A ROBUST EVIDENCE BASE? A Report on quality in Housing Needs and Strategic Housing Market Assessments: Executive Summary
1. Many £millions have been wasted (unintentionally) by councils on faulty HNS, and now faulty SHMAs. A great many more £millions have been wasted on wrong strategic housing choices using that wrong evidence. This has been going on for at least a decade, but there is no sign that DCLG has yet understood the level of waste involved. It has taken no action to introduce quality control. As a result the prospects for properly focussed new housing policies under PPS3 (Nov 2006) is poor. This report presents some findings.
2. The Government has required an evidence base when councils seek affordable housing for many years (since 1991 to be exact). That is how housing needs surveys (HNS) began. Only towards the end of that decade did the Government show awareness of the poor quality of much of the HNS work. But no mechanism was put in place to ensure robustness. The only forum in which robustness could be tested is the Local Plan Inquiry (LPI or UDP), now the Local Development Framework (LDF).
3. The first phase (1998-2004) arose when the Home Builders Federation (HBF) in particular launched attacks at LPIs mainly on HNS by Fordham Research as the leading firm. These rose to a peak in 2003, but since all of them failed, these technical challenges to HNS by developers have effectively been abandoned.
4. The second phase (2005-6) of challenges was based on quality control (or lack of it). Fordham Research carried out a dozen or so 'pro bono' objections at Inquiries to show the weaknesses in HNS work. A number of Inspectors devoted considerable energy to addressing the large amounts of detailed reasoning involved.
5. In 4 of the 14 cases the Inspector dismissed the HNS as unsound evidence, and in another 5 cases found significant flaws (details in Chapters 2-3). This is remarkable: the presumption has been that HNS are sound. But over 60% of these were found to be flawed.
6. The new Practice Guidance for PPS3 stresses the use of secondary (existing) data as opposed to fresh surveys and also discourages Inquiry challenges on the technical soundness of the new Strategic Housing Market Assessments (SHMAs). However PPS12 (on LDFs) requires a rigorous evidence base, and so challenges are likely.
7. Early results from SHMAs based on secondary data only suggest that there are significant technical shortcomings. The results are summarised in Appendix 2. The situation is not helped by the fact that PPS3 makes clear and detailed demands on the evidence base, but the Practice Guidance is ineffective. Quality control will remain an issue.
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