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Why Tandridge Council's housing need figure is wrong

OLRG has been contacted by a number of residents who have been told that the Council's proposed objectively assessed need figure (OAN) of 9,400 is

1) set by the Government

2) an accurate figure arrived at via a process laid down by the Government.

Neither of these things is correct.

The proposed OAN figure is a standard population projection spat out by a computer model which mechanically projects recent past trends into the future.

In Tandridge's case, the model assumes that the past very high levels of inward migration resulting from the past very high levels of house building - Tandridge has been building roughly double its housing requirement for many years - will continue into the future. The consequence is that around 90% of the population increase included in the proposed 9,400 figure is comprised of inward migration from other districts into Tandridge.

This is no more than a reflection of past unusually high levels of house building in Tandridge combined with under-provision elsewhere and is not an indication of housing need attributable to Tandridge.

One clear sign that the standard projections and the OAN figure are likely to be skewed and unreliable comes from the major discrepancy between the figures and the characteristics of Tandridge. The evidence base published in the Local Plan documents describes Tandridge as a predominately rural district with no recognised economic or population centres and limited economic growth.

And yet the projections show the population growing by 17.7% from 2013 - 2033. This is higher than the projected growth rate for Surrey or the South East which have numerous, large population and economic centres and stronger and more diverse economic growth. This mismatch between the projection results and Tandridge's characteristics needs investigating because cross-checking model results with reality is a routine part of helping ensure that model results are reliable.

An investigation shows that the past high levels of inward migration were due to the accelerated rate of housing development which was made possible because a considerable amount of brownfield land, including a number of large, ex-military and health sites, were brought forward for housing development in quick succession.

This unusually high rate of house building combined with under-provision of housing in other districts, such as Croydon and Mid-Sussex, artificially increased inward migration and dampened outward migration leading to high net inward migration levels. The Council's own Local Plan documents explain that the rate of house building and inward migration are linked.

So, the standard projections have simply captured past history and projected it into the future. They assume that the same pattern will persist for the next 20 years into the future, but the remainder of the evidence shows that the supply of these brownfield sites has been exhausted.

Therefore, the standard projections are not reliable guides to the future and do not give a scenario that could reasonably be expected to occur which is what is required by National Planning Practice Guidance.

In addition, Tandridge's most recent Local Plan documents state that the proposed 9,400 figure includes a significant amount of inward migration that comprises 'lifestyle choice'. Recent best practice for OAN calculations published by the Government-sponsored Planning Advisory Service explains that lifestyle choices are aspirational and so should not be included as part of housing need.

The proposed OAN figure also includes unmet need and inward migration from a wide range of other local authorities even though there is no obligation to include that need in the Tandridge OAN because Tandridge is not in the housing market area of any of these other local authorities.

The Council's most recent documents state that the proposed OAN relies on jobs outside of Tandridge to provide employment for the sizeable projected increase in the labour force, which is primarily driven by high levels of inward migration. However, the reliance on jobs located outside the district is contrary to the Government objective of locating jobs near homes. Reliance on employment outside the district will also create a dormitory district reliant on the car which is unsustainable and contrary to the Government policy.

Lastly, there are significant unexplained mathematical discrepancies between the standard projections and the OAN figures, where, for example, charts in the Local Plan documents show a labour force that appears to be three times the size of that in the standard projections. The lack of transparency in the Local Plan documents means that it is impossible to externally cross-check the calculations.

For these reasons, we believe that the Council's proposed OAN figure is inflated and unrealistic, and it may also be mathematically incorrect.

Of particular concern to OLRG is that these reasons are not new and Tandridge Council itself has previously given evidence highlighting a number of the flaws mentioned above to a Planning Inspector at a Public Inquiry in 2014.

These are two quotes from the Council barrister's closing submission regarding a similarly inflated OAN number that had been put before the Inquiry:

"... the demographic projections are not robust when applied to the particular circumstances of Tandridge... They are predicated upon a massive increase in population which bears no relationship to past trends of population growth...."

" the Council has explained that in the past a number of large military and health sites (and employment sites) have been developed in Tandridge, unexpectedly;
the Council has also explained that there is a close correlation between the high number of completions recently achieved against the Core Strategy requirement and the high levels of in-migration at a similar time."

The Council has given no explanation as to why it has so fundamentally changed its position and why it is now proposing an OAN containing similar flaws to those it previously highlighted and argued against to the Planning Inspectorate.