In the past week all councils within the Joint Core Strategy area, Gloucester, Cheltenham and Tewkesbury have met to decide the required housing need for the area. Out of 739 responses to the JCS questionnaire 78% of the public voted for option A for 16,200 homes and that brownfield is developed before greenfield and that urban regeneration comes first. We expected the councils preference to be for option B to build 33,200 homes despite the lack of public support.

There was a very length debate at Cheltenham council, where Save The Countryside campaigners were out in force with strong evidence to back up their arguments. The population within the JCS area is estimated to rise by 44,700 over the next 20 years, it actually likely to be lower since this ignores the fact that we are seeing much less economic growth due to the recessions (less job migration). The projection of 33,200 assumes a low occupancy rate of 1.2, whereas the “2011 census” and “Local Tax and Labour Force Survey” both give household occupancy of 2.4! Naturally this more realistic occupancy requires far fewer homes to be built given the population increase. STC and Leglag are stunned that this ridiculously low occupancy rate can be counted as an evidence when there is absolutely no evidence for it!

During the debate it became increasingly clear to STC campaigners how shaky the evidence was for the housing estimates. The JCS team seem to believe you can invent some assumptions, pass them through a faulty mathematical and claim to have conjured up some solid evidence. We expect better from our representatives. Importantly the Cheltenham councillors are sympathetic to our arguments but face strong resistance from the officers. At the end of the day councillors voted for a housing figure of 28,500 homes but due to strong arguments from STC and Leglag they add an option to further investigate evidence for the 16,200 figure. There is hope that they will be convinced by the solid evidence for this lower figure.

While this appears to be a small chink in the armour of Cheltenham Borough Council even this slight ‘weakness’ has been pounced upon by Gloucester and Tewkesbury council and have suggested that unless CBC goes with the higher housing figures the whole JCS might collapse. This is very unfortunate and more pressure needs to be put on these other councils. Tewkesbury members even said the figure might need to be as high as 43,220! , however there are different voices and some councillors at Tewkesbury said that more work need to be done before housing need for the three councils could be established and that that work needs to be substantial.

Several people have mentioned how the fiasco is the awarding of the West Coast mainline contract has echo with the JCS process. In both cases, flawed statistics are put up to support the wrong outcome and costs in the long term of getting this decision wrong and likely to be very high.

Margaret White (Leglag)  discovered these figures, showing generally that councils have in the region  have all adopted far lower housing requirements than those given in the now scrapped Regional Spatial Strategies (RSSs). Not so in Cheltenham yet.

Bristol adopted – housing numbers 32,800 (RSS 36,500)
North Somerset adopted – housing numbers 14,000 (RSS 26,750)
South Gloucestershire – housing numbers 26,400 (RSS 32,800) –Hearings happening currently.
Bath & North East Somerset – housing numbers 11,000 (RSS figure 21,300 waiting to hear further from the Inspector.

Heres is letter sent to Councillors before the meeting from STCs chair, Helen Wells giving some more background information and evidence.
Dear Councillors,

We feel the need to highlight the issues with the JCS resolution ahead of Monday’s Council:

  • Population projections from the Office of National Statistics (ONS) have now been accepted by JCS Officers & Consultants
  • Average Household Size (AHS) projected to 2031 remains a sticking point, NLP have failed to make the case for a significant reduction in household size in the JCS area. Use of 2011 Census District Tables (see figure 2 of the attached brief), local tax data & Labour Force Survey information all show the district AHS is in line with the national/european household occupancy of 2.4 with a LEVEL trend

NLP are making a case for building more houses to accommodate the existing population needing more space, more people living alone etc. This assessed housing need is over and above the housing required for the 44,000 population growth to 2031, this also assumes a return to pre 2008 district economic growth. We do accept that the economy will return to ‘normal’ levels of growth in the mid-term, however there is no objective evidence for the reduction in average household size.

We ask Tewkesbury Council to consider JCS housing numbers based on actual and objective district AHS which is now following a level trend, it is no surprise that the large JCS area is close to the national average. There was cross party support at Cheltenham Council for officers to look at household size in the resolution, this is entirely consistant with NLP’s recommendation [Ref. 2]. Council Tax reforms set out in the Comprehensive Spending Review whereby councils will be able to set their own criteria will likely target empty and second homes. In the JCS Public Consultation, analysis shows 8/10 residents are in favour of the reduced number of houses, brownfield before greenfield and supporting the continued urban regeneration.  

Best Regards 
Helen Wells, Chair, Save The Countryside
Margaret White, Secretary of LEGLAG

REFERENCES1. Information on Household Size, other SW councils are signing upto the use of ONS data to assess the housing need, Stroud District Council are in a similar situation and looking at the DSS evidence

2  NLP Report, para 3.9 – ‘In summary,  … there were no serious flaws in the approach.However, the consultants advise that certain elements of the information used to inform the work in 2011 are in need of revision because more up to date and reliable sources of data to are now available‘.


3. Richard Fordham, provides our consultant’s view of the NLP Report, Richard has been closely involved with assessment of the housing need for Gloucestershire since the early 80’s

For Councillors consideration, I would offer the following points:
1. This study makes no reference to the Strategic Housing Market Assessment (SHMA) and Housing Needs studies done for the same area, as part of Gloucestershire in 2008 and 2010. This is presumably because these much better sourced studies produced much lower estimated requirements. The 2010 projections used by Litchfield are not much bigger than the 2006 ones we used, and so the result is due to poor analysis. Litchfield’s history is in acting for developers at the former Regional Spatial Strategy hearings, to argue for higher targets on behalf of developer clients. They have only turned to local authorities as a result of the ending of the RSS.
2. The document refers to ‘Housing Needs’ without showing any understanding of what Government Guidance (the latest being the 2007 Practice Guidance from CLG – defines as housing need. Housing need refers to those unable to afford market housing who are in unsuitable housing. There is no reference to the Government guidance in the Litchfield report, presumably because their approach does not conform to the official one. The NPPF supports the use of the Practice Guidance but Litchfield ignores it. They use ‘housing need’ to mean ‘housing demand’. There is actually no analysis of housing need in their report.
3. In paras 4.6-4.7 Litchfield refer to the ‘adverse social impacts’ of producing 1,900 new dwellings pa across the JCS area, which coincides with worsening affordability. It suggests that their proposed target will stabilise prices. This remark reflects remarkable ignorance of the operations of the housing market. Most (80-90%) of housing transactions in an area are second hand, not newbuild. Newbuild is not a separate product, but just represents additional housing. House price change is driven by the relative attractiveness of the overall housing stock, in response to the ability of purchasers to afford it. The long term rise in house prices in the south of England has been driven by increasing real income. That rise has largely stopped, even in the good parts of the south and there is no prospect of a big increase any time soon. The idea that increasing the minority element of housing that is newbuild in the JCS area would affect overall house prices is absurd. The well respected Barker review of 2004 estimated that it would be necessary to double new housebuilding to have even a small effect on house prices (at the national level). At the subregional level, like the JCS, the level of new housebuilding is likely to have no effect whatever on local prices. Most house sales are secondhand. If there were a genuine shortage in the JCS area, purchasers would simply go next door (north south east or west) to find ample supplies without bidding up prices in the JCS area. There are plenty of other dormitory areas for Bristol and Cardiff. The Litchfield argument reflects a pitiful lack of market awareness and is completely misguided.
4. The general thrust of the Lichfield report is that the NPPF demands more housing and here’s how to provide it. The NPPF does not demand more housing. It pays due respect to Localism, which I would have thought is the best argument to present to councillors. The JCS has a bureaucratic necessity to bid up local housebuilding: that is it’s purpose. It should not be allowed to use dubious research to justify its aims.