Object

Representation ID: 25158

Received: 23/03/2021

Respondent: Home Builders Federation

Housing Need and Requirement

The NPPF expects strategic policy-making authorities to follow the standard method in this guidance for assessing local housing need. The HBF has considered the LHN using the Standard Methodology set out in PPG, it can be calculated as follows:

Step 1 - Setting the baseline:
2014-based household projections in England average annual household growth over a 10-year period, with the current year being used as the starting point. The household projection for 2021 was 213,692 and in 2031 it is 229,467, therefore the growth equals 15,775, giving an average of 1,577.5 households each year.

Step 2 - An adjustment to take account of affordability:
The most recent median workplace-based affordability ratio for Bradford (2019) is 5.23.

Where an adjustment is to be made, the formula is:

Minimum annual local housing need figure = (adjustment factor) x projected household growth.

For Bradford this would be: Minimum annual local housing need figure = (1.076875) x 1,577.5 = 1,699.

Step 3 - Capping the level of any increase
The Bradford Core Strategy was adopted in 2017, and is less than five years old, therefore the local housing need figure is capped at 40% above average annual housing requirement figure set out in the most recently adopted strategic policies. The Core Strategy has a housing requirement of 2,476dpa, 40% above the 2,476 would be 3,466dpa. The minimum annual LHN is therefore below this cap, and therefore does not limit the increase to the local authority’s minimum annual housing need figure.

Step 4 – Cities and Urban Centres Uplift
A 35% uplift is then applied for those urban local authorities in the top 20 cities and urban centres list. This includes Bradford.
The 35% uplift for Bradford would be 1,698.77 x 0.35 = 594.5695

Therefore, the minimum LHN for Bradford as calculated by the standard method is 2,293 dwellings each year.

The HBF is concerned that the Bradford Local Plan housing requirement, at 1,704dpa is significantly below the identified LHN of 2,293dpa. The Plan states that ‘based on current evidence it is considered that the additional 35% uplift of the standard method cannot be realistically met in terms of deliverable land supply, strategic constraints (Green Belt) and potential significant adverse impacts within the Regional City of Bradford’. The HBF does not consider this to be consistent with national policy or the Government’s objective to boost the supply of homes.

It should be noted that the standard method identifies the minimum LHN and there may be circumstances, as set out in the PPG, when it is appropriate to plan for a higher housing need figure than the standard method identifies. These circumstances include where there are growth strategies, strategic infrastructure improvements, an unmet need from neighbouring authorities or where previous levels of housing delivery in the area or previous assessments of need are significantly greater than the outcome of the standard method. The HBF recommends that the Council give further consideration to these circumstances.

The HBF considers that the Council should amend the housing requirement to better reflect the LHN identified by the standard method, and to take into consideration the circumstances where it may be appropriate to plan for a higher figure.