 1991 and this increased to 53,113 in 2001. This represents an increase of workers by 12% over that earlier decade.

3.53 In terms of workers living and working in the district, this increased from 27,830 to 34,430, an increase of 24%, suggesting that during this period the district became more self-contained.

3.54 To add complexity to this however the numbers working outside of the county increased from 5,290 to 7,943 which is almost a 50% rise in out of county commuting, but which involved very much smaller absolute numbers. This suggests that patterns of commuting may have become more polarised. This conclusion is supported by the more recent 2008 information in Figure 2.5.13.

3.55 According to the Employment estimates in Table 9 the district grew from 46,250 jobs in 1991 to 48,900 in 1999 before falling back to 45,040 in 2001 and then again growing to 54,650 in 2008 (a growth of 9,610 jobs or 21% in 7 years). A small decline took place in 2009, the latest year for which information is available.

3.56 Table 10 sets out the projected employment growth 2010 to 2020 produced by Cambridge Econometrics. They do not look further than 2020 and are not therefore consistent with the forecasting or policy periods needing to be addressed within the Core Strategy. This suggests a 1% reduction in the level of employment in Stroud to 52,580 to 2010 then a recovery to 54,150 by 2020. This is a growth of employment of 1,450 jobs which is an equivalent to an average of 145 jobs a year.




Employment Land Study Stroud District Council

Model 2: Policy ‘off’ – Employment Based Forecast 3.57 Oxford Economics’ baseline indicates that whilst Stroud’s employment has been

impacted by the recent recession, this has not been as detrimental as some other areas of the UK. The forecasts indicate a shorter impact, with total numbers only beginning to fall in 2009 (55,200 in total). Whilst the baseline shows total numbers falling year on year between 2009 and 2011, this trend is forecast to reverse from 2012, and to demonstrate annual growth, albeit at a low level, continually through the Plan period to 2031 (paragraph 10.12).

3.58 Paragraph 10.13 states that over the Plan period (in this case 2012 to 2031) the total employment is forecast to increase by 5,200 jobs, equivalent to a rise of 9.2 per cent from 2012, when the total figure was 56,000. This is marginally above the UK growth figure of 8.7 per cent for the same period, but is a fifth less than the 11.8 per cent increase projected for Gloucestershire.

3.59 In paragraph 10.14 it is stated that the model suggests that much of Stroud’s growth will be in the five year period 2012- 2016, at which point total employment is expected to be 57,800 – a 5.1 per cent increase from the pre-recession (2007) level of 55,000. This is below the growth rate of 6.6 for Gloucestershire over the same period.

3.60 This represents an increase of some 1,800 jobs from 2012 to 2016 reflecting an annual average growth rate of 0.6 per cent. This stated to align to the forecast performance for Gloucestershire. Between 2016 and 2020 the forecast indicates Stroud’s employment will continue to grow at a similar annual average. As a consequence Stroud will be slightly below the Gloucestershire annual average of 0.7 per cent (paragraph 10.15).

3.61 The rate of Stroud’s employment growth is forecast to slow post-2020, with the figures equating to annual average growth of less than 0.3 per cent for the last decade of the Plan period. This is similar to the expectations for the whole of the UK, but is only two thirds of the growth envisaged for Gloucestershire (paragraph 10.16).

Model 3: Labour Supply Forecast 3.62 This scenario is based upon Oxford Economics Population Forecasts. The projections

indicate a rise in population numbers for the District to 121,000 by 2031. Reflecting a trend of an ageing population, the working age population figure would see a lesser increase of only 1.5 per cent – from 67,000 in 2012 to 68,000 in 2031 (paragraph 10.27).

3.63 The forecast is based on the assumption that the current economic activity rate remains unchanged and suggests an increase in the number of residents working of 807 by 2031. This translates to an increased need of between 2.26 and 2.64 ha of employment land (paragraph 10.28).

3.64 This suggests that the level of proposed housing in the Local Plan will not provide for the creation of the level of jobs that are being forecasts.

3.65 In Paragraph 13.49 reference is made to the summary of the forecast scenarios is set out in Table 6 and states that these projections relate solely to the Plan period 2012 – 2031.




Additional evidence of changes to employment 3.66 The Tempro Model version 62 has been updated to reflect the impact of the recession

in terms of its employment forecasts although the dwelling projections are 2008 based. The summary for both Stroud and the wider Housing Market Area is set out below:

Population, dwelling and job forecasts Tempro Table 4

Name < 16 16 to 64 65+ Total HHs Jobs Workers

Annual rate Dwgs

rural (Stroud) 90 -393 4,499 4,196 2,540 -38 -1,463 105 Gloucester (part of) 9 -89 580 500 422 1 -285 17 Stroud -121 -925 4,324 3,278 2,637 129 -2,013 109 Stonehouse -59 -247 844 538 497 -94 -463 20 Nailsworth 20 -77 813 756 536 22 -295 22 Dursley -50 -360 1,902 1,492 1,067 19 -781 44 Chalford 20 -76 850 794 598 -5 -352 25 Wotton-under-Edge 2 -65 736 673 478 23 -251 20 Stroud -89 -2,232 14,548 12,227 8,775 57 -5,903 362

3.67 This suggests that a lower level of dwelling provision meeting the needs of about 360

households a year would result in the fall in workers of almost 6,000. In terms of employment generation it suggests that there would be little change over the period 2006 to 2031. More recent employment forecasts and population projections suggest that both the overall level of housing should be increased and that there is also likely to be a higher level of job growth.

3.68 Policy CS2 suggests that the plan should achieve a growth of 6,200 additional Jobs between 2006 and 2031. It is unclear from the evidence base how this figure has been derived.

3.69 It should also be noted that employment projections, especially during times of economic recession are difficult.

3.70 The table below shows that the number of persons in employment who reside in Stroud has increased by some 7,400. This is an increase of those in employment of some 14%. Not all of these new workers have taken jobs in Stroud and some will commute to other centres. This also suggests that the levels of economic activity within the area are higher than that experienced in region or country as a whole.




All people - Economically active - In employment Stroud Table 5Date Stroud Jobs Stroud % South West % Great Britain % Apr 04-Mar 05 53,600 76.6 75.7 72.7 Apr 05-Mar 06 52,700 76.6 75.5 72.5 Apr 06-Mar 07 53,300 75.9 75.6 72.5 Apr 07-Mar 08 58,500 81.7 76.2 72.6 Apr 08-Mar 09 58,000 80.4 75.6 72 Apr 09-Mar 10 55,900 77.2 73.6 70.3 Apr 10-Mar 11 54,600 76.1 73.6 70.2 Apr 11-Mar 12 59,800 76.5 73.4 70.2 Apr 12-Mar 13 60,700 83 73.9 70.9 change 2006 to 2012 7,400

Numbers are for those aged 16 and over, % are for those aged 16-64

Source: ONS annual population survey

3.71 The table below provides the evidence of job growth within the area the latest evidence is that total jobs increased from 53,000 in 2006 to 58,000 in 2008 and have then fallen back to 57,000, which has remained constant for the period to 2011. This demonstrates an increase of some 4,000 jobs in the period 2006 to 2011, which is almost two thirds of the plans suggested job growth and would only leave some 2,200 jobs to be created in the period 2011 to 2012.

3.72 This would actually be a lower level of job growth than that suggested in the Employment Land Study.

3.73 The table below uses the annual growth rates from the Oxford Economics projections, as reported in the Employment Land Study, to recalculate job growth using the Nomis 2011 figure as a starting point. This suggests that this latest projection would suggest about 3,000 jobs between 2011 and 2026 and a total of 5,200 jobs between 2011 and 2031. This result of course is entirely compatible with the paragraph 10.13 of the Employment Land Study Employment led projection of 5,200 jobs 2012 to 2031.




Total jobs (Nomis) Table 6

Date Stroud CE 2008 CE LEFM feb 2012

Employment Land Study Oxford Economics

2000 49,000 2001 45,000 45,500

2002 48,000 2003 52,000 2004 50,000 2005 49,000 2006 53,000 49,700 49,700

2007 55,000 2008 58,000 2009 57,000 2010 57,000 2011 57,000 51,100 50,700 57,000

2016

52,000 50,900 58,731 2021

52,800 53,700 60,333

2031

62,168 job growth 2006 to 2011 4,000 1,400 1,000

job growth 2006 to 2026 3,100 4,000 job growth 2011 to 2026 1,700 3,000 3,333 job growth 2011 to 2031 5,168

ONS Crown Copyright Reserved [from Nomis on 7 October 2013]

3.74 While the proposed level of job growth at first glance appears to be aspirational, but achievable, the analysis above suggests that if most of the growth occurred already in the period 2006 to 2008 then the target is not at all aspiration and could be considered to be pessimistic given the most recent projections for the 2011 to 2031 period by Oxford Economics of 5,200 new jobs.

Population Growth and Housing Requirements Woodhead 2012 3.75 In paragraph 3.53.10 the report states that the Cambridge Econometrics projection of

4,000 jobs (2006 to 2026) is not large in historic terms and that it may be unduly pessimistic for Stroud.

3.76 It is noted that this report on page 42 criticises the earlier submissions by DLP with regard to the use of an employment projection based on the Cambridge Econometrics’ results and the 6,400 target in the plan. In this part of the document the author appears to be arguing that the council’s job target is unsound.

3.77 Interestingly this also suggests that Stroud is part of a much wider travel to work area that includes South Gloucestershire, Bristol, Gloucester, Cheltenham and Swindon. This would suggest that the assessment of housing need should be undertaken over this wider area rather than at the district level.




Evidence Update: Incorporating updated material from DCLG Interim 2011 – based household projections Woodhead (April 2013)

3.78 In paragraph 1.2 of this report it states that the purpose of the earlier 2012 report (Population Growth and Housing Requirements) was to inform the council’s evaluation of how to distribute 3,200 additional new homes and a target of 6,200 jobs across the district between now (2013) and 2016.

3.79 This report however makes no analysis of the implications for the labour force of the 2011 based Interim Household Projections

3.80 The next section considers the influence of commuting on employment and job growth.

Evidence on Commuting 3.81 The evidence on recent changes to commuting patterns would suggest that a higher

percentage of the residents of the area are also working in the area and that the area is drawing in workers from other locations to a greater extent.

The proportions of people living in 'Stroud' that have jobs in the Table 7local authority shown

Place of work for Stroud residents: Change over time 2001 flow 2008 flow Stroud 57% 67% Gloucester 14% 11% Bristol, City of 5% 5% South Gloucestershire 6% 5% Cheltenham 5% 4% Cotswold 4% 3%

Source: Local Labour Force Survey, 2001. Annual Population Survey, 2008

The proportion of jobs in 'Stroud' that are filled by people who live Table 8in the local authority shown

Place of residence for Stroud workers: Change over time 2001 flow 2008 flow Stroud 79.49% 73.02% Gloucester 6.26% 5.69% South Gloucestershire 5.18% 5.63% Bristol, City of .. 3.34% Tewkesbury 2.90% 3.22%

Source: Local Labour Force Survey, 2001. Annual Population Survey, 2008.

3.82 If it is assumed that commuting rates will stay stable then the creation of 5,200 jobs in the period 2011 to 2031 would require the economically active to increase by 7,760 persons to take account that some 33% of the new workforce are likely to take jobs outside of the area.




The impact of increasing the pension age on activity rates 3.83 As part of determining the future level of workers that will result from any given

population the economic activity rate of the population has to be assessed.

3.84 In the Chelmer model used for these projections the default is to retain the existing levels of economic activity. This approach has been retained for a number of the projections in this report. In the circumstances of an aging population this will model an increased number of older workers as a function of more of the population falling within these age categories.

3.85 It is however acknowledged that there will be changes to the pensionable age and that this might have an impact on the activity rates for both men and women between 60 and 70. A further scenario has therefore been tested which the activity rates for the 60 to 64 age groups of both male and females has been increased by 2.5% for the two 5 year periods 2011 to 2021 (approx. 5% over period). It is then held constant at this new level. The activity rates of the 65 to 69 age groups has also been increased by 5% over the same two 5 year periods from 2011 to 2021 (approx. 10% over period).

3.86 The implications of these changes are illustrated in the Table below:

Summary Table changes to economic activity rates Table 9Males 2001-06 2006-11 2011-16 2016-21 2021-26 2026-31 2031-36 60-64 0.611808 0.638857 0.638857 0.638857 0.638857 0.638857 0.638857 65-69 0.436949 0.553989 0.553989 0.553989 0.553989 0.553989 0.553989 Change

60-64 0.611808 0.638857 0.654828 0.671199 0.671199 0.671199 0.671199 65-69 0.436949 0.553989 0.581688 0.610773 0.610773 0.610773 0.610773 Females 2001-06 2006-11 2011-16 2016-21 2021-26 2026-31 2031-36 60-64 0.345385 0.388315 0.388315 0.388315 0.388315 0.388315 0.388315 65-69 0.144716 0.069841 0.069841 0.069841 0.069841 0.069841 0.069841 Change 60-64 0.345385 0.388315 0.398023 0.407973 0.407973 0.407973 0.407973 65-69 0.144716 0.069841 0.073333 0.077 0.077 0.077 0.077

Migration 3.87 In considering the appropriateness of adopting the CLG figure for Stroud District a

number of issues should be considered. First, is whether the policies being pursued by the surrounding Districts and Regions are likely to impact upon the migration flows that are included in the CLG projections. The second issue is whether the level of housing being proposed is consistent with other plan policies including policies on the local economy and employment growth.

3.88 The table below highlights those regions which generate the highest levels of migration into Stroud District using the CLG data The highest flows are from the remainder of the South West, followed by flows from London, the South East, and the West Midlands. The level of in migration will have changed over time but this is a good indication as to the important factors to consider when determining what impact the policies of other authorities might have on migration pressures into the district.




2008 Migration flows into Stroud (CLG Table 3: Moves within Table 10England and Wales Registered during the year ending June 2009)

source /destination Totals

North East

North West

Yorks and the Humber

East Mids

West Mids East London

South East

South West

South Gloucestershire UA 12,400 80 320 240 340 620 460 600 1,370 7,560 Cheltenham 7,400 110 300 210 320 910 420 630 1,000 3,170 Cotswold 4,600 70 170 150 190 550 230 480 870 1,750 Forest of Dean 3,300 30 80 120 100 560 110 130 420 1,240 Gloucester 5,500 60 160 150 200 490 190 250 400 3,270 Stroud 4,800 30 160 120 160 350 150 370 520 2,740 Tewkesbury 4,800 30 140 100 120 650 110 150 350 2,960

3.89 The table below compares the new planned level of provision as a result of the removal

of RSS. This highlights that the South West districts are planning the highest level of cuts compared to the RSS requirement and this is likely to result in pressure for out migration from other parts of the region into Stroud. Likewise significant planned undersupply in the South East and London is likely to increase in migration flows into the district over the period of the plan. The constrained nature of the South East and London suggest that this will be an on-going issue under the Framework and needs to be taken into account in this plan.

Impact of the removal of Regional Spatial Strategies Table 11

Region Cuts to Date

LAs in stasis

Est. total housing loss p.a.

North East -1.9% 45% 3,419 North West -17.9% 20% 1,616 Midlands -6.0% 26% 3,838 South East -18.2% 50% 16,712 South West -26.5% 34% 5,822 England Total -20.6% 37% 31,407

Source: Housing the Nation BNP Paribas Real Estate 3.90 It is noted that the work to date on the Local Plan has not considered the

appropriateness of the continued use of past migration levels. This evidence suggests that there is likely to be an increased propensity to move into the district especially from the London the South East and the West Midlands.

3.91 The future shortfall of housing in London has recently been estimated by The London Councils in a Discussion Paper “London Housing Challenge”. This suggests that on current projections London will be faced with a 559,000 deficit of homes by 2021. As almost 20% of Stroud’s in migration comes from London and the South East it would be unwise to assume that past rates of migration will be maintained in circumstances of substantial demographic pressure.

Vacancy Rates 3.92 The 2011 census records some 49,983 household spaces of which 2,189 have no usual

resident (vacant or second homes). This would represent a 4.2% vacancy rate amongst all household spaces.

3.93 The “Evidence Review Update: incorporating updated material from DCLG Interim 2011 based household projections” Keith Woodhead (August 2012) uses two levels of vacancy 3.12% (2011 based) and 3.8% (ONS/NOMIS) estimate for 2008.




3.94 The default on the Chelmer model used in this report is lower than all of these as it uses a vacancy rate of 3.0% based upon the 2001 census.

Conclusion 3.95 In conclusion, the approach to generating the objectively assessed needs will take into

account the following: a. The 2010 and 2011 SNPP

b. The 2008 Household representation rates

c. The 2011 Household representation rates extended to 2031 by:

i. Pro rata changes

ii. Increasing to 2008 rates by 2031

d. The needs of the economy will need to be considered in terms of providing the appropriate level of housing to meet a range of job forecasts from a residual 2,200, to 5,200 (Oxford Economics), 6,400 jobs as per CS2 and finally 7,760 (Oxford Economics taking into account current pattern of commuting).

e. The changes to the pension age in terms of increased activity in the 60 to 70 ages groups

f. A range of vacancy rates from 3% to 3.8%




4.0 Indicators of Market Demand and the Housing Market Area

The definition of the appropriate area to be covered by a SHMA 4.1 The SHMA is the process by which councils are to determine their housing requirement

(Framework - paragraphs 47 and 159). This needs to be a joint process if the housing market extends across administrative boundaries (Framework - paragraphs 159 and 179).

4.2 In this context therefore it is necessary to establish if Stroud is a self-contained housing market or part of a larger housing market area.

4.3 The evidence in the previous section suggests that there are clear economic links between the area and its more urban neighbours.

“The Geography of Housing Market Areas” (DCLG, 2010) 4.4 This research sought to identify the optimal areas within which planning for housing

should be carried out. It links places where people live, work, and move home. Published by the DCLG it was commissioned by the National Housing Planning Advisory Unit (NHPAU). The NHPAU commissioned this work because they considered that there was a fundamental argument in support of planning for housing on a scale that is larger than most local authorities because market dynamics and population changes do not respect administrative boundaries but cut across them, operating at different scales.

4.5 The Executive Summary states that analysis and decision making within areas which are functionally as self-contained as possible allows the various factors that affect housing supply to be weighed against demand pressures, with minimum distortion due ‘out of area’ effects. It goes onto state:

“The need for joint planning will vary across the country. It is determined by the level of interdependence between adjoining areas within which jobs are created, people search for work or housing, and where they shop and play. This will be based on labour markets, housing markets, and other – often local - factors. In areas that are critical to the economic, social or environmental health of the country, joint planning is a critical requirement. Here, local plans must consider the wider spatial context, land resources and development outcomes (positive, negative, and displacement effects) of surrounding areas. Local communities need the confidence of knowing that they will be supported by, and not undermined by, the planning decisions of adjoining areas. Local initiative cannot be effective otherwise Housing Market Area which was to deliver.”

4.6 Within England, the work defined a set of 75 Framework housing market areas, with a tier of 280 local housing market areas nested wholly within them.

4.7 This states that the upper tier of Framework housing market areas would be most effective in providing a longer term overview of projected household changes, transport connectivities, housing land availability, housing market change and urban capacity, thereby addressing major initiatives like growth areas. As such the report states that this upper tier is the most suitable for delivering a strategic planning Framework.




4.8 This work identifies that Stroud is within the Housing Market area together with the following Local Authorities:

Extract from table 27 of The Geography of Housing Market Areas in Table 12England Centre for Regional Development Studies

23UB Cheltenham 35 23UD Forest of Dean 35 23UE Gloucester 35 23UF Stroud 35 23UG Tewkesbury 35

Evidence of need in the wider HMA 4.9 Evidence for this wider area is provided in the background paper “Housing Trend

Analysis & population and Household Projections” (May 2011) which has been produced by Gloucestershire County Council (GCC).

4.10 The table below illustrates that the differences between these two projections is that the GCC projections suggest an overall higher level of housing demand than the CLG projections. This increase is not uniform across all districts but those districts which have the larger urban areas are projected to have a higher level of household increase these being the districts of Cheltenham, Gloucester and Stroud.

CLG based household projections compared to projection of Table 13households in GCC “Housing Trend Analysis & Population and Household Projections”

2006 2026

Change 2008 2028

CLG 2006

CLG 2026

CLG change 2006 2026

Difference between projected change in households CLG and GCC

Gloucestershire 247,250 304,100 56,850 248,000 301,000 53,000 3,850 Cheltenham 49,430 60,000 10,570 49,000 59,000 10,000 570 Cotswold 35,960 42,300 6,340 36,000 44,000 8,000 -1,660 Forest of Dean 33,870 40,200 6,330 34,000 41,000 7,000 -670 Gloucester 48,080 65,600 17,520 48,000 61,000 13,000 4,520 Stroud 46,230 55,600 9,370 46,000 55,000 9,000 370 Tewkesbury 33,670 40,400 6,730 34,000 42,000 8,000 -1,270

PopGroup trend based forecast in table 12 of appendix B

Housing Trend Analysis & Population and Household Projections

4.11 A further element of the evidence base is the Gloucestershire Affordable Housing Model (GAM (October 2011)). The Gloucestershire Housing Affordability Model (GAM) has been designed to provide supporting evidence for local policy planning and in particular local strategies for deciding how much housing should be provided. The model generates forecasts for a variety of aspects of the housing market, and various aspects of ‘housing need’, based upon anticipated and where possible, desirable changes in housing supply and economic activity over time.

4.12 This model differs from the CLG, GCC and our projections in that it starts at 2008 rather than 2006.




4.13 Table 12 (below) sets out the migration assumptions in the GAM model. For Stroud these start with a recorded net level of out migration of 227 persons in 2008 which changes to a level of 707 in migrants in 2010, this level of in migration is then modelled to decline for the period to 2031.

4.14 There is no explanation of the chosen levels of migration in the GAM model but it is an output of the other considerations of the model.

4.15 The Gloucestershire Affordable Housing Model (October 2011) also comments that from 2012 job growth will return (paragraph 2.43) and continue at a sustained rate. It also suggests that the increase 2012 onwards will be considerably more than that forecast for the study period. For the county this means an increase of just over 47,000 new jobs (2012 to 2031) compared to 36,500 new jobs for the study period forecast (2008 to 2031).

4.16 The GAM model generates a broadly similar countywide household figure to the CLG projections but appears to generate a very different pattern of dispersal. The difference in the results are illustrated in Table 12 below:

CLG based household projections compared to projection of Table 14households by Gloucestershire Housing Affordability Model (GAM)

GAM 2008

GAM 2026

Change 2008 2026

CLG 2008

CLG 2026

CLG change 2008 2028

Difference between projected change in households GAM and CLG

Gloucestershire 252,514 300,867 48,353 252,000 301,000 49,000 -647 Cheltenham 49,582 58,497 8,915 50,000 59,000 9,000 -85 Cotswold 36,785 39,379 2,594 36,000 44,000 8,000 -5,406 Forest of Dean 34,765 40,048 5,283 34,000 41,000 7,000 -1,717 Gloucester 49,155 65,999 16,844 50,000 61,000 11,000 5,844 Stroud 47,437 52,648 5,211 47,000 55,000 8,000 -2,789 Tewkesbury 34,790 44,315 9,525 35,000 42,000 7,000 2,525

GAM forecast in appendix B of Gloucestershire Housing Affordability Model

4.17 The above table suggests that the GAM outcomes have made some very different assumptions regarding where housing demand might be met within the county. The resulting high levels of projected requirement at Gloucester and Tewkesbury would have to tested in terms of the ability to deliver these rates within and adjacent to these settlements and it is highly likely that such levels of provision could not be met within the each authority boundary. In the case of Gloucester, which shares its urban boundaries with other authorities this higher rate of potential requirement will have implications for those authorities as work already undertaken suggests that the will be a need for cross boundary urban extensions to meet the previous RSS housing requirement.

4.18 This evidence would suggest that there is additional housing demand that should be met in and around Gloucester. Given that Stroud shares its northern boundary with the town then specific consideration for cross boundary allocations should be considered.

4.19 The above projections are based in part on the 2008 household projection so the table below from CLG provides a comparison between these 2008 based household projections and the 2011 interim household projections for the wider area.




Table 430: Comparison between 2011-based projections and 2008-Table 15based projections, England, 2011- 2021

2011-based projections 2008-based projections

HHs 2011 (000s)

HHs 2021 (000s)

Total change in HHs (000s)

Average Change (000s)

HHs 2011 (000s)

HHs 2021 (000s)

Total change in HHs (000s)

Average Change (000s)

Cheltenham 50,902 55,078 4,176 418 51,465 56,857 5,392 539

Cotswold 36,369 38,952 2,583 258 37,480 41,566 4,086 409

Forest of Dean 34,273 36,763 2,490 249 35,416 38,869 3,454 345

Gloucester 50,456 56,218 5,762 576 51,414 57,779 6,364 636

Stroud 47,917 51,978 4,061 406 47,911 52,664 4,753 475

Tewkesbury 35,264 39,804 4,540 454 35,622 39,668 4,046 405

Gloucestershire 255,181 278,793 23,612 2,361 259,308 287,404 28,095 2,810 CLG Live tables: Table 430

4.20 The table above suggests that the number of household between 2011 and 2021 are

expected to be lower if the conditions which are pertinent to the 2011 projections are to continue. For Stroud the proposed level of change according to the 2011 Interim Household projections of over 4,000 households in this decade is still substantially higher than the level of requirement estimated by Gloucestershire Housing Affordability Model (GAM).

House prices and affordability 4.21 The chart on the next page demonstrates that house prices within Stroud have been

consistently higher than both national and regional mean house prices and that they remain close to their 2007 peak.

4.22 The second chart on the next page demonstrates that these higher mean house prices translate into higher affordability ratio’s than for England as a whole and that it has been consistently one of the districts with a high affordability ratio with the lower quartile house price being some 7 times the lower quartile earnings.

4.23 The appropriate response to this evidence is that the council should considering increasing the level of supply in accordance with the principles of sustainable development.







5.0 The conversion of SNPP to dwelling requirements using the Chelmer Model

Introduction 5.1 The Chelmer model has been used to produce a range of future dwelling requirements

that would result from both the 2010 based SNPP projections and the 2011 interim SNPP.

5.2 The ‘Chelmer model’ is a variant of the official government projection methodology and was developed by the Population and Housing Research Group at Anglia Polytechnic University. This model provides household growth estimates down to district level that can be tested by varying inputs .e.g. trend migration may be compared with zero net migration (migration led projections). Alternatively the model can provide household growth based upon the Government’s population projections (population led projections) or project the makeup of the population and the migration implications of any chosen level of dwelling provision (dwelling led projections). The Model is identified as an appropriate tool for determining future housing requirements in the Communities and Local Government Strategic Housing Market Assessments Practice Guidance (Version 2).

5.3 The detail of these projections is explained below. The default setting of the model has been used for the following inputs:

a. Activity Rates – two approaches have been used:

i. Annual Population Survey (APS) activity rates to 2010, held constant thereafter; and

ii. Activity rates increased for the 60- 64 and 65 – 69 age groups to reflect changes to pension age.

b. Population in Communal Establishments at end of Each Period - Calculated from 2008-based sub-national Population projections, ONS and 2008-based CLG household projections.

c. Fertility Rates UK age-specific births per woman (all births) The model uses rates constructed from officially-published data (e.g. for the UK) and then localises them through a local correction factor calculated on historical data. Population projections for England, GAD (various vintages, latest are 2010-based projections).

d. Household representative rates. These indicate the proportion of each demographic group (e.g. age and gender) that are the head of a household. Two options are available: (i) rates can be entered for total households; (ii) enter rates by age and gender for particular household types. The number and definition of the household types are completely flexible (some guidance on classifications and values are provided in the data file that accompanies the Chelmer release) but should be mutually exclusive. Because the classifications are not necessarily pre-determined in the model, the household classification titles are taken from the information provided below. These projections have used the following:

i. the default representative headship rates which are by status of household from the 2008-based Household Projections, CLG




ii. the 2011 interim household projections rates extended to 2031 by either:

1. extrapolation of trend

2. a return to 2008 rates by 2008

e. Migration. In the population led projections migration is an output of the model. In migration led projections total net migration has been used. In both circumstances the model utilises the age/sex of migration based upon the ONS mid-year population estimates and internal migration estimates (to 2010), and 2010-based UK population projections, ONS.

f. Mortality rates to be applied in the scenario. The model used rates constructed from officially-published data (e.g. for the UK) and then localises them through a local correction factor calculated on historical data including various population projections for England, GAD. Latest are 2010-based.

g. Vacancy Rates – we have used the model default vacancy rates of 3.0% based upon the 2001 census. The 2011 census records some 49,983 household spaces of which 2,189 have no usual resident (vacant or second homes). This would represent a 4.2% vacancy rate amongst all household spaces.

h. Shared dwellings - the proportion of dwellings that are shared-occupancy has been held constant as recorded in the 2001 census

i. Households in shared dwellings - the average number of households per shared dwelling has been held constant as recorded in the 2001 census

5.4 The different assumptions for each of the alternative projections are explained in more detail below.

The modelled scenarios 5.5 All of the modelled scenarios have a 2011 base as the 2011 SNPP have been used for

the majority of the scenarios as this represents the most up to date evidence and reflects the 2011 census. The exception is the 2010 SNPP based projection as explained below.

2011 interim SNPP (2011/2008HHRR) PA adjustment 7,523 dwellings 5.6 This is a dwelling led projection which considers the outcomes in terms of population,

labour force and migration as a result of the proposed level of dwelling provision in the Core Strategy.

5.7 It is noted from the councils five year land supply document 2012 that some 1,977 dwellings have been completed. These have been subtracted from the total of 9,500 to give 7,523 dwellings and it has been assumed that these will be completed at an average annual rate over the rest of the plan period.

5.8 The model has been set at 2011 using the 2011 SNPP total population and the associated age/sex.

5.9 It has also been adjusted to increase the number of workers in the 60 to 64 age group by 5% and the 65 to 69 age group by 10% over the period 2011 to 2021 to reflect the changes in pension age.

5.10 It uses the default setting in the model including the 2008 household representation rates, 3% vacancy and constant economic (2010) activity rates.




2011 interim SNPP (2008HHRR) last year Mig 5.11 This is a composite projection which models the outcomes of 2011 SNPP to 2021 and

then extends the projection using the level of migration in the last year (2021) held constant for the period 2021 to 2031. The changes to the number of additional dwellings required, the labour force and migration are all outputs of the model. It uses the default setting in the model including the 2008 household representation rates, 3% vacancy and constant economic (2010) activity rates.

2011 interim SNPP (2008HHRR) 2010Mig 5.12 This is a composite projection which models the outcomes of 2011 SNPP to 2021 and

then extends the projection using the level of migration in the 2010 SNPP for the period 2021 to 2031. The changes to the number of additional dwellings required, the labour force and migration are all outputs of the model. It uses the default setting in the model including the 2008 household representation rates, 3% vacancy and constant economic (2010) activity rates.

2010 SNPP (2008HHRR) 5.13 This is a population led projection which models the outcomes of 2010 SNPP to 2031.

The changes to the number of additional dwellings required, the labour force and migration are all outputs of the model. It uses the default setting in the model including the 2008 household representation rates, 3% vacancy and constant economic (2010) activity rates.

2011 interim SNPP (2008HHRR) last year Mig PA adjustment 5.14 This is a composite projection which models the outcomes of 2011 SNPP to 2021 and

then extends the projection using the level of migration in the last year (2021) held constant for the period 2021 to 2031. The changes to the number of additional dwellings required, the labour force and migration are all outputs of the model. It uses the default setting in the model including the 2008 household representation rates and 3% vacancy but changes the activity rates for the 60 to 70 age groups as set out in the earlier section.

2011 interim SNPP (2011HHRR increased to 2008HHRR by 2031) last year Mig PA adjustment

5.15 This is a composite projection which models the outcomes of 2011 SNPP to 2021 and then extends the projection using the level of migration in the last year (2021) held constant for the period 2021 to 2031. The changes to the number of additional dwellings required, the labour force and migration are all outputs of the model. It uses the 2011 interim household projection headship rates to 2021 and then increases these to align with the 2008 headship rates by 2031. It also models the changes the activity rates for the 60 to 70 age groups as set out in the earlier section. It uses the 3% vacancy rate.

2011 interim SNPP (2011HHRR average change) last year Mig PA adjustment 5.16 This is a composite projection which models the outcomes of 2011 SNPP to 2021 and

then extends the projection using the level of migration in the last year (2021) held constant for the period 2021 to 2031. The changes to the number of additional dwellings required, the labour force and migration are all outputs of the model. It uses the 2011 interim household projection headship rates to 2021 and then increases these to




proportionately to 2031. It also models the changes the activity rates for the 60 to 70 age groups as set out in the earlier section. It uses the 3% vacancy rate.

2011 interim SNPP (2011HHRR to 2031) increased mig (PA adjustment) 2,200 labour force

5.17 This is a migration led projection which starts with the age sex of the population in the 2011 SNPP but increases migration so as to result in changes to the labour force to reflect the projected change in the labour force of 2,200 jobs between 2011 and 2031 as per the Cambridge Econometrics projection as set out earlier in this report. The changes to the number of additional dwellings required, the labour force and migration are all outputs of the model. It uses the 2011 interim household projection headship rates to 2021 and then increases these to proportionately to 2031. It also models the changes the activity rates for the 60 to 70 age groups as set out in the earlier section. It uses the 3% vacancy rate.

5.18 As this uses the 2011 household representative rates this level of dwelling provision will not allow for increased opportunities for home ownership as required by the Framework.

2011 interim SNPP (2011HHRR) increased Mig (PA adjustment) 5,200 labour force 5.19 This is a migration led projection which starts with the age sex of the population in the

2011 SNPP but increases migration so as to result in changes to the labour force to reflect the projected change in the labour force of 5,200 jobs between 2011 and 2031. The changes to the number of additional dwellings required, the labour force and migration are all outputs of the model. It uses the 2011 interim household projection headship rates to 2021 and then increases these to proportionately to 2031. It also models the changes the activity rates for the 60 to 70 age groups as set out in the earlier section. It uses the 3% vacancy rate.


2011 interim SNPP (2011HHRR) increased Mig (PA adjustment) 6,400 labour force 5.21 This is a migration led projection which starts with the age sex of the population in the

2011 SNPP but increases migration so as to result in changes to the labour force to reflect the projected change in the labour force of 6,400 jobs between 2011 and 2031. The changes to the number of additional dwellings required, the labour force and migration are all outputs of the model. It uses the 2011 interim household projection headship rates to 2021 and then increases these proportionately to 2031. It also models the changes the activity rates for the 60 to 70 age groups as set out in the earlier section. It uses the 3% vacancy rate.


2011 interim SNPP (2011/2008HHRR) increased Mig (PA adjustment) 7,760 labour force 3.8% vacancy

5.23 This is a migration led projection which starts with the age sex of the population in the 2011 SNPP but increases migration so as to result in a growth of 7,760 in the labour force. This reflects the need to meet the 5,200 forecast job growth between 2011 and 2031 and allow for existing patterns of commuting to continue. This addresses the




earlier criticism that was made of the approach that the projection did not take account of the needs of the wider travel to work area.

5.24 The changes to the number of additional dwellings required, the labour force and migration are all outputs of the model.

5.25 It uses the 2011 interim household projection headship rates to 2021 and then increases these so that at 2031 they are returned to the rates in the 2008 projection.

5.26 It also models the changes the activity rates for the 60 to 70 age groups as set out in the earlier section.

5.27 It uses the 3.8% vacancy rate.

5.28 This projection represents the upper level of the potential needs as it would accommodate an aspirational but achievable level of economic and job growth as it would provide for the employment needs of the district while maintaining existing commuting patterns thereby not disadvantaging other areas with the travel to work area. It also takes into account the latest evidence on vacancy rates and allows for increased access to homeownership

The results of the scenario testing 5.29 The results of the Chelmer model are set out over the next few pages.

5.30 These are the most up to date population projections and combined with the household formation rates from the Interim 2011 household projections represent the most up to date evidence. As such these must form the starting point for the consideration of the objectively assessed need.

5.31 These suggest that to meet the requirements of the 2011 household projections as extended to 2031 then a dwelling provision should be made in the period 2011 to 2031 of between 8,187 and 11,145 dwellings (Table 16). As the lower of these two projections effectively continues the low level of household formation for the younger age ranges it is not considered to be in accordance with the Framework as it would not increase the opportunities for home ownership with in the area.

5.32 In terms of a demographic projection the 11,145 dwellings for the period 2011 to 2031 would appear to be the more appropriate and in accordance with the Framework. This projection while allowing for increased access to home ownership by returning to the 2008 based household representation rates by 2031 will not assist the local economy.




Chelmer Projections: dwelling requirement Table 16

Dwelling change 2011-2016

2016-2021

2021-2026

2026-2031

2011 2031

ave dwg 2011 to 2031

2011 interim SNPP (2011/2008HHRR) PA adjustment 7523dwgs 376 376 376 376 7,520 376 2011 interim SNPP (2008HHRR) last year Mig 446 457 506 507 9,577 479 2011 interim SNPP (2008HHRR) 2010Mig 446 457 445 457 9,025 451 2010 SNPP (2008HHRR) 357 413 396 275 7,204 360 2011 interim SNPP (2008HHRR) last year Mig PA adjustment 446 457 506 507 9,577 479 2011 interim SNPP (2011/2008HHRR) last year Mig PA adjustment 405 396 710 717 11,145 557 2011 interim SNPP (2011HHRR) last year Mig PA adjustment 405 396 435 401 8,187 409 2011 interim SNPP (2011HHRR) PA adjustment 2200 labour force 525 565 524 425 10,193 510 2011 interim SNPP (2011HHRR) PA adjustment 5200 labour force 579 646 643 542 12,047 602 2011 interim SNPP (2011HHRR) PA adjustment 6400 labour force 573 662 670 637 12,715 636 2011 interim SNPP (2011/2008HHRR) PA adjustment Migration for 7760 labour force 3.8% vacancy 743 737 1,023 1,019 17,608 880




Chelmer Projections: Changes to labour force Table 17

Labour force change 2011-2016

2016-2021

2021-2026

2026-2031

2011 2031

2011 interim SNPP (2011/2008HHRR) PA adjustment 7523dwgs -100 -191 -663 -400 -6,771 2011 interim SNPP (2008HHRR) last year Mig -64 -92 -57 25 -939 2011 interim SNPP (2008HHRR) 2010Mig -64 -92 -163 -48 -1,833 2010 SNPP (2008HHRR) -121 -119 -215 -146 -3,005 2011 interim SNPP (2008HHRR) last year Mig PA adjustment -20 -47 -49 26 -450 2011 interim SNPP (2011/2008HHRR) last year Mig PA adjustment -20 -47 -49 26 -450 2011 interim SNPP (2011HHRR) last year Mig PA adjustment -20 -47 -49 26 -450 2011 interim SNPP (2011HHRR) PA adjustment 2200 labour force 178 126 61 71 2,180 2011 interim SNPP (2011HHRR) PA adjustment 5200 labour force 277 265 257 242 5,199 2011 interim SNPP (2011HHRR) PA adjustment 6400 labour force 267 296 305 411 6,395 2011 interim SNPP (2011/2008HHRR) PA adjustment Migration for 7760 labour force 3.8% vacancy 422 406 312 412 7,761

5.33 It is noted that the proposed dwelling provision will result in a reduction the available

labour force (Table 15). This is contrary to the up to date evidence on job creation and therefore consideration should be given to higher levels of provision. Such consideration is also supported by the evidence on affordability and house prices.

5.34 In considering the level of dwellings required to support future levels of employment growth the projections have used the lower level of household representation rates for the period 2021 to 2031. This will reduce the level of dwellings required to accommodate a given increase in the workforce.

5.35 Not unsurprisingly the higher levels of dwelling provision to support the forecast job growth also require higher levels of migration.




Chelmer Projections: Changes to Population Table 18

Population change 2011-2016

2016-2021

2021-2026

2026-2031

2011 2031

2011 interim SNPP (2011/2008HHRR) PA adjustment 7523dwgs 445 446 -68 110 4,658 2011 interim SNPP (2008HHRR) last year Mig 591 725 777 645 13,691 2011 interim SNPP (2008HHRR) 2010Mig 591 725 617 528 12,307 2010 SNPP (2008HHRR) 420 560 500 340 9,100 2011 interim SNPP (2008HHRR) last year Mig PA adjustment 591 725 777 645 13,691 2011 interim SNPP (2011/2008HHRR) last year Mig PA adjustment 591 725 777 645 13,691 2011 interim SNPP (2011HHRR) last year Mig PA adjustment 591 725 777 645 13,691 2011 interim SNPP (2011HHRR) PA adjustment 2200 labour force 865 946 1,088 941 19,199 2011 interim SNPP (2011HHRR) PA adjustment 5200 labour force 1,014 1,163 1,404 1,244 24,126 2011 interim SNPP (2011HHRR) PA adjustment 6400 labour force 1,000 1,210 1,479 1,505 25,972 2011 interim SNPP (2011/2008HHRR) PA adjustment Migration for 7760 labour force 3.8% vacancy 1,234 1,387 1,520 1,538 28,396

5.36 Three of the projections have the same population this is because the projections are

demonstrating the impact of the use of different household representative rates. Increasing the headship rates to the population from the 2011 to the 2008 rates during the projection increases the number of households formed compared to running the 2008 headship rates throughout the whole model because using the 2008 rates at the being of the projection model more households in existence at 2011 than the 2011 rates.




Chelmer Projections: Migration Table 19

Migration 2011-2016

2016-2021

2021-2026

2026-2031

2011 2031

ave mig 2011 to 2031

2011 interim SNPP (2011/2008HHRR) PA adjustment 7523dwgs 330 447 -63 320 5,166 258 2011 interim SNPP (2008HHRR) last year Mig 476 715 800 800 13,956 698 2011 interim SNPP (2008HHRR) 2010Mig 476 715 640 700 12,656 633 2010 SNPP (2008HHRR) 408 623 555 527 10,559 528 2011 interim SNPP (2008HHRR) last year Mig PA adjustment 476 715 800 800 13,956 698 2011 interim SNPP (2011/2008HHRR) last year Mig PA adjustment 476 715 800 800 13,956 698 2011 interim SNPP (2011HHRR) last year Mig PA adjustment 476 715 800 800 13,956 698 2011 interim SNPP (2011HHRR) PA adjustment 2200 labour force 750 900 1,000 960 18,050 903 2011 interim SNPP (2011HHRR) PA adjustment 5200 labour force 900 1,100 1,280 1,200 22,400 1,120 2011 interim SNPP (2011HHRR) PA adjustment 6400 labour force 885 1,150 1,350 1,450 24,175 1,209 2011 interim SNPP (2011/2008HHRR) PA adjustment Migration for 7760 labour force 3.8% vacancy 1,120 1,300 1,350 1,450 26,100 1,305

5.37 In terms of migration the dwellings lead forecast suggest that there will be a lower level

of net migration of only some 258 net migrants a year compared to the previous lowest level of any of the government forecasts of 550 (see tables 1 and 2). In terms of the higher levels of migration required to meet the economic needs of the area these are not considered to be unrealistic given the levels projected by the previous government projections of up to 1,000 migrants a year. The more recent evidence of likely increased migration from London and the South East which will impact both directly in terms of increased migration from these locations but also indirectly as the demographic pressure ripples out from these locations also suggest that the low level of implied migration by the residual dwelling requirement is too low and may have implications for surrounding authorities.

5.38 The implications for the population of Stroud of providing the various levels of housing discussed in this report are illustrated in the charts below. The first chart summarises the changes over the plan period as a result of the plans preferred level of housing provision. This shows the differential between population growth and changes to the labour force as a result of the ageing population, in particular it illustrates the very small additions to the existing labour force which may impact adversely on the local economy.

5.39 The charts show the implications of the proposed level of dwelling provision to meet the 5,200 forecast jobs taking into account the 2011 interim household projection headship rates.




Chart 3: Summary of demographic change in Stroud Borough over the period 2006 to 2031 as a result of the Local Plan level of dwelling provision

Chart 4: Summary of demographic change in Stroud over the period 2011 to 2031 as a result of the level of dwelling provision based upon increasing the labour force by 5,200 to match forecast job growth




5.40 The next three charts show the age/sex of the 2011 population of Stroud and compares this with the Local plan dwelling lead projection at 2031 and the migration lead projection that would result in the increase to the labour force by 5,200 at the end of the plan period.

5.41 The difference is that while the population above 65 is similar, the projection for a higher level of migration encourages the in migration of younger migrants of a working age.

Chart 5: Stroud age / sex of population at 2011

Chart 6: Stroud age / sex of population at 2031 as a result of a the local plan proposed level of dwelling provision




Chart 7: Stroud age / sex of population at 2031 as a result of an increased level of migration to support the growth in the labour force by 5,200 persons.

5.42 The above illustrates that the Local plan as currently drafted proposed provides little

scope for economic growth in the period from 2011 onwards.

Conclusion on Chelmer Projections 5.43 The employment based projections range from 10,200 to 17,600 for the period 2011 to

2031. The highest projection assumes job growth of 5,200 and continued out commuting together with a return to 2008 household representation rates and a level of vacancy of 3.8%. This may be regarded as an aspirational but reasonable target for both job and housing growth. It is however acknowledged that job growth might be slower than projected and the ability for household to form and enter the private and affordable markets may not reach the rates projected in the 2008 household projections. Likewise it is possible that the 3.8% vacancy rate might fall. Nevertheless this should be regarded as a realistic bookend to the range of “objectively assessed need”.

5.44 It is as unlikely all the above assumptions will be meet as it is that all of the assumptions that underlie the 2011 interim SNPP projection based on the 2011 Household representative rates (8,187 dwellings 2011 to 2031) will occur. This projection assumes a return to a 3% vacancy rate from the recorded 3.8%, it requires the continuation of the present housing market and in particular the continued inability of those age groups under 35 to form households. In terms of the local economy it signals that the labour force will reduce by 450 and the consequential impact of a virtually static level of available labour will not assist growth in the local economy.




5.45 While these projection lie at either end of the range the middle of the range is populated by a number of scenarios. Of these scenarios the projection based upon the 2011 SNPP which allows for household representative rates to return to 2008 levels by 2031 (11,200 dwellings 2011 to 2031) and the projection that models the increase in the workforce by 5,200 (12,050 dwellings 2011 to 2031) while maintaining the lower 2011 household representation rates (i.e. no improvement in the access to housing for selected groups) would appear to represent a mid-point which could allow for some increase in the labour force and some increase in the access to housing. Taking this all into consideration it is considered that the housing requirement for the period 2011 should be set at 11,200 dwellings.




6.0 Conclusion 6.1 The proposed level of housing in the Pre Submission Draft in the Local Plan of 9,500

dwellings between 2006 and 2031 which equates to 376 dwellings a year is below the latest 2011 Interim Household projections of some 400 dwellings a year which is based upon maintaining the lower rates of headship rates extended for the whole plan period. If account is taken of the suppressed household representation rates in the 2011 Interim Projections and an allowance is made for these rates return to the below long term trend rates of the 2008 household projections then the annual requirement 2011 to 2031 raises to 557 dwellings year or 11,145 dwellings.

6.2 It is recognised that the starting point for the level of dwelling provision should be the 2011 interim projections. However, in order there is credible evidence to suggest a departure from this figure in order to respond appropriately to the Framework. This evidence suggests that the basic projection of 400 dwellings a year needs to be adjusted upwards for the following reasons:

a. It is not considered that the household representative rates in the 2011 interim household projections will persist throughout the whole of the plan period. These suggest low rates of household formation for the under 35’s which is not considered to properly reflect the requirement of the Framework to increase home ownership and therefore a policy decision to increase supply to meet these aspirations is an appropriate response to the requirement of the Framework. This would suggest a minimum housing requirement of about 560 dwellings a year (11,200 for the period 2011 to 2031).

b. The proposed level of dwelling provision will not provide for any increase in the labour force in the remainder of the Plan period. This is considered to be incompatible with the employment projections and the stated employment aspirations of the plan. A modest increase in the available labour force for the period from 2011 is considered to be a more appropriate response to the evidence. This expansion of the labour force can be achieved by increased dwelling provision and this is considered would be better able to accommodate the economic aspirations of the Council. It is accepted that the economic and associated job forecasts are subject to substantial variations however even maintaining the lower headship rates and increasing economic activity of the 60 to 69 age groups there would be a requirement for between 510 and 880 dwellings a year to meet the range of job forecast that appear to lie behind the plan of between 2,200 jobs to 5,200 jobs in the period 2011 to 2031. The highest of these figures is based upon maintaining the existing pattern of commuting while the others match labour force growth to job growth.

c. The level of housing proposed, 376 dwellings per year, will not address the issue of affordability, high mean house prices and the high affordability ratio. While the practice guide suggests that the SHMA should address the impact of the chosen policy on affordability there appears to be no background evidence that addresses this matter. This evidence would suggest that when considering the objectively assessed need then provision above the trend based projections would be justified to address the issue of affordability.




d. The level of housing proposed, 376 dwellings per year would also suggest that the area is accommodate fewer migrants than the nationally consistent projections are expecting and as such this lower level of provision may have implications for the surrounding parts of the Housing Market Area.

e. Furthermore it would not be appropriate to conclude that past rates of migration into the District will remain close to previous levels. There is a strong indication that the rest of the region as well as the West Midlands and especially the South East are likely to significantly undersupply housing. As this under provision has not been modelled in the CLG projections then the resulting levels of out migration from these areas have been under represented. It is therefore appropriate for the Local Plan to assume higher levels of in migration from these regions. The general approach in the rest of the South West would also seem to be one of undersupply as such it is unlikely that the District can offset higher levels of in migration with higher levels of out migration to the rest of the county or the wider Region.

6.3 Taking these considerations into account it is suggested that a dwelling requirement of around 560 dwellings a year would be a more appropriate requirement. This would require some 11,200 dwellings for the period 2011 to 2031. It is recognised that this is below the requirement that would be required to meet the higher forecasts for new jobs especially if account is taken of the existing pattern of commuting, the potential for improved access to housing for the under 35 age groups or the higher rates of vacancy assumed by the Council and suggested by the 2011 census.

6.4 The evidence produced by GAM suggests a different spatial distribution between the Gloucestershire districts with demand concentrated within Gloucester itself. While these are not determinative it highlights that in considering the distribution with Stroud some consideration should be given to the relationship between the district and the town both in terms of this potential level of demand and, more importantly in our view the established links between the two areas in respect of migration and travel to work patterns.




Appendix 2: Further Scenario Testing

Dwelling change 2011 - 2031 Ave 2011 to 2031 2011 Half Trend PA adjustment 3800 jobs 11,576 579 2011 Half Trend PA adjustment 5500 jobs 12,694 635 2011 Half Trend PA adjustment dwgs 7,520 376 Labour force change 2011 - 2031 Ave 2011 to 2031 2011 Half Trend PA adjustment 3800 jobs 3,800 1 2011 Half Trend PA adjustment 5500 jobs 5,500 275 2011 Half Trend PA adjustment dwgs -2,650 -133 Population change 2011 - 2031 Ave 2011 to 2031 2011 Half Trend PA adjustment 3800 jobs 21,727 1,086 2011 Half Trend PA adjustment 5500 jobs 24,644 1,232 2011 Half Trend PA adjustment dwgs 11,006 550 Migration 2011 - 2031 Ave 2011 to 2031 2011 Half Trend PA adjustment 3800 jobs 20,420 1,021 2011 Half Trend PA adjustment 5500 jobs 22,830 1,142 2011 Half Trend PA adjustment dwgs 11,187 559

Assumptions for Chelmer model for Employment led forecasts Employment projections – Pensionable age In order to reflect the impact of the change in pensionable age the modelling of economic activity rates has taken into account both the changes that the ONS suggest have occur to 2011 and a further increase in the 60 to 64 age groups (2.5% for each of the two 5 year periods 2011 to 2021 and then held constant) and 65 to 69 age groups (5% for each of the two year periods 2011 to 2021 and then held constant)

2001-06 2006-11 2011-16 2016-21 2021-26 2026-31 2031-36

Males 60-64 0.612 0.639 0.655 0.671 0.671 0.671 0.671

65-69 0.437 0.554 0.582 0.611 0.611 0.611 0.611 Females

60-64 0.345 0.388 0.398 0.408 0.408 0.408 0.408 65-69 0.145 0.070 0.073 0.077 0.077 0.077 0.077

Employment projections - commuting In terms of the modelling of economic activity rates both the changes that the ONS suggest have occurred to 2011 and a further increase in the 60 to 64 age groups (2.5% for each of the two 5 year periods 2011 to 2021 and then held constant) and 65 to 69 age groups (5% for each of the two year periods 2011 to 2021 and then held constant)

It should be noted that this approach to commuting will increase the level of housing requirement to meet a set level of employment growth in area that has net out commuting, but will decrease the level of housing required to meet the employment forecasts in locations which have net in commuting.




Household Representation Rates It has been assumed, in accordance with market indicators, that the depressed rates of household formation contained in the 2011 interim projections will start improving from 2016 onwards (providing of course there is the increase in supply to accommodate this demand); It has further been assumed that rather than just tracking the long term trend there will be an adjustment back towards the long term trend from 2016 onwards so that the household representation rate (HRR) reaches the midpoint between the 2011 HRR and the 2031 HHR by 2031. While this does not achieve the long term trend by 2031 it is considered that this partial return to trend will increase the opportunity for households to form and increase the opportunities for home ownership.




Appendix 3: Output of the Experian Economic Forecast

UK Local Market Forecasts Quarterly

Levels

Annual

2001 2006 2011 2016 2021 2026 2031

South

West

Gloucester

shireStroud Output GVA Total Output (GVA) (£mn CVM 2010 prices) 1743.98 1970.47 1928.14 2065.24 2272.86 2509.31 2763.57

GVA by Industry,

broad sectorsAgriculture, Forestry & Fishing (£mn CVM 2010 prices) 17.1 23.95 22.23 24.2 24.89 25.4 25.82

Extraction & Mining (£mn CVM 2010 prices) 0.91 0.57 0.08 0.03 0.05 0.04 0.04

Manufacturing (£mn CVM 2010 prices) 407.93 481.06 530.36 573.73 594.76 623.9 653.32

Utilities (£mn CVM 2010 prices) 204.45 165.48 91.21 80.11 88.03 89.6 90.09

Construction (£mn CVM 2010 prices) 142.34 154.05 164.02 181.89 218.49 249.41 279.17

Wholesale & Retail (£mn CVM 2010 prices) 174.18 199.25 187.46 216.07 244.53 277.88 314.29

Transport & storage (£mn CVM 2010 prices) 64.37 81.49 74.42 76.11 82.51 90.35 98.72

Accomodation, Food Services & Recreation (£mn CVM 2010 prices) 69.08 75.04 72.48 80.81 92.02 106.22 120.58

Information & communication (£mn CVM 2010 prices) 50.22 58.98 90.59 110.45 123.29 139.45 159.09

Finance & Insurance (£mn CVM 2010 prices) 40.49 54.79 43.35 37.62 45.2 52.6 60.17

Professional & Other Private Services (£mn CVM 2010 prices) 311.18 370.72 350.21 367.15 420.4 482.11 552

Public Services (£mn CVM 2010 prices) 261.68 305.04 301.68 317.02 338.65 372.28 410.23GVA by Industry,

categoriesAgriculture, Forestry & Fishing (£mn CVM 2010 prices) 17.1 23.95 22.23 24.2 24.89 25.4 25.82

Extraction & Mining (£mn CVM 2010 prices) 0.91 0.57 0.08 0.03 0.05 0.04 0.04

Food, Drink & Tobacco (manufacture of) (£mn CVM 2010 prices) 63.2 84.86 92.39 95.06 97.78 99.44 100.98

Textiles & Clothing (manufacture of) (£mn CVM 2010 prices) 8.77 11.07 15.66 18.15 17.4 16.58 15.78

Wood & Paper (manufacture of) (£mn CVM 2010 prices) 15.28 11.55 8.77 8.63 8.63 8.23 7.84

Printing and Recorded Media (manufacture of) (£mn CVM 2010 prices) 25.12 17.99 15.5 15.44 15.13 14.76 14.59

Fuel Refining (£mn CVM 2010 prices) 4.1 5.78 0.98 0.11 0.21 0.17 0.13

Chemicals (manufacture of) (£mn CVM 2010 prices) 9.07 10.38 11.23 10.6 11.46 12.2 12.92

Pharmaceuticals (manufacture of) (£mn CVM 2010 prices) N/A N/A N/A N/A N/A N/A N/A

Non-Metallic Products (manufacture of) (£mn CVM 2010 prices) 32.85 31.71 27.51 29.8 35.23 38 39.72

Metal Products (manufacture of) (£mn CVM 2010 prices) 53.52 63.53 68.4 70.7 77.79 85.03 92.72

Computer & Electronic Products (manufacture of) (£mn CVM 2010 prices) 87.33 108.65 140.62 178.67 184.61 198.19 213.38

Machinery & Equipment (manufacture of) (£mn CVM 2010 prices) 62.74 80.43 105.17 104.26 100.06 101.51 102.15

Transport Equipment (manufacture of) (£mn CVM 2010 prices) 28.09 36.36 18.88 13.77 16.72 19.24 21.94

Other Manufacturing (£mn CVM 2010 prices) 17.81 18.69 25.19 28.5 29.71 30.49 31.13

Utilities (£mn CVM 2010 prices) 204.45 165.48 91.21 80.11 88.03 89.6 90.09

Construction of Buildings (£mn CVM 2010 prices) 50.77 54.52 62.21 64.05 76.08 86.85 97.79

Civil Engineering (£mn CVM 2010 prices) 37.36 39.69 32.18 36.11 44.01 50.5 57.07

Specialised Construction Activities (£mn CVM 2010 prices) 54.2 59.83 69.62 81.73 98.38 112.05 124.29

Wholesale (£mn CVM 2010 prices) 82.6 99.67 94.32 111.2 126.89 145.92 167.08

Retail (£mn CVM 2010 prices) 91.58 99.57 93.14 104.86 117.63 131.96 147.21

Land Transport, Storage & Post (£mn CVM 2010 prices) 63.08 80.63 74.11 75.96 82.33 90.16 98.51

Air & Water Transport (£mn CVM 2010 prices) 1.28 0.85 0.3 0.14 0.17 0.19 0.2

Accommodation & Food Services (£mn CVM 2010 prices) 43.66 45.64 47.24 54.19 61.74 71.09 80.38

Recreation (£mn CVM 2010 prices) 25.41 29.4 25.24 26.61 30.28 35.13 40.2

Media Activities (£mn CVM 2010 prices) 24.21 20.83 24.13 29.48 32.09 35.07 38.4

Telecoms (£mn CVM 2010 prices) 1.14 4.45 14.19 15.51 17.64 20.62 24.16

Computing & Information Services (£mn CVM 2010 prices) 24.86 33.7 52.26 65.45 73.54 83.75 96.53

Finance (£mn CVM 2010 prices) 40.47 54.64 42.97 37.18 44.77 52.16 59.73

Insurance & Pensions (£mn CVM 2010 prices) 0.01 0.15 0.38 0.43 0.43 0.43 0.43

Real Estate (£mn CVM 2010 prices) 156.18 165.79 121.7 133.8 154.27 175.59 198.58

Professional Services (£mn CVM 2010 prices) 68.68 107.83 127.67 135 155.53 181.01 210.79

Administrative & Supportive Services (£mn CVM 2010 prices) 45.43 59.11 65.91 68.72 78.36 90.47 104.65

Other Private Services (£mn CVM 2010 prices) 40.89 37.97 34.92 29.61 32.23 35.03 37.97

Public Administration & Defence (£mn CVM 2010 prices) 48.78 50.32 41.36 41.49 42.19 43.75 45.31

Education (£mn CVM 2010 prices) 128.69 144.58 142.34 137.46 139.95 145.49 151.22

Health (£mn CVM 2010 prices) 49.51 65.38 73.07 88.46 100.5 117.41 137.05

Residential Care & Social Work (£mn CVM 2010 prices) 34.68 44.75 44.88 49.59 56 65.61 76.64

Employ

ment

Summary Statistics

for Labour MarketTotal FTE employment (Thousands) 37.16 37.77 37.66 40.27 40.67 40.93 41.46

Workforce jobs (Thousands) 47.61 51.73 54.55 58.29 58.73 59.55 60.37

Total employees in employment (Thousands) 40.65 44.62 45.49 48.43 48.69 49.26 49.79

Total self employed (Thousands) 6.4 6.62 8.64 9.51 9.72 10 10.3

FTE Employment, Agriculture, Forestry & Fishing (Thousands) 0.58 0.63 0.43 0.54 0.49 0.44 0.42

Extraction & Mining (Thousands) 0.05 0.04 0.02 0.01 0.02 0.02 0.02

Manufacturing (Thousands) 9.98 9.24 9.55 9.79 8.71 7.87 7.17

Utilities (Thousands) 1.43 0.86 0.68 0.73 0.76 0.77 0.77

Construction (Thousands) 2 2.53 2.47 2.68 2.92 3.11 3.32

Wholesale & Retail (Thousands) 5.17 5.09 4.97 5.33 5.55 5.7 5.85

Transport & storage (Thousands) 1.56 1.73 2.13 2.2 2.36 2.53 2.7

Accomodation, Food Services & Recreation (Thousands) 3.04 2.98 2.94 3.61 3.93 4.2 4.48

Information & communication (Thousands) 1.02 0.92 1.09 1.4 1.42 1.4 1.39

Finance & Insurance (Thousands) 0.56 0.5 0.39 0.37 0.4 0.43 0.44

Professional & Other Private Services (Thousands) 4.54 5.43 5.08 5.32 5.54 5.61 5.72

Public Services (Thousands) 7.17 7.77 7.86 8.24 8.5 8.8 9.11

FTE Employment, Agriculture, Forestry & Fishing (Thousands) 0.58 0.63 0.43 0.54 0.49 0.44 0.42


Food, Drink & Tobacco (manufacture of) (Thousands) 1.33 1.51 1.53 1.68 1.67 1.63 1.59

Textiles & Clothing (manufacture of) (Thousands) 0.27 0.18 0.2 0.0011 0.0017 0.0076 0.0017

Wood & Paper (manufacture of) (Thousands) 0.42 0.27 0.18 0.13 0.1 0.08 0.07

Printing and Recorded Media (manufacture of) (Thousands) 0.72 0.43 0.36 0.34 0.31 0.27 0.24

Fuel Refining (Thousands) 0.01 0.01 0.0038 0.0027 0.0026 0.0023 0.0022

Chemicals (manufacture of) (Thousands) 0.13 0.13 0.12 0.11 0.09 0.08 0.06

Pharmaceuticals (manufacture of) (Thousands) N/A N/A N/A N/A N/A N/A N/A

Non-Metallic Products (manufacture of) (Thousands) 0.9 0.68 0.52 0.52 0.48 0.43 0.38

Metal Products (manufacture of) (Thousands) 1.36 1.33 1.57 1.72 1.59 1.43 1.28

Computer & Electronic Products (manufacture of) (Thousands) 1.76 1.75 2.37 2.72 2.36 2.18 2.05

Machinery & Equipment (manufacture of) (Thousands) 1.77 1.7 1.78 1.67 1.25 0.97 0.76

Transport Equipment (manufacture of) (Thousands) 0.71 0.71 0.32 0.3 0.29 0.26 0.24

Other Manufacturing (Thousands) 0.53 0.49 0.56 0.56 0.52 0.49 0.46


Construction of Buildings (Thousands) 0.42 0.57 0.63 0.62 0.67 0.72 0.78

Civil Engineering (Thousands) 0.53 0.64 0.44 0.42 0.46 0.48 0.5

Specialised Construction Activities (Thousands) 1.04 1.31 1.39 1.63 1.79 1.91 2.04

Wholesale (Thousands) 1.97 2.09 2.19 2.32 2.45 2.54 2.63

Retail (Thousands) 3.2 3 2.78 3.01 3.1 3.15 3.22

Land Transport, Storage & Post (Thousands) 1.54 1.72 2.12 2.2 2.36 2.52 2.7

Air & Water Transport (Thousands) 0.02 0.0088 0.0035 0.0019 0.0021 0.0021 0.0022

Accommodation & Food Services (Thousands) 2.31 2.24 2.24 2.96 3.24 3.47 3.71

Recreation (Thousands) 0.72 0.74 0.69 0.64 0.69 0.73 0.77

Media Activities (Thousands) 0.25 0.17 0.15 0.17 0.17 0.16 0.16

Telecoms (Thousands) 0.03 0.06 0.12 0.11 0.11 0.1 0.1

Computing & Information Services (Thousands) 0.73 0.68 0.8 1.1 1.13 1.12 1.12

Finance (Thousands) 0.56 0.5 0.39 0.36 0.4 0.43 0.44

Insurance & Pensions (Thousands) 0.00018 0.00099 0.0017 0.0017 0.0017 0.0016 0.0016

Real Estate (Thousands) 0.32 0.4 0.32 0.43 0.46 0.48 0.49

Professional Services (Thousands) 1.63 2.3 2.41 2.57 2.69 2.75 2.83

Administrative & Supportive Services (Thousands) 1.84 1.95 1.75 1.79 1.85 1.85 1.87

Other Private Services (Thousands) 0.74 0.77 0.59 0.52 0.53 0.52 0.52

Public Administration & Defence (Thousands) 0.96 1.04 0.78 0.64 0.65 0.64 0.64

Education (Thousands) 2.9 3.1 3.15 3 3 3.04 3.07

Health (Thousands) 1.67 1.75 1.69 2.01 2.11 2.21 2.32

Residential Care & Social Work (Thousands) 1.63 1.87 2.22 2.57 2.74 2.89 3.06

Employees, broad Agriculture, Forestry & Fishing (Thousands) 0.55 0.7 0.5 0.56 0.53 0.5 0.47




Construction (Thousands) 1.79 2.45 2.54 2.74 2.92 3.09 3.28








Employees, Agriculture, Forestry & Fishing (Thousands) 0.55 0.7 0.5 0.56 0.53 0.5 0.47




















Retail (Thousands) 4.28 4.35 4.01 4.24 4.36 4.44 4.52



Accommodation & Food Services (Thousands) 2.74 3 3.25 4.23 4.48 4.7 4.95












Education (Thousands) 4 4.67 4.8 4.58 4.65 4.82 5

Health (Thousands) 2 2.23 2.27 2.66 2.79 2.92 3.06


Self Employment, Agriculture, Forestry & Fishing (Thousands) 0.4 0.39 0.82 0.46 0.48 0.5 0.51

Extraction & Mining (Thousands) 0.002 0.0002 0.0034 0.0048 0.0054 0.0061 0









Professional & Other Private Services (Thousands) 1.66 1.59 1.93 2 2.19 2.39 2.56


Self Employment, Agriculture, Forestry & Fishing (Thousands) 0.4 0.39 0.82 0.46 0.48 0.5 0.51

Extraction & Mining (Thousands) 0.002 0.0002 0.0034 0.0048 0.0054 0.0061 0





Fuel Refining (Thousands) 1.30E-09 0.00026 0.00044 0.001 0.00013 0.000041 0.000003
















Air & Water Transport (Thousands) 0.0014 0.00016 0.00012 8.3E-05 0.00009 0.000083 0







Insurance & Pensions (Thousands) 2.6E-06 8.5E-06 5.1E-05 6.6E-05 6.8E-05 0.000068 0.000067






Education (Thousands) 0.17 0.27 0.51 0.59 0.67 0.81 1.01



Workforce jobs, Agriculture, Forestry & Fishing (Thousands) 0.96 1.09 1.33 1.02 1.02 1.01 0.99












Workforce jobs, Agriculture, Forestry & Fishing (Thousands) 0.96 1.09 1.33 1.02 1.02 1.01 0.99



































Education (Thousands) 4.17 4.94 5.31 5.18 5.32 5.63 6.02


Residential Care & Social Work (Thousands) 2.46 2.78 3.2 3.72 3.94 4.14 4.36Unempl

oyment

&

Demogr

aphics

Population Working age population (Thousands) 64.77 65.15 64.84 66.86 68.24 67.92 67.16

Total population (Thousands) 108.17 109.92 112.13 114.1 116.77 119.46 121.84

Unemployment LFS unemployment (Thousands) 1.83 2.19 3.28 2.53 2.36 2.08 1.91

LFS employment (Thousands) 56.1 52.76 56.46 61.19 63.66 65.9 68.21

Househo

ld sectorOther Household disposable income (£mn, current prices) 1349.25 1615.21 1929.16 2309.94 2782.79 3414.22 4226.31

Household disposable Income (£mn CVM 2010 prices) 1661.8 1813.81 1855.91 1997.9 2198.26 2431.44 2701.26

Household spending, Nominal (£mn, current prices) 1218.72 1650.89 2017.76 2480.76 2970.51 3603.76 4360.95

Household spending, Real (£mn CVM 2010 prices) 1501.05 1853.71 1941.13 2143.09 2344.07 2563.08 2785.85

Cost of Living Index (2010=100) N/A N/A N/A N/A N/A N/A N/A

House Price Index (*UK regions only) (2010=100) N/A N/A N/A N/A N/A N/A N/A

Date extracted: 25 February 2014

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Appendix 4: Potential location of development on edge of Gloucester

Convenience Store

Library

Private School

Primary School

Community Centre

Nursery/Infant School

Secondary School

Doctor's Surgery

Place of Worship

Public House

Park/Public Open Space

500m

2,000m

1,500m

2,500m

1,000m

Dentist

Bus Route/Stop

Community Facilities Map

© Crown Copyright 2008. All rights reserved. Licence number 100020449. Plotted Scale - 1:10000

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