Inspector raises concerns about Essex council's housing need evaluation

The Council submitted the plan to the secretary of state for communities and local government for examination in April. The housing need assessment of 294 dwellings per annum given in the document was based on 2010 figures from the Office of National Statistics.

The appointed Planning Inspector, David Vickery, wrote to the Council in June raising his concerns regarding the potential soundness of the document ahead of an exploratory meeting on 3 July.

In his letter (8-page / 505 KB PDF), the inspector questioned the Council's use of the 2010 figures, given that it also had two strategic housing market assessments (SHMAs), from 2012 and 2014 respectively, in its evidence base. The 2012 assessment gave a figure of 825 units per annum, which the Council had argued overestimated the housing need, having been based statistics from 2008 during a housing boom. The 2014 assessment indicated a need for 381 homes per annum.

"Even if I accept the Council's premise that the 2012 SHMA overestimates housing need and should not be used, I do not understand why the Council has chosen to disregard its more up-to-date 2014 SHMA in favour of the older and cruder 2010 sub national population projections," said the inspector.

"Thus, my initial view is that the full objective housing need assessment figure is more likely to be that in the 2014 SHMA. Moreover, it may be higher if further work is needed on the 2014 SHMA to take account of possible recessionary underestimation," said the inspector.

"This means that the plan's housing policies may be fundamentally flawed either because they do not allocate sufficient housing land or because a credible planning policy case has not been made for seeking a reduced housing target figure with a consequential requirement to seek to locate unmet need in other local planning authority areas under the duty to co-operate."

The inspector was also unconvinced of the Council's ability to demonstrate a 5.25-year housing land supply and expressed concerns about evidence supporting the Council's housing trajectory and proposals for the provision of employment and retail space.

In response to the inspector's concerns, the Council produced a proposed timetable (3-page / 685 KB PDF) for completing further work. An expert's assessment of the district's housing need is anticipated to be completed by the end of July, demographic projections by the end of August and evidence in support of employment and retail policies by September.