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Welsh Government 2018-based subnational household projections: A warning
On 27 February 2020 the Welsh Government published its 2018-based subnational household projections, which replace the previous 2014-based projections (published in March 2017). The new projections indicate that there will be c.38,000 additional households living in Wales in 2028 compared to 2018, an increase of 2.8%. While the projections cover a 25-year period from 2018 to 2043, the Welsh Government’s focus in its announcement of the new figures (and my focus in this blog) is on the initial 10-year period, given that the results are increasingly uncertain in the longer term.The new household projections show a drastically reduced level of growth across Wales when compared to the 2014-based data set – 42.9% lower for the 2018 to 2028 period. The projections have been constrained to align with the ONS national 2018-based population projections for Wales, which show stagnation in the population during this period (+0.6% growth) and a decline in the longer term. The working age population (aged 16 to 64) across Wales is anticipated to decline by 1.7% from 2018 to 2028, whilst the number of residents aged 65+ is expected to increase by 13.8%. At the local authority level, the size of the total population is expected to reduce in a total of 11 local authorities, with the working age population projected to decrease in 17 local authority areas. This projected stagnation of population growth and decline in workers is alarming. It is critical that this model does not constitute the basis for forward planning in Wales, which should seek the achievement of sustainable development through promoting social, economic and environmental well-being. An important element of this pillar of planning is to deliver economic growth and tackle the challenges associated with an ageing population, including spiralling dependency ratios – issues readily acknowledged by the Welsh Government. Furthermore, one of the key themes of the Welsh Government’s national strategy, “Prosperity for All”, (December 2017) is to drive an economy which spreads opportunity and delivers prosperity, to include providing secure employment and creating the right environment for businesses to grow and thrive. The achievement of this aim will require supporting the retention of a suitably sized workforce through the provision of sufficient housing – which is clearly not reflected in the household projection figures. Use of the projections As required by Planning Policy Wales (PPW) (edition 10, December 2018), the new projections will form a “fundamental part” of the evidence base for Local Development Plans (LDPs), including in particular the setting of housing requirements. However, the negative direction of travel indicated by the new projections highlights the importance of the PPW requirement that plan-makers should consider the projections together with other key evidence, including the links between homes and jobs, the need for affordable housing, and the deliverability of the plan. The projections will also inform an updated set of national and regional “estimates of housing need” (date TBC) to replace those published in January and July 2019 (see my blog: Welsh Government Housing Need Estimates by Tenure). These estimates are referenced in the draft National Development Framework (NDF) (August 2019) and will inform future Strategic Development Plans (SDPs). Scale of growth A total of 15 of the 22 local authorities (excluding National Parks) are expected to experience growth in the number of households between 2018 and 2028, ranging from +0.3% in Merthyr Tydfil to +6.9% in Newport. A total of 7 local authorities are projected to experience decline, ranging from -0.4% in Denbighshire to -4.8% in Ceredigion. Figure 1 Welsh Government 2018-based subnational household projections: Scale of growth (2018-2028) Source: Welsh Government 2018-based subnational household projections / Lichfields Projected household growth is expected to be heavily focused in South East Wales, accounting for 72.2% of all growth in Wales between 2018 and 2028. Cardiff is projected to account for the highest proportion of total growth over the 10-year period (20.1%). Table 1 Top five areas of projected household growth (2018-2028) Source: Lichfields analysis of Welsh Government 2018-based subnational household projections The greatest reduction in anticipated household growth when compared to the 2014-based household projections relates to Cardiff, which is expected to see an increase of only 766 households per annum between 2018 and 2018, compared to 1,906pa in the 2014-based projections (a 59.8% decrease).Figure 2 Difference between the Welsh Government 2018-based and 2014-based subnational household projections (2018-2028) Source: Welsh Government 2018-based and 2014-based subnational household projections / Lichfields Why such a significant reduction? So why are the 2018-based household projections so much lower than the previous set? The Welsh Government has not yet published its full quality and methodology information on the new projections (expected in March 2020). However, the key reasons for the differences in this data relate to their basis in the associated 2018-based population projections. The Welsh Government introduced several changes to its methodology in producing the 2018-based subnational population projections, including constraining the total local authority population figures to match the national total published by the ONS. Interestingly, the Chief Statistician’s blog of 20 February 2020 notes that, had the Welsh Government not applied this constraint, the combined local authority figures would have continued to show “strong growth” over the projection period. There were some reasonable assumptions behind this methodology change but the difference it has made does highlight the need to take a critical view of the results. What is clear is that the projections do not reflect national and local committed strategies for economic growth and regeneration and fall far short of actual housing need in Wales. They simply carry forward past trends in natural change and migration, which would result in a rapidly ageing population and ever-increasing dependency ratios – outcomes which should not be acceptable in 21st century Wales. Impact and implications Unless substantial productivity improvements are delivered, the inevitable result of a reduction in the total workforce of Wales would be a shrinking economy. This would in turn make it more difficult to meet the increased social care costs associated with an ageing population. It is therefore vital that these projections are applied only as a starting point and that planning policies at all levels move quickly away from carrying forward these patterns of past underperformance. Instead, plan-making must support policies promoting prosperity and well-being through alignment with positive economic and social outcomes, such as those within the Cardiff City Deal. In particular, there is a need to attract and retain younger people and workers in order to boost the economy, provide skilled jobs and improve productivity. Hence, rather than a basis for future plan-making, these latest projections should stand as a warning about how Wales might look in 10 to 25 years’ time if we fail to deliver the positive social and economic outcomes desperately needed.


Welsh Government housing delivery proposals: Fixing the system or hiding its failures?
Planning for housing is not an academic exercise. An insufficient supply of deliverable housing land means not enough homes will be built. House prices will rise (further). Some people will be left without a home of their own. This is why it is of paramount importance that we have a planning system in Wales that works to deliver housing. On 9 October 2019 the Welsh Government published its consultation document, “ Delivery of housing through the planning system: Revisions to Planning Policy Wales and associated advice and guidance”. Responses are due by 20 November 2019. The focus of the document is on responding to the perception that developers are taking advantage of the long-established five-year housing land supply policy (Planning Policy Wales). It implies that developers are disingenuously “querying” the deliverability of allocated sites, thereby reducing local authorities’ five-year land supply figures and swaying the planning balance in favour of obtaining permission on “speculative” sites – coded language for windfall sites, which the Welsh Government implies are undesirable. Its key proposals are: To remove the requirement in Planning Policy Wales for local planning authorities to provide a five-year supply of land for housing. To consequently revoke Technical Advice Note 1 (TAN1) in its entirety. To replace the monitoring of housing land supply by the monitoring of housing delivery based on the Local Development Plan (LDP) housing trajectory, to be reported through the Annual Monitoring Report (AMR). These latest proposed changes follow the Welsh Government’s disapplication of paragraph 6.2 of TAN1 in July 2018, which attached “considerable weight” to the lack of a five-year housing land supply as a material consideration in determining housing applications. (N.B. The disapplied paragraph did not state that this would be the overriding factor; in order to secure planning permission, proposals would still need to meet the principles of good planning and be assessed as sustainable.) This move, which was widely opposed by developers, left the matter of weight to be given to this factor to the discretion of the decision-maker when taken in the round as part of the planning balance. The lack of a five-year supply therefore remained (and still is currently) material to planning decisions. This is key to ensuring sites are brought forward to provide needed homes in the short to medium term. If the requirement for a five-year supply is taken away entirely, there would be no policy basis for supporting development proposals according to their potential to fill unmet housing needs. With 19 out of 25 local authorities currently unable to demonstrate that they have enough housing land in the pipeline to meet needs over the next five years, there is a clear imperative to bring additional sites forward. If this is not happening through the plan-led system, surely measures should be kept in place to support the delivery of housing through other routes? The Welsh Government proposals would also result in key differences in the way local planning authorities assess how their LDPs are performing and their obligations to rectify any deficiencies. Housing policies would be tested against the LDP trajectory, which would need to be updated each year through the AMR. The trajectory should set out the sources of housing land needed to meet the full housing requirement during the plan period plus a flexibility allowance (identified by the document as 10%). Delivery will be tested against projected annual and cumulative build rates based on the housing requirement (not including the buffer). There would be no hard consequences for under delivery against the trajectory. Local planning authorities would need to consider performance against all indicators of the LDP collectively and to assess the magnitude of variance (a subjective assessment) before deciding on appropriate actions to be taken. Examples of these actions in the document range from providing training to officers or members to simply conducting “further research or investigation” to triggering an early review of the plan (a process which, as we know, takes years to complete). The way in which the existing five-year supply requirement policy has been implemented has not proven adequate to deliver a sufficient number of homes through LDPs or otherwise, and this is clearly an issue that should be addressed. However, the proposals put forward in this consultation offer a significantly weaker approach, which is likely to yield even weaker housing delivery than under the current arrangements.  The proposed changes outline a system whereby the impetus for local authorities to provide enough homes would effectively be relaxed, with no hard consequences for failing to deliver and no mechanisms in place to fill the gaps. Instead of identifying ways to make the plan-led system work, they would simply re-frame the metrics to make it look as if the system is working even if it is not and cut off the only available avenue for housing to come forward. Is the current system so broken that it needs such a draconian restructure? True, changes are needed to support the delivery of housing through the plan-led system – where planning for all types of development can be considered holistically. But is the main problem an overreliance on windfall sites (in sustainable locations), or is it rather that an insufficient number of homes are being delivered to meet the needs of the nation?