Local Plan Examination Day 3

Day 3 was spent arguing about discussing the SHMA, how it was designed, conducted, its assumptions and what possible evidence there could be to support the unprecedented forecast of huge growth in jobs and housing need.

Here’s a link to the Oxford Times article yesterday about the housing figures. It’s written by¬† Julie Mabberly, of Wantage and Grove Campaign Group: fantastic housing figures.

If I had been QC, at the table, here are the five points I would have made in summation:

  1. Vale claim repeatedly that SHMA figures are robust and fair. Only the developers and their agents seem to agree with this and they urge that this plan be adopted now. Parishes, open space proponents and ordinary people mostly disagree. If it’s true that SHMA is robust and fair, but most people see it as not so, then the quality of the communication and scrutiny is surely questionable.
  2. There is great irreversible harm associated with adoption of a Local Plan based on an unrealistically high housing need figure. Housing sites in green spaces, including the Green Belt (GB) and Areas of Outstanding Natural Beauty (AONB), are more likely to be brought forward first; they are less costly to develop than brownfield sites, so would be preferred by developers in order to maximise their profits. Some priority should be given to development of brownfield sites, before greenfield, then AONB, and finally GB (as GB is most protected) to ensure the permanent loss of irreplaceable space or beauty happens last, and only if needed. Of course all this applies only if we accept that housing need is exceptional enough to lose forever our Green Belt and AONB. The inspector will decide that.
  3. Corporations don’t plan 15-20 years ahead. It would be the rare one who even planned 5 years ahead. And they always forecast optimistic growth. No company would forecast stagnation. None would say, ‘We will be out of business in 8 years, with the loss of 2000 jobs.” No one would admit to a problem that’s just been exposed in Volkswagen. So of course the (unelected and unaccountable) LEP (Local Enterprise Partnership) would forecast optimistic business success and unprecedented economic growth, wouldn’t they?
  4. Vale’s Scrutiny Committee were frustrated when the SHMA report came before us. Every attempt we made to evaluate their process, assumptions, baseline, or any other part of it was obstructed. For the most part, we were told that we couldn’t see how the SHMA was done as the data manipulation (sorry, ‘modelling’) was a proprietary secret. We were told by senior Vale officers that we just had to accept the SHMA as it was.
  5. Government Guidance and the SHMA legislation itself told us explicitly that SHMA was not to be accepted as our final housing target. It was a baseline against which local constraints and issues of capacity were to be applied. It is relevant that we have constraints such as Green Belt and AONB and highways capacity and Flood Zones and maybe even builders’ capacity to build houses. (Vale’s average is about 400 houses per year. Best ever was just over 800. The new targets require 1028 per year to be built. How is that deliverable?) The Vale refused to perform that step and repeatedly asserted that they were forced to accept the full SHMA as our Obectively Assessd Need ‘in accordance with national policy’.

These are the reasons the Liberal Democrat Group continue to oppose a Local Plan that uses the un-assessed SHMA figure as our inflated housing target.

If this high figure is to remain the target, then a Plan-Implement-Review- Repeat approach could help us prevent over-development. But the scramble to claim GB and AONB land for easily profitable housing development will be ensured, I fear.