Comment ID 2334
Document Section Proposed Submission Local Plan 2006-2028 Settlement Strategy Scale of Growth for the District and the Main Settlements Housing Housing Paras 4.70-4.77 Tables 2a and 2b [View all comments on this section]
Respondent Cllr M Fysh [View all comments by this respondent]
Response Date 10 Aug 2012
Do you consider the DPD is Legally Compliant? No
Do you consider the DPD is Sound? No
If you have responded that the DPD is unsound, Do you consider the DPD is unsound because it is:
  • Not Consistent with national policy

1.       Alternative 1: substitute 15,950 with 14,000, being the optimistic latest forecast by Baker Associates which is in the evidence base and sufficiently close to the 13,600 home figure which has been consulted and appraised. It is therefore positive and evidence based (although in my view even 14,000 is likely to be a wild overestimate of what is necessary to accommodate business and job growth in South Somerset over the Plan period). This approach is superior to the methodology used by SSDC, as evidenced at paragraph 4.72 of the Plan and elsewhere, which is deeply unsound. There is in fact no required additional provision for affluent older people such as contended in the SHMA, or in any work or evidence that is before us, that provides any justification for a higher number. In fact, extra in-migration on top of what is in the latest ONS mid year 2010 population projection is completely unsubstantiated. I challenge the use of outdated SHMA data and draw attention to the health warnings on housing need that are given in the SHMA, eg paragraph 31.1 “One of the central features of the Guidance is that SHMAs are collaborative and continuing processes, not just the production of a report. This requirement is implied by the Local Development Framework approach and the strong emphasis on flexibility in the response to changing housing market demands (‘Explain how the assessment findings have been monitored and updated since it was originally undertaken’ -SHMA Practice Guidance). There is also no clear or convincing justification for including extra provision for homes at Yeovilton, given that many more jobs have been lost over the past few years at Westland, BAE and elsewhere.

Alternative 2:  (and I would argue this is the most robust in the circumstances), use the most recent population growth projection figures from ONS, confirmed as the most robust available by proximity of 2011 forecast to that seen for 2011 in the Census, and divide the 2028 forecast figure, adjusted for private households, by 2.19 people per household in 2028, for a figure of 10,900 derived as a strategic housing requirement for 2028. NB 2.19 is more realistic and up to date and robust than the out of date and not sufficiently substantiated 2.1 people per household figure used by the Council. Previous Population growth figures and household projections have been discredited by recent ONS bulletins. This is especially so given the Census 2011 showed that persons per household has NOT been falling as previously expected, so 10,900 is by far the most robust figure that we can possibly get to now.

Alternative 3: use 13,600 as the requirement (being some way between 10,900 and the top end economic-led figure of 14,000 and therefore positively prepared, and having been consulted upon).

NB that actual measured net in-migration has dropped very substantially and is showing no sign of reviving. The factors such as available debt, easy second home finance and perception of its requirement, plentiful work, economic optimism and buoyant house prices are no longer there for the time being, which according to the bank of England will probably stay with us until 2020 and beyond.

What changes do you suggest to make the DPD legally compliant or sound? This submission Local Plan has at least in part been worked up to a pre-conceived idea without serious or proper consideration given to alternatives. Evidence adduced to support the Plan has at times been contrived and manipulated, and consultation and approval processes manipulated to suit the pre-conceived idea. I understand the areas of these matters in detail, and have witnessed many of the processes first hand. I am an elected Member for the ward of Yeovil South, and South Somerset, which will be much affected by the current proposals. I am an English Heritage “Heritage Champion” on South Somerset District Council, and have detailed knowledge of heritage assets in the area. My professional background and experience is economic analysis, investment and real estate development, so I am well qualified to comment on all aspects of the Plan.

I would be pleased to evidence any part of my statement further with written and or oral evidence, and would welcome the opportunity for an oral hearing to explain all points more fully and to answer questions as necessary.
If your representation is seeking a change, do you consider it necessary to participate at the oral part of the examination? Yes
If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: I would therefore respectfully submit that I should be entitled to an oral hearing on these matters, and say that I have substantial further written evidence that I can adduce in support of the points in this statement.