We have recently read a LPA S.78 planning appeal statement of case that claims that the housing needs assessments produced by the LPA “ are a robust examination of housing need ”. The LPA considers that its HNA’s are exemplary and should be replicated. Only their methodology would be accepted as robust evidence of need.

Following our assessment of the example of its robust housing need assessment supplied by the LPA that accompanied the statement of case (therefore in the public domain), we can confidently say that the HNA is neither robust nor does it meet the LPA’s own policy for evidencing need for a rural exception site! How inconvenient for the LPA.

There are 4 fundamental issues with the LPA’s preferred methodology;

1) The first fundamental issue is that the HNA makes no reference to supply.   An assessment of supply is necessary. Logically, the snapshot of households in affordable need is not the same as the number of additional homes that are needed.   The LPA fails to take into account that supply from vacancies is likely to occur to mitigate the measure of need. Have any planning consents been granted that amount to committed development that will help to address the outstanding need?

2) The second fundamental issue is that the LPA relies on a headcount of households i.e. at the point the survey was undertaken X households were in housing need. Somehow the number X is interpreted as the level of need ignoring the fact that only a small proportion of households actually completed the survey, and that housing need is in fact a flow of households measured over time. The flow over time provides a further dimension to the assessment (turning the circle into a sphere).

3) The third fundamental issue is that the LPA survey questionnaire even fails to ask if the household in need is seeking to remain living in the parish or is planning to leave it!   Therefore evidence is questionable to support the council’s policy requirement to demonstrate that need for local housing exists.

4) The fourth fundamental issue is that house prices and rents are not fully analysed or described in the report. The report is ambiguous about prices and there is no clarity about how the test of affordability is applied. This is crucial to the credibility of the report.

The problem is that 80% to 90% of HNAs in circulation on England are produced by LPAs or rural enablers and none of them are robust as they are all rely on a similar methodology.

So why the disc to sphere analogy? Because measuring the flow of need over time adds an extra dimension which most thinking people recognise as true!

Our full critique of the LPA one dimensional HNA can be found at the following link. It makes fascinating reading. https://www.cnbhousing.co.uk/independent-expert-witness-services

For follow up reading we recommend  the various publications of philosopher and astrophysicist Neil DeGrasse Tyson who applies deep thought to belief systems and subjectivity.