During tonight’s Castle Point Cabinet meeting, whilst Cabinet members busy themselves “Noting” the publication of CPBC Annual Monitoring Report they may wish to consider the Housing Completion position of the local authority.
The Report in comparing the disbanded RSS figures of 200 dwellings per annum up to 2012, and the CLG figures of 285 dwellings per annum up to 2014, the housing provision in Castle Point indicates a chronic under supply!
2001 – 2014
Annualised Target 2,770 Total Net additional Dwellings achieved 1,234 An under supply against Target of -1,536 dwellings
However these figures carry a footnote;
“The figures presented have been amended since the 2011/12 AMR to reflect the decision of the Inspector for the Glebelands Appeal to remove past delivery of park homes at Kings Park from completion figures.”
Further into the Report it reads; “calculations indicate that Caravans in residential use across the Borough 2001 – 2014 shows an increase of 1,409”
The Glebelands Appeal Inspector’s considered;
302 However, it is questionable whether counting these as housing completions is within the spirit of what the NPPF seeks to achieve in terms of national housing policies.
- I appreciate that the changes that have occurred at that site might have taken up some of the District’s housing need. But that does not necessarily mean that the households now occupying caravans, would have chosen that type of accommodation, in preference to bricks-and-mortar; there is certainly no evidence to that effect.
- The main purpose of assessing the 5-year supply is, as stated in the NPPF’s paragraph 47, to boost the supply of new housing. At Kings Park, no houses have been built at all.
- There is no evidence that those needs have gone away, or been met elsewhere. It is difficult therefore not to agree with the appellants, that this is likely to mean more households either becoming homeless, or living in overcrowded or unsuitable accommodation . In Castle Point, that may include households moving into caravans.
No doubt when Local Plans fail through the lack of Traveller Site Provision, Inspectors do not query the right to choose what type of home constitutes a dwelling.
It is surely clear that if something has bedding facilities like a home, has cooking facilities like a home, has toilet facilities like a home and is charge Council Tax like a home, then the chances are it is a home!
The fact is that some of the dwellings may not be best suited for year round accommodation, BUT the Local authority have sanctioned there use.
The issue says more about the standards of those in authority than it does about whether dwellings have been provided. Some residents prefer this type of accommodation and if that is the case there right to chose should be protected.
As long as they are aware that caravan dwellings in a Flood Risk Zone offer little protection. Being close to the Hazardous Industry sites also requires consideration.
However whilst Council Tax is collected the local authority must accept responsibility for these risks, as it can be argued that CPBC condones the situation.
Regarding housing delivery the projected requirement of 200 and 285 we can assume disregards Constraints, as no Local Plan is in place, except the out of date 1998 Plan. The Local Plan Task and Finish group meet next week to discuss how the Objectively Assessed Housing Need figures may be affected by local Constraints.
The Planning Inspector referred to caravans thus “However, it is questionable whether counting these as housing completions is within the spirit of what the NPPF seeks to achieve.”
“However it is questionable” whilst not a ringing endorsement, hardly prohibits caravans inclusion to some extent within the housing completions.
In fact he goes on “that does not necessarily mean that the households now occupying caravans, would have chosen that type of accommodation,” which cannot be denied is conjecture.
An opportunity was missed during the 2011 census to gather important evidence as to preferences.
Many people have moved into the area and into caravan accommodation, they would have added to the area’s population, in turn this would filter into the population growth estimate.
Clearly the inclusion of the caravans into dwelling figures is for the local authority to decide through committee. The point will be raised during the Appeals covering Jotmans and Glebelands and point of reference will be made to the previous Inspector’s judgement, when really this should be tested through the Local Plan process.
The local authority refer to sustainability of sections of the Borough, rather than Borough-wide. The sustainability of Canvey is used as THE reason for a Canvey development scheme passing the Sequential Test. In contrast the need for affordable and social homes across the whole Borough is left unaddressed! Whilst caravans are permitted for use for this purpose on Canvey the whole Borough reaps the benefit.
Once again an in-house, rather than commissioned Report receives Cabinet approval, ahead of its criticism at Appeal.