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National and regional estimates of housing need in Wales
On 30 January 2019 the Welsh Government published its 2018-based national and regional estimates of overall housing need in Wales for 2018/19 to 2037/38. These estimates are intended to inform policy decisions, in particular in relation to the emerging National Development Framework (NDF) and future Strategic Development Plans (SDPs). However, Welsh Government has made it clear that the estimates are policy neutral and do not in themselves constitute housing targets. The national “central estimates” indicate a need for 8,300 additional dwellings per annum (dpa) for the first five years of the 20-year period (2018/19 to 2023/24), decreasing to an average of 3,600dpa during the last five years of the period (2033/34 to 2037/38). This slowing rate of growth mirrors that contained in the 2014-based household projections, which form the basis for the assessment. Excluding the existing unmet need element, the central estimates indicate a need for 5,417dpa between 2018 and 2038. By comparison, the previous estimates published by the Public Policy Institute for Wales in October 2015 indicated a need for 8,700 new homes per annum from 2011 to 2031. Does this mean that the need for new housing has significantly reduced? In our view, which seems to be echoed by Welsh Government policy statements, the answer is emphatically no! It is therefore important to understand the basis of these estimates and what they really mean for policy making. Table 1: National estimates of housing need: newly-forming households (5-year averages) Source: Welsh Government 2018-based estimates of overall housing need in Wales Five different scenarios are presented, based on different demographic and migration assumptions, with the national level of need ranging between 6,700 and 9,700dpa during the first five years. The central estimates for the three identified regions during the first five years (2018/19 to 2022/23) are: North Wales: 1,600dpa; Mid and South West Wales: 2,000dpa; and, South East Wales: 4,700dpa. Table 2: Regional estimates of housing need (5-year averages) Source: Welsh Government 2018-based estimates of overall housing need in Wales The Welsh Government has stated that the estimates will be reviewed “at regular intervals, as and when more up-to-date information becomes available”. However, at the time of writing Welsh Government is unable provide an indication as to when this will be. Methodology Following the approach pioneered by the Scottish Government in its Housing Need and Demand Assessment tool, the 2018-based housing need estimates have been calculated based on: Newly-arising need, as identified by the 2014-based household projections; and, For the first five years of the period only (2018/19 to 2022/23), existing unmet need, comprised of: a. Homeless households in temporary accommodation (Welsh Government homelessness data (June 2018)); and,b. Households that were both overcrowded and concealed (Census 2011). Figure 1: 2018-based housing need estimates: Methodology Source: Welsh Government Statistical Article (30 January 2019) / Lichfields Newly-arising need Whilst the estimates are identified as “2018-based”, they are actually derived from the 2014-based household projections. There are a number of concerns with the use of household projections as the basis for assessing housing need, principally stemming from their derivation from past trends. In the case of the 2014-based projections, the principal projection is based on trends experienced between 2009 and 2014. This data was therefore collected primarily during the recession years, which saw suppressed levels of household formation and reduced housing delivery. The 2014-based projections indicate a level of household growth that is 21% lower for Wales than the expected level of growth in the previous (2011-based) projections between 2014 and 2036[1]. The 2014-based projections also indicate a decline of 107,700 working age people (age 16 to 64) (5.6%). The direct translation of these household projections into housing requirements would therefore result in a smaller workforce and potential economic and social difficulties in future. While it is appropriate that the most recent household projections should form the starting point for housing need assessments in Wales, policy makers should recognise and seek to respond to the specific limitations of the 2014-based publication. In accordance with Planning Policy Wales (ed. 10) plan preparation should also take account of other key factors, including the alignment between housing and jobs, the need for affordable housing, and the objectives of the plan. In South East Wales, the Cardiff City Deal is seeking a step change to boost the local economy. A continuation of the past trends embodied in the 2014-based projections would be contrary to this strategy and could jeopardise delivery of the City Deal. It follows that housing requirement policies in the emerging NDF and future SDPs should seek to support the Welsh economy by providing a sufficient number of homes, and of a sufficient quality, to attract and retain skilled professionals and should not carry forward the recession-based trends in the most recent projections. Existing unmet need For the first time, the housing estimates take account of “existing unmet need”, i.e. existing households without a home of their own – but only for the first five years of the 20-year period. It is assumed that all of this unmet need, totalling 5,645 households, will be cleared within these five years. The Welsh Government has noted that unmet need figures will be updated when the overall estimates are reviewed. The Welsh Government has acknowledged that its assessment of existing unmet need is “likely to be an undercount”, as it does not encompass the full range of need for additional homes. In particular, it only includes concealed households where they were both concealed and overcrowded. Furthermore, single people are not identified as a concealed household under any circumstances, so any single person living in a shared household, for example with parents, or an older person living with an adult child would not be counted. This approach therefore underestimates the number of households in need of a home of their own. Even more troubling is the fact that the overcrowded and concealed household data is taken from the 2011 Census and is included as a number rather than a proportion of all households. These statistics are now dated. For comparison, we note that the total number of concealed families in Wales increased by 57% (+4,832 households) between the 2001 and 2011 Census[2]. While the Welsh Government’s inclusion of an element of unmet need in the housing estimates is to be welcomed, it is important to recognise that its approach significantly underestimates the actual level of unmet need. Tenure breakdown  The overall national and regional housing need estimates will be broken down by tenure in Spring 2019, to include the following sectors: Owner-occupier; Private sector rent; Below market rent; and, Social rent. We will be interested to see how the need for each of these tenures has been calculated and distributed. However, the crucial test will be during plan preparation to understand how these figures are applied in policy – and the extent to which they impact upon viability and deliverability considerations. [1] The common period covered by both sets of projections [2] Equivalent data from the 2001 Census on overcrowded and concealed households is not available.  


Drones, airports and an already constrained airspace: are the latest government proposals enough?
Last week, for the second time in less than a month, flights at a major London airport were halted by drone activity. On 8th January flights out of Heathrow Airport were suspended for over an hour, following drone sightings. Between 19th and 21st December, the runway at Gatwick Airport was closed for nearly 36 hours after drones were reported over the airfield, with flights unable to take-off or land. At Gatwick, as the world’s busiest single-runway airport and on one of its busiest days of the year, there were estimates of 140,000 passengers that were due to use the airport being affected. The media, aviation sector and public have all watched with interest. Malicious use or otherwise, this is clearly a very serious ongoing issue whereby substantial drones have been used to bring about the temporary closure of two major international airports. Questions have been raised: why was it apparently so easy to shut a British airport with a drone, what controls are there to avoid it happening in the future, and can drones actually co-exist with existing operations in our airspace? To add to the drama, the Heathrow Airport drone sighting followed only days after announcements by the Secretary of State for Transport, Chris Grayling, of plans for further drone regulation.  In a previous blog of June last year, I set out the current policy and regulatory framework and explained new laws for drone operators. Announced in May 2018, the new laws came into force in part from July 2018 with the remaining provisions coming into force on 30 November 2019[1]. At the time of announcing the new laws, Government said that these new measures, alongside an upcoming draft Drones Bill, would be the first step in setting the UK on a path to be a global leader in the drones use, tackling misuse to build public confidence in drone technology and encourage positive, innovative drone use in the UK – stating ‘ensuring drones are being used safely will pave the way for the devices to play an increasingly important role in society, and demonstrating that the industry can operate safely will be key to its advancement’. So, what’s next for government to ensure this societal and safety objective – and within the context of these drone incidents? Last summer, Government published a consultation paper ‘Taking flight: the future of drones in the UK’, seeking views on proposed legislation regarding the use of drones. Government also released a Drones and Other Unmanned Aircraft Bill impact assessment. The consultation period ran from July to September 2018 and detailed a number of proposed policies, including: a minimum age requirement for operators for small unmanned aircraft; whether the 1km flight restriction around protected aerodromes is sufficient; proposals to mandate and regulate a Flight Information and Notification System (FINS) as part of future unmanned traffic management and airspace modernisation programme; the powers required by enforcement bodies in order to properly police drone use and penalise incorrect use; and counter drone technology system proposals. The consultation also looked ahead on how counter-drone technology could be used as a means of addressing the potential threat malicious misuse of drones can pose; and the estimated growth in numbers of commercial drones in the UK over future years. On 7th January, Government published its response to this consultation. The response outlined government’s decisions, in particular, to legislate to give the police greater powers to tackle drone misuse, including the power to issue on the spot fines, and to better protect airports by extending the area around airports and runways in which drones are banned. There will be new powers for the police to order an operator to ground a drone if it’s deemed necessary. The police will also be able to seize drone parts, to prove the drone has been used to commit a criminal offence. This all builds on the new laws announced last year. The Heathrow drone sighting occurred the day after this government announcement, reinforcing just how important these new measures are and the need to implement them into legislation as soon as practicably possible. By the end of the week, the Aviation Minister, Baroness Sugg met UK airport bosses to discuss the technology already in use and how airports can strengthen their defences. Government has now said that it is considering implementation of military-grade anti-drone equipment at all major UK airports, as well as other critical infrastructure such as power stations and prisons. However, cost will no doubt be an issue. In the aftermath of the Gatwick drone incident, it was reported that the airport installed a £1million protection system, comprising 360-degree radar and thermal imaging systems, as well as a radio jammer. An airport’s security ‘fence’ will no longer be just the standard 1.8m chain link fence around an airport boundary. While big airports like Gatwick and Heathrow may be able to meet the cost of several million for drone protection, smaller operators will not have that luxury, potentially simply shifting the problem to the places that are less able to deal with it. Are these plans enough? Until now, Government has followed a light touch approach and the only legislation that has so far been passed focuses on regulating the drone user. Will this latest round of proposed regulation, combined with that announced last year, provide sufficient checks and controls to mitigate against another Heathrow/Gatwick drone incident? The Aviation Strategy Green Paper consultation ‘Aviation 2050 — the future of UK aviation consultation’, which commenced in December 2018, and the House of Commons 2nd reading of the Drones (Regulation) Bill 2017-19, which is expected sometime this year, should build on this work to date. As drones continue to play an increasingly important role in our society there will be pressures placed on our airspace and there is a growing need to understand how current users and new users (drones and other unmanned aircraft) can co-exist, and co-exist in an already constrained environment. The potential of drone technology to aid the way we live, work and play is wide-ranging, offering so much more than solely a recreational application. The Heathrow/Gatwick incidents must not prejudice its future. What is certain is that regulation and policy must continue to play catch-up, and then in consultation with industry, anticipate innovations in advancing technologies; safety must continue to be its focus. This includes aerodrome safeguarding and facilitating an airspace that can benefit all. Failure to do so will likely lead to another airport shutdown, or at its worst, a major aviation disaster.   [1] Announced 30 May 2018. In force in part from 30 July 2018 with the remaining from 30 November 2019, in an amendment to the Air Navigation Order 2016 (The Air Navigation (Amendment) Order 2018.