The Herefordshire Council’s Draft Core Strategy, published in March 2013 and confirmed in May 2014 (Pre-submission version) proposed 5,300 new houses to be built in rural Herefordshire between 2011-2031. Following the February 2015 Examination in Public by the Planning Inspector, the Council put forward proposed “Main Modifications” on their website: https://www.herefordshire.gov.uk/media/2059746/Main-modifications-consultation-document.pdf.
In Main Modification M037 para 4.8.26 on page 48 (PDF page 50) there is the new statement “The target represents a level of growth for settlements, as a percentage, that is proportionate to existing HMA characteristics. For individual settlements in each HMA, this will be reflected as a percentage of the TOTAL number of DWELLINGS in the PARISH concerned.” The target now proposed is a MINIMUM.
For the past 2 years the formula for applying the growth target has been based on a different premise, written in the July 2014 version of the Core Strategy as “a percentage of the total number of dwellings in the village core (not parish)”. The target was indicative, not a prescriptive minimum.
This changed with the 5 year Housing Land Supply Report February 2015 produced by Herefordshire Council (para 4.3 ) which clearly states that “The Herefordshire Core Strategy covers the period 2011-31 and provides for a minimum 16,500 homes. This target exceeds the objectively assessed need identified for between 15,400-16,200 homes over this period by 2% – 7% (300-1,100 homes).”
Now the Main Modifications (if implemented) would change that, following only a 6 week consultation. For the whole rural area of Herefordshire the outcome is as follows:
|Rural areas||Old formula||New formula|
|Target new houses allocated in Settlements||3,250||5,269||+62%|
The Council have now confirmed that the total minimum target remains at 5,300 and that it does include the “windfalls” which are 850, so this website page has been updated to reflect this new information. It does however remain a puzzle that the Core strategy Rural target remains at 5,300 when the latest Office for National Statistics projections, published in February 2015, forecast that household growth in Herefordshire for 2011-2031 will be 17% lower than allowed for in the “modified” Core Strategy.
This new formula would produce 62% (or 5,269-3250 = 2,019) more houses than before, just in the listed settlements targeted for development. The targets are now minimums as they are not capped. (Neighbourhood Planning Groups across the county have been working with applying the old formula to their listed settlements for many months and it is only now that they are being told that the housing requirement has to be increased. This is despite that fact that the Main Modifications applying this rule are currently out to consultation and have not been ratified yet by the Planning Inspector or the full Council of Herefordshire).
There is also a gap of 2,050 houses between the Core Strategy total 5,300 and the target housing growth in settlements of 3,250 calculated under the previous settlement-based formula. 1,000 or so would be windfalls as discussed in the Pre-submission Core strategy, but there is still then a “missing” number of 1,050 houses (5,300-3,250-1,000=1,050) which emerges from that comparison, which Herefordshire Council planners need to explain. One suspects that that missing number is in part a reason for the sudden and rather hidden change in the growth formula methodology. If there has been a mistake why not admit it?
When the detailed impact of the change to the new formula is considered, it produces some bizarre, disproportionate effects. When the new formula is applied to settlements in parishes where the parish boundary is not much larger than the settlement boundary, the housing numbers will generally increase just a little (e.g. Moccas, in Golden Valley where the number of new houses would change from 5 to 6.) However where there is a much larger Parish, applying the new formula will increase the numbers on the settlement much more (e.g. Cradley where the number of new houses required would change from +58 to +102. Explanation: the Parish of Cradley according to the ONS Census in 2011 was 733 dwellings but the settlement size of Cradley itself, as determined by Herefordshire Council, was 418 dwellings. A 14% Ledbury area growth target x 733 = 102 not the previous 14% x 418 = 58. The new ‘rules’ then apply the 102 extra houses totally to the settlement itself i.e. to Cradley village.)
There are other even more extreme examples:
- Much Cowarne would move from a target of +5 new dwellings to +29
- St Weonards would move from a target of +5 new dwellings to +22
And there is another problem. The boundaries which the Office for National Statistics sets for the statistical basis are based on “Output Areas”. Sometimes they coincide with Parish boundaries (the ones quoted above do coincide) but many do not.
This information has been provided in good faith to assist parish(es) to understand the implications of the proposed Main Modifications to the Draft Core Strategy.
The six week period of consultation will run from 20 March to 1 May 2015 so if you are concerned about this change, you have until then to make your opinion known to the Inspector.
The Summary of Modifications is here: https://www.herefordshire.gov.uk/planning-and-building-control/planning-policy/core-strategy/examination-of-the-herefordshire-local-plan-core-strategy/post-hearing-and-further-consultations/summary-of-modifications