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STROUD LOCAL PLAN

RESPONSE TO INSPECTOR’S QUESTIONS FOR THE EXAMINATION IN PUBLIC

FEBRUARY 2014

© Don’t Strangle Stroud 2014 Issued by Community Group ‘Don’t Strangle Stroud’ Peer Reviewed by Mr. I Bickerton, Bristol University

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Introduction Paragraph 8.5 of the Guidance Notes recommends participants to try to agree factual matters and statistics. In this regard we have co-operated closely with Mr Ian Stuart and Dr Richard Fordham on behalf of Eastington Parish Council and ‘Keep Eastington Rural’. We share many objectives and opinions. To add further confidence, this evidence base has been peer-reviewed by a leading Bristol University statistician who provides his statement in appendix E. As a background to responding to the Inspectors questions for the EIP in April it is important to recognise that a real tension exists between:

A. The requirement in the NPPF for local plans to be informed by a sound and objective assessment, based on the latest datai. and

B. A perceived political imperative to go for ‘growth’ and plan for much increased house-buildingii.

This dilemma exposes itself in five specific ways, as follows: Falling ONS Population Projections ONS long-term population growth projections have consistently fallen since the 2006-based projections published in 2008iii, they fell again in the 2010iv publication, again in the 2012v publication and yet again in the 2013vi publication for England. This is summarized in a table and graph in the DSS evidence documentvii This is a dramatic drop of 8,200 people in the plan period (75% less growth) from the 2006 to the 2010-based projections. The Argument for the highest ‘growth’ is only supported by out-of-date and stale data, which is non-compliant with the requirements of the NPPF. A Fallacy- Unsound Logic It is easy to confuse higher economic growth (so called ‘pre-recession’ growth) with population growth. The fall in the Household Projections is fundamentally due do the reduction in the population projection. No current submission to this EIP, nor any ONS or DCLG evidence, is available to link the fall in population projection to the recession. Evidence of previously unfactored immigration changes None of the population or housing projections from the ONS or DCLG recognise forward change in government policyviii. The ONS project that 60% (6 million) of the population growth over the next 25 years is driven by net migration and the associated birthrate changeix. The Government is committed to reducing net migration ‘over the lifetime of this parliament to tens of thousands’. So far there has been a declared 30% reduction since 2010x. The published government policy on immigration, if achieved, will result in a 30% reduction in population growth (and thus housing need) over the plan period.

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Avoiding the myth It is a myth that, on average, more people are living alone, so causing a need for more houses for a given population level. The DCLG used to hold this opinion in their 2008 based projection iv. However DCLG now show that the average household size has not significantly changed for the last three census pointsxi A ‘reality check’ for soundness Historically Stroud District has seen a rate of population growth of 4.5% per decade (between the 2001xii and 2011xi census), and this has been unaffected by the recession. However, the draft Local Plan housing requirement of 9,500 targets a rate of population growth of 5.8% over the next decadexiii. This is contrary not only to past experience, but also to the ONS guidance that the population growth is slowingvi. Equally unsound is the fact that Stroud District has seen a housing growth of 3,300 houses in the last decadexii & xi, but is planning for an increase of 4,060xiii in the next decade. This is in contrast to a backdrop of declining population projections. So the data presented by the local planning team to support this may respect the political imperative but is neither sound nor objective. A sound and objective and updated evidence base, incorporating the latest 2012 ONS release, resides in the DSS submission and the answers here to the inspector’s questions.

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MATTER 1 - HOUSING REQUIREMENT

2.1 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?

The Council’s proposed Housing requirement of 9,500 houses was tested by an external consultant. His approach was at face value both sound and objective, as he built his conclusions around economic projections, employment history and projections, ONS population projections, trends and the DCLG releasesxiv. However, as stated in this evidence base, the consultant was engaged to provide ‘A robust and independent review of the derivation of the housing and population numbers in the Core Strategy’ The consultant’s brief was not ‘to determine SDC’s projected housing need‘. In this endeavour, the consultant made a number of errors and assumptions that had the effect of inflating the stated housing requirement. Additionally, this report has not been through any peer review or survived any scrutiny check.

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?

The Plan exceeds the objectively assessed needs for market and affordable housing, due to the errors and incorrect assumptions made by the consultant who advised SDC. This will have the adverse impact that has been seen elsewhere, where the over-projection of housing leads to “under delivery to plan”, and thus a penalty to the council for under-supply of housing as the five-year land supply cannot be maintained, resulting in more housing planning applications being passed that cannot be met by the developer. With such an oversupply of planning permissions this leaves the developer free to select sites based on profitability rather than a good planning priority guided by the NPPF. This is to the detriment of good planning and disastrous for the district. c. What is the basis, justification and methodology for the proposed level of housing provision, and are

the assumptions robust and justified:

The Council employed a consultant to justify the specific housing numbers proposed by SDC. In doing so, the consultant has made a number of critical errors and assumptions which undermine the robustness and justifications for the housing number proposed. All of the errors we found in the consultant’s report were in one direction and all resulted in an inflated housing figure. See Appendix A

i. Does it have sufficient regard to the supporting and other relevant evidence, including the

various SHMAs & SHLAAs;

The Local plan fails to make use of several key pieces of local data and evidence; for example, no data from the Revenue Department (Council Tax) has been used concerning single-person occupancy – in spite of this being brought to SDC attention.

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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;

To achieve the NPPF requirement for being objectively assessed, adequate, relevant and up-to-date, the ideal source for Population data would be the ONS 2012, census based, full horizon, subnational projection. This is only available for England currently, not subnational. The next most adequate, relevant and up-to-date source is the ONS 2010-based subnational population projections, as it is by district and projects beyond the 2031 plan timeframe. Though not fully up-to-date, it can be correlated to the very latest ONS census report for the trends published for England. Using 2008-based Data would not be up-to date (now 7 years out of date) and not corrected to the 2011 Census. Using 2011-based Data would not be adequate, as the publishers (ONS) have declared it unsuitable for long-range projection (beyond 2021). There is now up-to-date information regarding the relevant government Immigration policy. The effects of which are not reflected in any of the ONS or DCLG projections, or the Local Plan. If the recent government policy to reduce net migration is applied to the 9,500 figure in the local plan, then the local plan housing need would reduce to 7,500 houses, in the plan period. In a number of developer submissions, there is a dominant promotion of the 2008-based projection as being “pre-recessionary”, and suggestions that the 2008 data must be used as this predates the “recession”. This is untrue - there is no evidence presented that links the reduction in population projections with the recession. The reduction in housing numbers in the ‘recession’ period is primarily driven by the reduction in ONS population projections. To suggest otherwise lacks any credibility. In attempting to convince the reader to use the 2008-based projections, one submission characterizes

the 2008 and 2011-based projections as being ‘relatively similar’. No credible statistician could ever

describe these two (very different) projections as “relatively similar”. This is one example of the

mistaken and false analyses presented in submissions to the local plan.

Adhering to the requirements of the NPPF, however the current plan is analysed, the only conclusion that can be made is that the proposed housing number is too high. Appendix B contains an in-depth and structured analysis of these population/household projections.

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?

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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)?

The plan makes no account of the current economic situation. It is extremely important to note that the Household Projections make no assumptions of future economic and market factors – they are only a projection of the last five year trend.

DSS fully support the economic appraisal identified in the AVOCA submission which supports this.

The plan has assumed two jobs per new household to deliver its additional 6,200 new jobs in the plan period. This is unrealistic and without any relevant evidence base. All references to this should be removed, and replaced with an evidence-based number of jobs per household (in the region of 1.1 jobs per household – from the K Woodhead’s report)

The plan, while it makes reference to the fact that the rise in the population in the plan period is in the over-65’s, there is no reference to house building that responds to this changing demographic need (see KER report R114 Tom Low, 25 Feb 2014 submitted to the Inspector)

The 2013 SHMA is not an adequate or relevant indicator of the number of affordable houses that need to be built in the plan period. The SHMA calculation was not designed to calculate an “affordable dwelling” build rate. The calculation that results in the 578 affordable dwellings per annum is an indicator of the number of households falling into need – not a number of dwellings that need to be built in the plan period.

In response to Barton Willmore’s submission, section 3.11:- In the drive by developers to increase planning permissions, there is a misconception that increasing the numbers of planning permissions will reduce house prices. There is no evidence presented that proves that this is true, indeed, in the recession, when prices fell, developers stopped building houses. House affordability is determined by the developer and landowner, and reinforced by the House Builders Federation, who state that developers are unwilling to accept profit margins of 9% on affordable homes, preferring 20%. The minimum income required to purchase a house is £45,000 (see AVOCA submission). This is almost double the average household income in Stroud.

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?

There is no one definitive method or dataset available that will accurately give our housing need in the plan period.

The most rigorous statistical course of action would be to compare the most up-to-date and relevant projections that are available and “triangulate” a housing need.

The first method to create a sound estimate of housing requirement, is to use the most sound available data, based on population and AHS data.

Unfortunately, these are not presented in one consistent data release, until later this year.

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In the meanwhile, the most sound population projection resides in the 2010-based data and the most sound AHS data is calculated from the 2008-based DCLG data (if corrected to match the 2011 census). The validity of these choices is described in a “pros & cons” analysis in Appendix C

This approach gives a requirement of 8,900 houses in the plan period.

Alternatively if we apply the 2010-based population data correction to the 2011-based interim household projections used in the Plan, the resulting housing requirement would be 8,100 houses in the plan period.

A third methodology would be to use the historic (pre-recessionary) housing build rate, and carry it forward for the duration of the plan. The suggested housing requirement would then be 8,380 in the plan period.

In conclusion, a triangulated result bracketed by all three methods would be the 8,500 figure recommended. An expansion of this methodology is in appendix C.

DSS Reccomendation:-

So we recommend the following text changes in the Local Plan:

Page 9 para 1 should read “Projections suggest that 8,500 new homes ….”

Page 19 para 2.10 point three “It addresses the need through planned provision of 8,500 new homes

up until 2031”

The effect of Immigration:-

The effect of a declared immigration policy would be to reduce these projections further by at least 1,000 houses, to 7,500. This emphasizes that our recommendation is a maximum housing level that could be justified.

a. 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?

A correction to 8,500 would increase the land supply to approximately 8.3 years. see page 13 of DSS submission “Stroud Housing Evidence Base, July 2012 (Updated 2011 census) Additionally, Windfall allowance, which has a substantial evidence base, and historically represents a large number of delivered houses (83 per year on average) has only been included at half this rate with no explanation or evidence for this lower figure.

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b. How does the Plan address the need for a 5/20% buffer to 5-year housing land supply, as required by

the NPPF (¶ 47) to significantly boost housing supply, and address any past shortfalls in provision

of housing?

A correction to 8,500 would increase the land supply to approximately 8.3 years. There is no shortfall in planned housing provision. As per page 13 of DSS submission “Stroud Housing Evidence Base, July 2012 (Updated 2011 Census)

c. 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?

The plan states that there will be 750 windfall houses built in the remaining plan period (this averages 40 per year). This number has been presented without any evidence. The plan should use an evidence based number of windfall houses – for Stroud, this would be 1,577 remaining windfall houses in the plan period (This average of 83 per year). This number comes directly from the published five-year land supply contained within the Local Plan. It is important to note that these windfall houses are built in addition to the developments recognised in the Local Plan, so underestimating this number will only serve to increase oversupply by 750 planning permissions in the plan period.

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MATTER 2 - EMPLOYMENT REQUIREMENTS

2.2 EMPLOYMENT REQUIREMENTS: The Plan proposes an additional 6,200 new jobs (2006-

2031) and 37ha of new

employment land (2012-2031) within Stroud district over the plan period.

a. What is the basis for this level of employment land provision, including the various economic

scenarios and forecasts, and how will this provision be delivered effectively in terms of existing

commitments and future allocations?

The employment strategy makes a clear argument in favour of knowledge-based jobs growth, but the plan then proposes warehousing and/or factory jobs at Stonehouse . We have argued that this will severely reduce access to Stroud and the valleys where 60% of the district jobs are to be found. Both the heavy commercial traffic congestion generated by warehousing and/or factory operations and the materially increased inward commuting would conflict with this use on this site. This proposal at Stonehouse was clearly rejected during public consultation. The Local Plan should be modified to remove this reference to major additional Stonehouse employment. (Local Plan Page 20 para 2.13, Page 50, para 3.16, Page 52 para 3.17,Page 53 para 3.18)

Evidence supported by The Federation of Small Businesses exists as follows to support this: A survey of all employers in the Parish of Eastington and the large employers in Stonehouse took place in 2014 and concluded: Small firms (under 20 employees) predominantly employ local people. Those in walking or cycling distance form 60%, and 71% are from within Stroud District.

1. Large firms (over 20 employees) tend to employ people from outside the district. 60% outside the district

2. This survey was in an area with the highest number of affordable houses in the district. So this defies the logic in the local plan that targets major manufacturers and warehousing to provide employment in Stonehouse. See DSS Consultation response page 15 para 3.2

The Local Planning Authority needs to follow through its knowledge-based focus – The plan should state page 11 para41 “past experience suggest a capacity to create additional jobs at around 200 a year to achieve this an emphasis will be placed on creating and supporting small sized industrial units across the district, and helping start-ups with, say, lowered business rates.” b. How will the proposed scale, nature and mix of new employment development address current

employment trends in Stroud district, including commuting imbalances and the need for further

employment in particular employment sectors?

Local jobs have consistently grown at around 200 a year in the district. This has been fairly consistent over the last ten years (see DSS Consultation Response, Page 14 para 3.1. See also AVOCA data), so for every two houses built one will be for a commuter. However above 8,500 houses the evidence suggests that every house would be for an additional commuter. This does not fit the policy that aims to improve the balance of in-commuting and out-commuting. This approach does not match the sustainability criteria.

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Appendices

Appendix A – SDC Consultant’s report – Critique.

The Council has employed a consultant to justify the housing numbers that are proposed by SDC. The consultant has, however failed to independently assess the housing need, and has made a number of critical errors, that include:-

1. Projection of the interim 2011-based DCLG projections beyond the recommended date-range

in paragraph 3.20, Table 4, in Ref xiv. (Contrary to ONS recommendations – see ONS

correspondence in Appendix B)

2. Using stale 2003 RSS-based projections (now 11 years out of date) to prove economic

arguments (table 6 of Rex xiv)

3. Using Stale 2001-based data in table 4, ref xiv. – the 2011 census was available, and not used.

4. Failing to incorporate the 2011 census when it was available in the August 2012 Keith

Woodhead report to SDC1.

5. Failing to incorporate the future retirement age (that is set to change from 65/60 to 67 for

both men and women respectively in the planning period - 2028) in tables 4 & 5 in Ref xiv.

6. Failure to objectively assess the validity of the 2008 DCLG projections – local evidence from

SDC regarding sole occupancy rates show how the 2008 DCLG projections are incorrect – this

has been ignored by suggesting that the council took action to reduce claims which distorted

the figures. This was untrue, as the evidence presented predated any Council action, and

pointed out to KW and Council Officers but ignored – Ref xv.

7. Failure to objectively assess the suitability and accuracy of DCLG and population projections –

in fact, no assessment of suitability is made at all – all projections are given even weight

without reason.

All these errors and assumptions result in an inflated housing figure.

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Appendix B - A Comparison Summary of evidence bases The NPPF demands that all evidence is sound, objective, and uses the latest data. The plan fails to make fully sound and objective assessments of the projections that it uses, and does not make the use of the latest data. The value of the 2008-based DCLG projections:- This is the most flawed of evidence bases as described in DSS Consultation Responsexv: page 4 section 1.1. and DSS Stroud housing Evidence Base July updatedvii: page 5 secion 3.1 2008-based projections have now been removed from the DCLG website suggesting, quite rightly, a lack of confidence in this data.

The value of the 2010-based population projections from the ONS:- The Local Plan does carry out a calculation of housing need based on the 2010 population projections, but uses the 2008-based household formation rates, and thus is open to criticism for the same reasons as the 2008-based projection itself. Additionally, the fact that the 2010 population projections have under-estimated the population by 1,000 at the 2011 census has not been highlighted. The value of the 2011 interim population and household projections:- This is answered in DSS Consultation Response: page 4 section 1.2

1. The population and housing projections have been extended beyond the recommended

maximum 2021 – contrary to ONS recommendation to use the 2010 projections for long term

planning – See Appendix E for ONS guidance.

2. The 2011 projections have been extended using a flawed numerical method. The report (ref

xiv) refers to a “crude calculation” in paragraph A6 that results in a household increase of

10,100 in the plan period, yet does not disclose the method used to achieve this – a linear

projection results in a somewhat lower projected household need of 9,800 houses.

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2012-based population projections:- In November 2013, the ONS released the 2012-based National Population Projections (ref vi). While the 2012-based data is only available at a national level, it can help to inform us of the validity of the previous projections:

1. The ONS have compared 2012 with 2010 National data and shown only a minor population reduction (of 0.2%, see table 6 of the statistical Bulletin in this release).

2. The 2012 data lowers the population projection to 2035 for England from .84% to .7% per

annum reflecting falling net immigration and changes in fertility rates, confirming that the

population projection is falling not rising – see table below, extracted from the 2012 ONS

release (from ref vi).

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The Graph below clearly illustrates the elevated population projection that results from erroneously extending the 2011-based projection beyond it’s 2021 maximum.

It also demonstrates the closeness and similarities of the 2010 and 2012-based long term projections at the 2031 timeframe. Additionally, it shows the dramatic effect that the Immigration cap will have, which is not included in any of the current ONS projections.

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Impact of Government policy changes – Immigration Firstly it is important to note that all the ONS and DCLG projections come with the caveat:-

“The projections do not take into account any future policy changes that have not yet occurred.”

However, the “National Population Projections, 2012-based Statistical Bulletin, Nov 2013” (ref vi), is clear that the main driver for population increase is the effect of net migration, direct and indirect. This is projected by the ONS to be 6 million, 60% of all population increase over the planning period, or 235,000 each year. Again the ONS are quite specific in stating that their projections take no account of changes in Government policy.

The Prime Minister has stated that net immigration will be reduced “to ten’s of thousands within the life of this parliament”. (see attached confirmatory letter from the Home Office, Visas and Immigration in Appendix D). To achieve this it describes how a cap has been placed on Non EU immigration (in November 2010). Non EU immigration is 48% of the total net migration (ONS). The cap has the effect of reducing non EU net migration by around 1 million over the planning period. The Immigration Bill going through parliament will reduce this still further. If immigration is reduced to say, 100,000 p.a., this being the very top end of a ‘ten’s of thousands’ definition, this would represent a reduction in population projection by 30% in the plan period. If this future reduction is applied to Stroud, then our projection of the remaining housing requirement for Stroud would drop from 6,713 to 4,669 – a drop of over 2,000 houses. Put another way, a 2,000 drop from SDC’s demonstrably inflated housing figure of 9,500 would give a total housing need of just 7,500 in the plan period.

Government policies (in this case the Immigration Bill) underpin the projections that SDC are using, and must form part of the analysis of housing need to avoid making the wrong assumptions which may have the effect of creating housing distortions. The “recession” argument is driven by a perceived belief in a political imperative to build houses to somehow drive growth in the economy. There is no evidence that shows that an over-supply of housing like this will stimulate the economy. On the contrary historic evidence shows that such bubbles as seen in Spain and Ireland were disastrous for their economies. They built thousands of developments, resulting in the construction of hundreds of thousands of houses based on incorrect population forecasts, aided by reckless banks and greedy developers only to discover that the population projections did not materialise. This has left, in the case of Spain, 500,000 empty new homes and a damaged economy. There is also clear evidence that suggests that increasing housing numbers in SDC above that projected by the ONS will increase out-commuting and create “dormitory communities”. There are no published policies or council decisions that suggests a desire to increase the population beyond that projected by the ONS. The proposed housing number, 9,500, that draws in a population approximately 2,000 above ONS projections is therefore at odds with the Local Authority’s published policies. This also increases out-commuting even further

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Appendix C Housing need – a “Common Sense” approach There are a number of sources that can be used to assess housing need. No single projection method is guaranteed to be correct, and there is no “magic formula” that we can apply to “get it right”. DSS considers five potential projections in it’s publication:- “Stroud Local Plan – DSS Consultation response – Oct 2013::

2008-based ONS & DCLG Projections

2011-based Interim ONS &DCLG projections

Employment Growth Model (with tests)

An “affordability” Model

An Average Household Size Model.

Here we will summarise the “pro” and “con” arguments attached with each projection, with suggestions on how any “con’s” may be be corrected. 2008-based Housing projection model:-

Pro:-

It projects for the whole of the plan period

It has a clear and continuous evidence base (as opposed to 2011 interim) Con:-

It has not been re-based since the 2001 census. It is one census out-of-date.

It makes extensive use of the LFS data – Which has proved to be flawed and inaccurate at district level because of the low sample size (DSS evidence base page 5, section 3.1 graph).

It makes assumptions on household formation (average household size) that do not match the facts that are now available (published actuals).

It is no longer available on DCLG website – it is now obsolete.

In our July 2012 submission to SDC (Stroud Housing Evidence Base – July 2012 (updated with 2011 census data), DSS shows how the 2008-based projection is flawed, how the census Average Household Size data and the SDC Single Occupancy data contradicts the Average Household Size projections presented by the DCLG. This report also shows that once this error was corrected, the 2008-based projections would reduce by between 3,000 and 3,500 houses in the original 2006-2026 timespan. Additionally, the recommendation is made to adopt the 2010 population projections, which were, at that time, newly released. These confirmed the AHS advanced previously by DSS and the census, and indeed those confirmed by Keith Woodhead in his supplementary note. This factually based, and fully referenced report makes it plainly clear that the 2008-based projections are flawed, and should not be used “raw”.

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2011-based interim projections:- Pro:-

It is currently the most recent projection at subnational level.

It has been partially rebased by the 2011 Census. Con:-

Is not recommended for use beyond 2021 by the ONS (The ONS recommend 2010-based data for long term planning.)

Being ‘interim’, it does not have a pure evidence base – much of the household formation and fertility rate data comes from the 2008-based projections.

It makes assumptions on household formation (Average Household Size) that do not match the facts found in reality (the census) (since they are 2008-based) – and some of this fertility data is very different to that found in reality.

In addition to the above known flaws with the 2011-interim projections, SDC’s consultant has chosen to arbitrarily extend these projections beyond the maximum timespan without any declared justification. Any projection beyond 2021 can be considered “unsound” as it is beyond the projected timespan and against the advice of the ONS. 2010-based interim projections:-

Pro:-

It is the most recent projection at subnational level.

The 2012-based population projections for the UK have been published in November 2013. These make a good clear reference to the similarities between the 2010-based projections and the 2012-based projections.

The two projections are similar although the 2012 projections confirm a slight slowing of the 2010 population growth forecast.

Table 1 shows the similarity between the 2010 and 2012 based projections, and how wayward the 20-11 based projection is.

Table 2 shows us the 2010-based household projection, using the 2011-interim projection based AHS.

Con:-

It will shortly be updated by the 2012 sub-national population release in April/May/June

Employment Growth Model. The SDC plan presents an overly complex, poorly explained and un-scrutinised model based on Employment growth, but has (among other flaws listed above) not factored in the changing retirement age. The calculation firstly assumes a retirement age of 65, but fails to declare why it has chosen this (there is no current default retirement age – so the calculation should actually calculate this, rather than assume it). If we assume that for the sake of argument, the state pension age has been used, then the calculation fails to take into account the fact that there is going to be a change to the state pension age, up to 67 for both men and women by 2028 If we broadly assume that the retirement age is currently 65 and is changing to 67, then this alone would, using the calculation in the KW report, result in a reduction in housing demand of 997 houses from the 9,500 houses proposed. (This 997 drop was identified by updating the “working population” number in Keith Woodhead’s calculation to reflect the change in the retirement age during the plan period, from 65 to 67)

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An “Affordability model” approach. In earlier submissions, the SDC consultant proposed a Jobs-per-household approach to calculating housing need. This straightforwardly argues that you need to have a job in order to have a house, so by calculating a Jobs per household ratio, this can project forward a housing need based on jobs growth. This method would project a housing growth provided no changes were made to the proportion of out-commuting. This resulted in a suggested housing need of 6,729 houses – yet oddly does not merit any mention in the consultant’s latest submission. It is worth noting that his strategy appears not to have been followed because it did not support the terms of reference under which he was instructed. Year-on-year growth charting housing delivery rates. In the DSS Consultation response(ref xvi) Page 9, table2, we can see the actual housing delivery rate, from the 2011-based interim projection. The suggested housing growth rate of 406 houses per year (resulting in 9,500 houses in the plan period) is greater than the average house building rate in Stroud (330 houses per annum, from 2001 to 2011). Moreover, the “pre-recession” average is lower, at 312 houses from 2001 to 2007). The proposed build rate of 406 houses per annum represents a greater average growth rate than has ever been achieved. The suggested build rates of 490 houses per annum (by Barton Willmore) are nearly one and a half times more than the achieved average, have only once been achieved in the last 13 years, is not based on any NPPF-compliant evidence base, and would represent an additional requirement of 2,880 houses above the average delivered housing rate. It would require the inward migration of an additional 6,300 persons into the Stroud district, an increase that is not supported by any SDC published, or consulted, policy. A sound extension of the established average build rate from 2001 to 2011 (of 330 houses per annum) results in a total forward housing requirement of 8,380 houses in the 2006-2031 planning timeframe. This would represent a clear and sound indicator of the sustainable delivery rate of housing in Stroud District.

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Appendix D

Mr Daniel James richard.pidgemore@yahoo.co.uk

4 February 2014

Our Ref: TO 200999

Our Ref: Dear Mr James

LSE Responder Hub Customer Service Improvement Directorate 6th

Floor Lunar House 40 Wellesley Road Croydon CR9 2BY

Tel +44 (0) 0870 606 7766 Web www.ukba.homeoffice.gov.uk

Thank you for your email correspondence of 7 January to the Immigration Minister, about immigration. Your correspondence has been passed to me to reply.

With regards to populations levels, United Nations projections suggest world population will increase from 6.9 billion now to 9.2 billion by 2050. By 2030 population increase will mean global demand for food and energy will rise by 50% and for water by up to 30%. Poor infrastructure and unemployment, combined with population and resource pressures will increase risks of instability and conflict. Established strong pull factors including established immigrant communities and the UK being perceived as a stable and tolerant country offering economic opportunity supported by welfare provision, will continue to make the UK an attractive destination.

The Government is taking a range of measures, including the cap on non-European Union (EU) migration, aiming to reduce net migration. Net migration is down by nearly a third since its peak in 2010. Government reforms are working and are building an immigration system that works in the national interest. Immigration routes have been tightened where abuse was rife. Immigration from outside the EU is now at its lowest level for fourteen years. At the same time, there has been an increase in the number of sponsored student visa applications for our world-class universities, and an increase in the number of visas issued to skilled workers.

In the five years to December 2008, more than 90 percent of the increase in employment was accounted for by foreign nationals. Since the second quarter of 2010, more than three quarters of the rise in employment is accounted for by UK nationals. This shows that the immigration policy benefits UK nationals first while still attracting skilled migrants needed by British business.

UK Visas and Immigration is an operational command of the Home Office

The Government is committed to bringing net migration down from the hundreds of thousands to the tens of thousands. The Government is working to protect public services and ensure the welfare system is not open to abuse. The Immigration Bill, which is currently before Parliament, will make it easier to remove people who have no right to be in the UK.

The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

Local planning authorities have responsibility for creating Green Belts and then protecting them from inappropriate development such as significant new housing. Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. When considering any planning application, local planning authorities should ensure that substantial weight is given to any potential harm to the Green Belt.

It is only right that Government asks local authorities to plan to meet the full need of their communities for housing. However, it is up to local authorities working with communities to decide how best to provide housing for their needs, and to work together across housing market areas under the duty to cooperate where appropriate. Local authorities and their communities are best placed to decide which land is most suitable for development. They may chose to re-develop in existing urban areas through conversions and redevelopment of brownfield land, through sustainable extensions to settlements, or even through new sustainable towns or villages. These options must have regard to the policies of the Framework, such as the protections for Green Belt and other countryside policies.

Further information on housing can be found on the DCLG’s website at: www.communities.gov.uk.

19

Further impacts of a growing population will be felt in the provision of healthcare Demand for health care continues to rise, including as a consequence of the growing and ageing population. While the Government has committed to increasing health spending in real terms in each year of the Parliament, in order for the NHS to continue to meet rising demand, while also improving the quality of care and outcomes for patients, it will need to deliver efficiency improvements of up to £20bn by 2014/15.

Further information on healthcare provision can be found on the Department of Health’s website at: www.dh.gov.uk.

With regards to the food supply of the UK, this is another valid area of concern and the Government recognises the coming decades will present the farming sector with growing economic, environmental and social challenges and that, in order to help feed 9 billion people worldwide by 2050, the Government will need to increase food production sustainably through improving productivity and competitiveness in the UK, EU and beyond. This Government is taking action to meet its objectives of supporting British farming, encouraging sustainable food production, and helping to enhance the competitiveness and resilience of the whole food chain with the aim of ensuring a secure, environmentally sustainable and healthy supply of food with improved standards of animal welfare.

In 2011 the Government’s Chief Scientific Advisor Sir John Beddington produced a Foresight report on the Future of Food and Farming: challenges and choices for global sustainability. The Foresight report examines population growth and climate change along with other pressures on the food system. The report challenges governments worldwide to take action. The Department for Environment, Food and Rural Affairs (Defra) and the Department for International Development (DfID) have both committed to act on the report and have signed up to a Foresight action plan.

Defra’s Foresight Action Plan and the Foresight Report can be accessed on the Department for Business, Innovation and Skills website at: www.bis.gov.uk/foresight/our-work/projects/published-projects/global-food-and-farming- futures/reports-and-publications.

Food security cannot however be delivered by focusing on self-sufficiency. International trade has an important role in providing food security. We are a trading nation in a global market and the Government is seeking to support industry in accessing and maximising opportunities within export markets. One of the ways the Government can support industry efforts is through the provision of the scientific evidence necessary to underpin the sustainable choices that our food and farming industries need to make for the future. To that aim, the Government is investing up to £90 million over 5 years for technological research and development, in areas such as crop productivity, sustainable livestock production, waste reduction and management, and greenhouse gas reduction.

However we need to make sure that producing food to meet our growing demand now does not undermine our ability to feed ourselves in the future. This means we need to carefully manage the natural environment and ecosystems that provide the inputs our farmers need and continue to reduce energy use in UK production. It is important to improve the condition of the natural environment so that future generations can enjoy the UK’s rich geology, landscapes and biodiversity.

The Government has placed the need for growth and productivity in the agri-food sector at the heart of Defra’s business plan. This sits alongside the strong environmental commitments we have made in the Natural Environment White Paper and elsewhere. The Green Food Project is a joint initiative between Government, the Food and Farming industry, environmental and consumer organisations. It is looking at the challenge of how we can increase food production in England, whilst simultaneously enhancing the environment, and how we might reconcile any tensions that this challenge raises.

The Government does not at present consider there to be a need for measures to control population growth beyond those needed to control net migration, nor for population targets or specific new Committees to address population growth issues. The Government will continue to monitor the longer term risks arising from global population growth, changes in the distribution of wealth and the potential for climate change to increase the number of countries experiencing political and/ or economic instability, which provide a long term context for emigration to the UK to increase.

Further information on immigration can be found on our website at: www.ukba.homeoffice.gov.uk/.

Yours sincerely

Sharif Assan LSE Responder Hub

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Appendix E The following is a peer review of this work by: Mr. Ian Bickerton C.Eng., B.Sc. (Hon). MIET. Mathematical and Quantum Statistician of The Diamond Nanoparticle Energy Converter Project, Bristol University. In the DSS response there is much discussion and detailed evidence on population projections and household formation rates to be used in attaining an objective assessment of housing targets for Stroud District Council. It's generally accepted that the true expertise for this area lies with the statisticians at the ONS Population Projection Unit headed up by Suzanne Dunsmith and the DCLG Household Modelling Group responsible for the England Model directed by Bob Garland, this work is both independent and peer reviewed. Both teams have worked extremely hard to update the England Modelling in-line with the 2011 census and to provide reliable projections to inform councils with local plan preparation. The ONS have been consistent in their advice to use the longer term population projections for planning periods beyond 2021 and have placed warning on the use of the 2011 interim population projections as stated correctly by the DSS in this response. To summarise the ONS position on population projections: The ONS do not support the use of the Interim 2011-based Sub National Population Projections for any purpose beyond 2021. The ONS acknowledge that the Interim 2011 based Projections contain known flaws which by implication would overstate housing forecasts. The ONS strongly recommend using long term statistics for long term purposes and suggest that the 2012 Based Sub national Population Projections, due in May/June, will be appropriate for a 2011-2031 strategic housing plan. Finally, the ONS refer to DCLG Household Projections as a key input to the Local Authority Planning, these will also be updated to the 2012 based Sub-National Population Projections. On employment and job creation, the DSS analysis is in agreement with the Economy Module of the SW Observatory, Prospects for Private Sector Jobs Growth in SW England, October 2011, the longer term job prospects are moderate for Gloucestershire, reference Table 2 SW Sub-Region Employment Projections (FTE's) for Gloucestershire, in the period 1995-2005 1.1% average change (benchmark period), 2011-2016 1.8% and 2016-2030 0.8% - Source: SW Economic Projections for SWRDA, autumn 2011 - 'this performance framework is revealed by the long and deep understanding, gained over many years of our analysis, of the historical trends and structures in the different parts of the SW economy'. Section entitled 'Avoiding the Myth', it is correct that the ONS have reported a flat-lining of household size in England and Wales from 1991 to 2011 in their Statistical Bulletin 2011 Census - Population and Household Estimates for England and Wales, March 2011, dated 16 July 2012, reference figure 10 showing an average household size of 2.4 in 1991, 2001 and 2011, correctly stated as three census points, a period of 20 years not 30 years as described. The overall response from the DSS is well researched, referenced and objective.

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APPENDIX F – ONS Population Projection Unit Correspondence From: Projections@ons.gsi.gov.uk Date: 21 February 2014 11:57:31 GMT To: cllrmikeevans@icloud.com Subject: Re: Questions about the 2011 Interim Population projections - 0661

Cllr Mike Evans You are right I did meant 2031. In the absence of any further information the assumptions you are making are reasonable. However, please note that although the total population projected for England are similar the assumptions made are different. So the patterns may not necessarily be the same for the local projections. See http://www.ons.gov.uk/ons/rel/npp/national-population-projections/2012-based-projections/stb-2012-based-npp-principal-and-key-variants.html#tab-Comparison-with-Previous-Projections

Regards

Denise Williams

___________________________________________________________________________________________________________________________________ Population Projections Unit | Office for National Statistics | Titchfield | PO15 5RR | Phone +44 (0)1329 444652 | email: projections@ons.gov.uk | www.ons.gov.uk National Population Projections web page: www.ons.gov.uk/ons/taxonomy/index.html?nscl=National+Population+Projections Interactive population pyramids: www.ons.gov.uk/ons/guide-method/understanding-ons-statistics/interactive-content/dvc3-twin-national-projections-pyramid-link.html Subnational Population Projections web page:

www.ons.gov.uk/ons/taxonomy/index.html?nscl=Sub-national+Population+Projections Interactive population pyramids: www.ons.gov.uk/ons/guide-method/understanding-ons-statistics/interactive-content/dvc4-twin-subnational-pyramid-link.html

From: cllrmikeevans@icloud.com To: Projections@ONS Date: 21/02/2014 08:46 Subject: Re: Questions about the 2011 Interim Population projections -

0661

Hello Denise, Many thanks for that information. I take it you meant to say that you would not recommend extending the interim 2011 sub national population projections to 2031 ( not 2021 as in your response)? As you have advised, we have compared the 2008 and 2010 based subnational projections agains the 2011 census data. This comparison would seem to suggest that the 2010-based data is the closest to the actual data measured in the 2011 census. Do you think this would be a sound assumption to make? Also, we note that, at a national level, the recently published 2012 population projections are closer to the 2010 projections than the 2008 projections. Is it therefore a sound assumption that this would be the case for the sub national population projections too? ( and thus suggesting that the 2010 population projections are the most sound ones to use) Kind regards, Cllr Mike Evans On 20 Feb 2014, at 15:32, Projections@ons.gsi.gov.uk wrote: Cllr Michael Evans We would not recommend extending the Interim 2011 subnational population projections to 2021 these were produced for a shorter time span. The Interim household projections published by DCLG only extend to 2021. We are not in a position to say which of either the 2010-based or 2008-based sets of projections best suits your current requirements. The population projections are an indication of what the population may be if recent trends continue. Obviously these change between sets of projections. Also you may wish to be informed by 2011 Census data which will give you an indication of differences between the projections and these data in 2011. Regards Denise Williams 01329 444872 ___________________________________________________________________________________________________________________________________ Population Projections Unit | Office for National Statistics | Titchfield | PO15 5RR | Phone +44 (0)1329 444652 | email: projections@ons.gov.uk | www.ons.gov.uk National Population Projections web page: www.ons.gov.uk/ons/taxonomy/index.html?nscl=National+Population+Projections Interactive population pyramids: www.ons.gov.uk/ons/guide-method/understanding-ons-statistics/interactive-content/dvc3-twin-national-projections-pyramid-link.html Subnational Population Projections web page:

www.ons.gov.uk/ons/taxonomy/index.html?nscl=Sub-national+Population+Projections Interactive population pyramids: www.ons.gov.uk/ons/guide-method/understanding-ons-statistics/interactive-content/dvc4-twin-subnational-pyramid-link.html

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From: cllrmikeevans@icloud.com To: Projections@ONS Date: 18/02/2014 21:10 Subject: Questions about the 2011 Interim Population projections - 0661

Dear Population Projections Unit, Further to a telephone conversation between yourselves and a colleague, Cllr Ian Bickerton, I was advised by Ian that you might be able to help on the following. I am an elected Councillor shortly to attend an Examination in Public with an inspector, and I have been working with the Stroud District population projections. I wonder if you could point me in the right direction, and confirm my understanding. Having read the Statistical Bulletin from the 2011-based interim Population projections, I noted the following passage:- "These 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 are only required to 2021. " With this in mind, would it be safe to manually extend the 2011-based Interim Population projection for our District beyond the 2021 timeframe to our 2031 horizon? If you think that this is inappropriate, would the 2010-based Population projection or the 2008-based population projection be most appropriate for our 2031 timeframe? With such limited timescales, I wonder if you could respond at your earliest opportunity, it would be very much appreciated. Kind Regards, Cllr Michael Evans. This email was received from the INTERNET and scanned by the Government Secure Intranet anti-virus service supplied by Vodafone in partnership with Symantec. (CCTM Certificate Number 2009/09/0052.) In case of problems, please call your organisation's IT Helpdesk. Communications via the GSi may be automatically logged, monitored and/or recorded for legal purposes. For the latest data on the economy and society consult National Statistics at http://www.ons.gov.uk

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The original of this email was scanned for viruses by the Government Secure Intranet virus scanning service supplied by Vodafone in partnership with Symantec. (CCTM Certificate Number 2009/09/0052.) On leaving the GSi this email was certified virus free. Communications via the GSi may be automatically logged, monitored and/or recorded for legal purposes. This email was received from the INTERNET and scanned by the Government Secure Intranet anti-virus service supplied by Vodafone in partnership with Symantec. (CCTM Certificate Number 2009/09/0052.) In case of problems, please call your organisation's IT Helpdesk. Communications via the GSi may be automatically logged, monitored and/or recorded for legal purposes. The original of this email was scanned for viruses by the Government Secure Intranet virus scanning service supplied by Vodafone in partnership with Symantec. (CCTM Certificate Number 2009/09/0052.) On leaving the GSi this email was certified virus free. Communications via the GSi may be automatically logged, monitored and/or recorded for legal purposes.

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DATA SOURCE DECLARATIONS

i The National Planning Policy Framework requires soundness in para 182, Objectivity - Para 14 Bulletpoint 2 and “up-to-date”- Para 158 ii Barton Willmore submission para 2.25 quotes from: ‘Housing the next generation’ Nick Bowles MP 10 Jan 2013

iii 2006-based subnational population projections by sex and quinary age, 23 Oct, 2007.

http://www.ons.gov.uk/ons/rel/snpp/sub-national-population-projections/2006-based-projections/table-4--las-and-counties-in-se--sw-and-london-gors--2006-2031-population-projections-by-sex-and-quinary-age.xls iv 2008-based Subnational Population Projections for England, 27 May 2010.

http://www.ons.gov.uk/ons/rel/snpp/sub-national-population-projections/2008--based-projections/2c--all-las-and-higher-administrative-areas-within-se--sw-and-london-gors--2008-2033-population-projections-by-sex-and-quinary-age.zip v 2010-based subnational population projections for England, 21 March, 2012.

http://www.ons.gov.uk/ons/rel/snpp/sub-national-population-projections/2010-based-projections/rft-table-2c-la-in-regions-quinary.xls vi 2012-based National Population Projections, 6

th Nov 2013.

http://www.ons.gov.uk/ons/rel/npp/national-population-projections/2012-based-projections/stb-2012-based-npp-principal-and-key-variants.html vii

DSS, Stroud Housing Evidence base, July 2013 (updated 2011 census). Section 2, Page 4 Table and Chart. viii

All ONS and DCLG projections have the following statement included:- “The projections do not take into account any policy changes that have not yet occurred, nor those that have not yet had an impact on observed trends.” Example: http://www.ons.gov.uk/ons/rel/snpp/sub-national-population-projections/2010-based-projections/rft-table-2c-la-in-regions-quinary.xls

ix in the 2012- based National Population projections,The ONS state that: “The UK population is projected to increase by

9.6 million over the next 25 years from an estimated 63.7 million in mid-2012 to 73.3 million in mid-2037.” And go on to state that: “.. about 60 per cent of the projected increase in the population over the period mid-2012 to mid-2037 is either directly attributable to future migration (43 per cent), or indirectly attributable to the effect of fertility and mortality on these future migrants (17 per cent). “

x The UK Visas and Immigration Office confirms “Net migration is down by nearly a third since its peak in 2010” and “The

Government is committed to bringing net migration down from the hundreds of thousands to the tens of thousands “see attached letter in Appendix D. xi 2011 Census.

http://www.ons.gov.uk/ons/guide-method/census/2011/the-2011-census/index.html xii

2001 Census. Spreadsheet. http://www.ons.gov.uk/ons/rel/census/census-2001-first-results-on-population-in-england-and-wales/first-results-on-population-in-england-and-wales/dataset-1---census-2001-first-results-on-population-in-england-and-wales.xls xiii

Stroud District Local Plan Pre-submission draft, September 2013 uses the http://consultation.stroud.gov.uk/planning-strategy/stroud-district-local-plan-pre-submission-consulta/supporting_documents/PreSubmission%20Draft%20Plan.pdf xv

DSS publication:- Stroud Local Plan – DSS Consultation response, Oct 2013.