Conclusions, Recommendations, and some responses

A living, informal document. Please use, abuse and modify to your heart’s content.

The below is taken from the briefing Summary, with some additions in red.

Stuart’s headlines can be cross –reference as follows

  1. Basildon have inflated the required housing growth by using an average of 2 projections, rather than relying on the most up to date projection. Overall growth has slowed and will continue to do so in future. (Conc 4 – Rec 2)
  2. 44% of the new Houses Basildon want to build will go to incoming migrants from outside the Borough. Basildon are building more homes than we need in order to attract migrants into the Borough. (Conc 6)
  3. Basildon justify the inflated OAN by claiming they will create 8,600 jobs and yet they expect the unemployment rate in the Borough to remain at around 7.9%. Who benefits? (Conc 8b)
  4. Basildon tell us they need more houses to support all the new jobs being created, then tell us that they need to create 8,600 jobs for the people in the new houses. Which is it? (Conc 8a)
  5. Most of the new Jobs are likely to be low skilled, working in huge warehouses. This is the worst use of economic land, providing the least number of jobs per hectare. Low aspiration, huge waste of valuable land. (The nearest is Rec 1a and 1b. I didn’t feel I had enough understanding of the economic side of things to put such a strong emphasis on this – though it’s a very strong point)

Note:Concs and Recs are ordered in a way that seemed to me a logical flow rather than a prioritisation.

Therefore in conclusion:

  1. The OAN was not imposed on BBC by Central Government or any Government body. It is the responsibility of Local Authorities to develop their own OAN.
  1. The Framework and Guidance governing LA plan-making give Authorities considerable lee-way. There are several legitimate ways to reach an OAN.
  1. An LA can submit an argument for a Housing Target lower than its OAN, citing constraints such as infrastructure and Green Belt.
  1. BBC takes an average from lower, more up to date 2011 census data as well as higher, less robust 2008 data. Giving these datasets equal weight inflates the OAN.

Note: BAG’s research only references the 2011 figures, an approach we share with Brentwood Borough Council whose OAN is based on 2011 figures only.

  1. Basildon’s ‘Natural Growth’ gives rise to a requirement of 8900 new homes.
  1. Comparing this figure to the 16000 minimum shows that 44% of new homes will be provided for new arrivals from neighbouring boroughs, London and beyond.
  1. Under the NPPF, BBC could not submit an OAN based on Natural Growth alone but must take past migration trends into account.

BBC examined a number of Migration-based projections in the 9700-13300 range, mostly at the lower end.

BBC could have selected one of these figures but chose to go further.

  1. The proposed OAN is based on an Economic Scenario. Such scenarios take a broad estimate of how many jobs might be created in the borough over the next 20 years as their foundation.
  2. They deploy a circular argument. In one document BBC argues that they require further new homes to house the outside workers necessary to fill these jobs – while in another document they argue that the large jobs total is only sustainable and necessary as it is assumed a very large number of houses will be built.
  3. In determining the number of new homes required to house the new workers, BBC makes the assumption that there is no slack in the Basildon labour market despite very high levels of unemployment, economic inactivity and other measures. Measures which will remain the same if and when the jobs are delivered.

Additional Notes

Assumption of No Slack is painfully untrue.

We have:

  • 8000 unemployed
  • An additional30000 classed as economically inactive
  • 18000 part-time workers
  • And half the workforce has to commute to jobs outside the borough.
  • A figure of 790 pa appears in graphs and recommendations and it is rounded up to 800pa in the local Plan, that’s 16000 over the Plan period.
  • The assumptions behind the chosen Scenario are provided, but the formulae are not explained and they are only available at a cost of £600.
  1. TGSE (Thames Gateway South Essex) Partnership, of which BBC is a member, explicitly criticise the type of approach taken by BBC and make a non-binding recommendation of 11900, though there are good reasons for lowering this figure.
  1. There is no evidence that BBC considered a Windfall Allowance which would alleviate pressure to designate countryside sites.

We recommend that the HGTP is revised and a new OAN proposed for the Local Plan. This should specifically focus on Natural Growth and Migration, not on Economic scenarios. We believe the terms of reference should be revised to request that:

  1. Only Migration based Scenarios should be considered as these have been shown to provide sufficient labour to sustain economic growth and are in line with the NPPF.

Note: A lower OAN and\or Housing Total would mean that a lower and more achievable jobs target could be set. This would allow BBC to:

  1. Spare Green Belt land round Basildon from industrial development
  2. Deliver a far better workers\job ratio than the current Plan.
  3. Spare some or all of the Green Belt and other open land, around all three towns, from residential development.
  1. BBC should only use the most up to date datasets in their projections as Brentwood has done. The ONS will produce more up to date figures in November 2014.
  1. Consideration should be given to the non-binding recommendation produced by TGSE. Castle Point adopted the recommendation made to them as their OAN.
  1. Consideration be given to the inclusion of an allowance for Windfall Sites in the overall OAN.
  1. In light of infrastructure and Green Belt constraints, that consideration be given to a Housing Target lower than the OAN.

Some Figures

We don’t have a policy, and we may not need one, but IMO we can be safe in the vague aspiration of a ‘Housing Target lower than our OAN’.

Here are some specific figures and some notes on some of the reasons on why we shouldn’t be drawn on a precise Housing Target or OAN.

  • 6000 – UKIPs current position according to comments made on Facebook.

It could be pointed out that this does not meet the borough’s ‘Natural Growth’

  • 6500 – The figure submitted in the previous Plan. No Green belt development but did include the Dry Street shocker.
  • 6900 – The amount of houses the current Plan estimates could be built within the current urban boundary.

Excludes Dry Street but does include further development on Parks and similar in Basildon.

  • 8900 – The Borough’s Natural Growth

Would require some Green Belt development in someone’s back yard

  • OAN – ie must factor in Migration
  • The lowest projection available is 9700.
  • Thames Gateway estimate 11,900 (based on long-term migration trends) but could be lowered to around 10,700, for instance because we believe in incorporates out of date 2008 data – and other reasons.

Some Potential Council Ripostes

  • You’re Nimbies\Only interested in Billericay\Billericay East.

By NIMBY I presume you mean someone who wants development but only if it happens in someone else’s neighbourhood.

Our Actions have shown that we’re taking a borough-wide view, we want land around all three town to be protected and we’ve shown it can be.

  • The Council’s Planning Team have already sent BAG a full answer to the questions they sent us.

We can be nice. Thank them, it was thorough response, but we’re confident those answers don’t challenge the case made in the White Paper.

  • A Housing target Lower than OAN: they may say “we tried that but had to drop it etc”

We can be nice, because they did and it’s a tricky one.

Leaving aside technicalities we can perhaps say that we think that the old Plan was withdrawn rather than rejected and there is a case that with more work and in light of evolving Planning Guidance something like the original Plan may have been passed by the Inspectors.

Perhaps we could add this is only an aspiration not the focus of the Paper – which is the OAN rather than the Housing Target (making the important differentiation between the two)

  • The number may not be imposed but the process was

The process gives considerable lee-way

  • Must meet the full OAN blah-de-blah

We show that the OAN is unnecessarily high and so it should be changed. A further consideration is that the Council can submit a case for a Housing target lower than its OAN.

  • Only the Economic Scenarios were compliant with the NPPF

The NPPF is a Framework and is nowhere near that specific.

Their rationale is probably based on the sections promoting sustainable economic development – a fair point taken far too far.

Several points could be made – Prob best to concentrate on this one…

  • The council hopes to promote economic development and create many new jobs. In doing this they hope to comply with the Economic Clauses. However it does not follow that because these jobs are planned for that we must bring in outside workers. Our figures show there’s more than enough slack in the Labour Market, rather than virtually not as the Council assumes.
  • What do you mean No slack in the labour market?

The Council argues that it is necessary to bring in new workers to fill the jobs they hope to create.

The conclusion that this is necessary is based on the assumption that unemployment and other measures will remain the same. The effect of that assumption is that it means that these people have been discounted when considering who is available to fill these jobs.

A good point to make here is that they have a flawed and over-complicated approach. Thames Gateway made a recommendation of 11,900 (though there are good reasons to lower this) and showed that in that case the increase in the size of the Labour Force was proportionally greater than the growth in jobs.

Under BBCs plan the imbalance will be much worse.

  • Your remarks about unemployment and social implications are wrong\inflammatory etc. We carried out Sensitivity Testing blah-de-blah…

The council’s consultants modelled the impact of a reduction of unemployment on the figures – from 7.9% to 6.6%.

This makes around 1500 more people available for work and so should considerably reduce the perceived need to bring outside workers in.

However the figures quoted by BBC show a reduction of only about 150 homes.

It looks as though something is very wrong with the mathematical formulae they’re using. We’d like to have looked at this but the Council want us to pay £600 to see the data.

  • On an error or perceived error being pointed out:
  • Will make a considered response
  • Will take to our research team
  • Possibly – “These are relatively minor points, the council do not seem to be disputing our overall description\critique of how the numbers were formulated
  • They make arguments that they need to take account of older 2008 figures

No need to get bogged down in technical stuff. It is true that there is a case for considering these older figures but it’s not conclusive, Brentwood don’t.

At the least it is certainly mistaken to give them equal weight.

  • We looked at TGSE’s figure but it is not an OAN

It is a non-binding recommendation and a reasonable candidate OAN (though there are good arguments to lower it). The only good reason it is not an OAN is because it’s BBC’s responsibility to come up with an OAN, not TGSE. Castle Point chose to adopt the recommendation made to them as their OAN.

  • The TGSE figures didn’t address the following considerations – only the Economic scenarios did (Enabling Economic Growth – Meeting Population Pressure – Addressing Affordability Challenges).

The statement that only the economic scenarios meet the first two is based on the flawed assumption that there is no slack in the labour market and so without outside workers these jobs won’t be delivered.

The Population Pressure they refer to is the pressure of the workers coming to fill these new jobs and not a factor when we remember that there’s enormous slack in the Labour Market.

The issue of Affordability Challenges is addressed next…

  • Your White paper takes no account of Affordability\Historic under-provision (aka backlog)

We judged that BBC considered these secondary arguments and so we didn’t include them in our White Paper as it was already long enough. However we have researched them and will publish soon

(We can do this as soon as there is interest or before –it’s damning stuff)