Q-E1.1: Do you think that the HEDNA evidence provides a reasonable basis for identifying future levels of employment need across South Warwickshire?
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The B1 office space is shown without the caveat caused by the Covid pandemic and the move away from the traditional use of office space. Hydrid working with a reduction in the need to house all employees but to work on a 60% provision moves the balance to well connected Fibre Broadband to all new settlements allowing for home working and CO2 reduction. Repurposing of retail in town centres in consequence of the digitial ecomony and the encourage of micro- businesses and start -ups in the redundant space should change the needs for new development moving it to redevelopment.
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Larger towns are better places for more jobs and money spent regenerating them rather than killing off small villages and green space
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The UK and local fertility & birth rate would be more appropriate starting place.
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Post COVID, brexit and levelling up types of employment and ways people work should be reviewed. Also, the impact of the past few years on travel and tourism should be analysed to predict future expectations
The HEDNA adopts an approach which triangulates different forecasting techniques. This immediately gives rise to a note of caution. Each forecasting technique is based on a particular rationale, with a logical basis for how results are to be generated. Moving to some position between techniques means that the outcome does not reflect any particular rationale or have a robust methodological integrity. The HEDNA includes assumptions which are not justified. For example, reference is made (paragraph 9.32) to sensitivity modelling with a 30% reduction in office needs to reflect home working. There is of course evidence of increased demand for home working reflected in a reduced requirement for office space, but the selection of 30% is not explained. It might be informed by data of the kind presented in Figure 9.1, but that would rely on a comparison between rates of working from home pre-pandemic (which would already be “baked in” to floorspace requirements) and those experienced and expected post pandemic. That exercise appears not to have been completed; it is certainly not reported. Equally, the use of an arbitrary division between non-strategic and strategic provision at 9,000 sq m is not justified in the report. This figure has been used in other settings and is referred to in the HEDNA as a “recognised definition” but its continued use without a clear explanation of why this value is selected and the implications of segmenting the market in this way in the analysis is inappropriate. At the very least it implies a division in the market that is not reflected in the real world, and that should be acknowledged or there is a risk of HEDNA results being misapplied when they are translated into policy and allocations. The reliance placed on past trends of floorspace and completions growth is flawed. Past growth does not reflect future need – it reflects what a planning constrained market was able to deliver in the past. Relying on it will act to perpetuate past failures fully to meet the requirement for employment land. Moreover, whilst some flexibility (a 5 year margin) is allowed for in calculating strategic warehousing need this is to support a choice of sites and allow for unforeseen delays, not to make up for past under delivery. An allowance must be included to make good pent up, unsatisfied, demand. Such pent up or “suppressed” demand that might have accrued over an extended period should be fully accounted for in any analysis of the requirement for employment land that is to be relied on in the emerging Plan. This should include land for industrial as well as logistics activity. It is often the case that employment land supply fails to keep up with demand, and economic growth, investment and job creation that would have taken place were this not the case is frustrated, delayed or lost. As such, there are real-world consequences in failing to grapple with the point. Where a shortfall arises and accrues it should be made good through planned for provision. Pent up demand may be accounted for in conventional studies by making a nominal allowance for flexibility in the stated requirement (although that does not appear to be the case here) and expressing that requirement as a minimum. However, such an approach does not properly, directly or accurately engage with and measure the issue. That “flexibility” or margin is additionally included to make an allowance for other considerations such as delays in delivery, or a buffer to account for uncertainties in forecasting. However, the extent to which the flexibility allowance in the HEDNA accounts sufficiently and accurately for these multiple purposes is not known, and it appears to make no attempt to account for suppressed demand. The uncertainty in this regard should be reduced by assessing properly suppressed demand and accounting for it in policy decisions in the emerging Plan. Such an exercise needs to be completed for South Warwickshire. The results from the HEDNA do not accommodate this issue and cannot be relied upon. Notwithstanding these shortcomings, the commentary in the HEDNA about the continued potential for established growth corridors to accommodate strategic B8 growth is supported. As recognised by the HEDNA the A45 / M45 is one such corridor with a continuing key role in this regard.
I don't know enough about this approach to comment on it.
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The HEDNA adopts an approach which triangulates different forecasting techniques. This immediately gives rise to a note of caution. Each forecasting technique is based on a particular rationale, with a logical basis for how results are to be generated. Moving to some position between techniques means that the outcome does not reflect any particular rationale or have a robust methodological integrity. The HEDNA includes assumptions which are not justified. For example, reference is made (paragraph 9.32) to sensitivity modelling with a 30% reduction in office needs to reflect home working. There is of course evidence of increased demand for home working reflected in a reduced requirement for office space, but the selection of 30% is not explained. It might be informed by data of the kind presented in Figure 9.1, but that would rely on a comparison between rates of working from home pre-pandemic (which would already be “baked in” to floorspace requirements) and those experienced and expected post pandemic. That exercise appears not to have been completed; it is certainly not reported. Equally, the use of an arbitrary division between non-strategic and strategic provision at 9,000 sq m is not justified in the report. This figure has been used in other settings and is referred to in the HEDNA as a “recognised definition” but its continued use without a clear explanation of why this value is selected and the implications of segmenting the market in this way in the analysis is inappropriate. At the very least it implies a division in the market that is not reflected in the real world, and that should be acknowledged or there is a risk of HEDNA results being misapplied when they are translated into policy and allocations. The reliance placed on past trends of floorspace and completions growth is flawed. Past growth does not reflect future need – it reflects what a planning constrained market was able to deliver in the past. Relying on it will act to perpetuate past failures fully to meet the requirement for employment land. Moreover, whilst some flexibility (a 5 year margin) is allowed for in calculating strategic warehousing need this is to support a choice of sites and allow for unforeseen delays, not to make up for past under delivery. An allowance must be included to make good pent up, unsatisfied, demand. Such pent up or “suppressed” demand that might have accrued over an extended period should be fully accounted for in any analysis of the requirement for employment land that is to be relied on in the emerging Plan. This should include land for industrial as well as logistics activity. It is often the case that employment land supply fails to keep up with demand, and economic growth, investment and job creation that would have taken place were this not the case is frustrated, delayed or lost. As such, there are real-world consequences in failing to grapple with the point. Where a shortfall arises and accrues it should be made good through planned for provision. Pent up demand may be accounted for in conventional studies by making a nominal allowance for flexibility in the stated requirement (although that does not appear to be the case here) and expressing that requirement as a minimum. However, such an approach does not properly, directly or accurately engage with and measure the issue. That “flexibility” or margin is additionally included to make an allowance for other considerations such as delays in delivery, or a buffer to account for uncertainties in forecasting. However, the extent to which the flexibility allowance in the HEDNA accounts sufficiently and accurately for these multiple purposes is not known, and it appears to make no attempt to account for suppressed demand. The uncertainty in this regard should be reduced by assessing properly suppressed demand and accounting for it in policy decisions in the emerging Plan. This issue was explored in the January 2022 publication by the British Property Federation (BPF) of “Levelling Up – The Logic of Logistics”, a report considering the benefits of the industrial and logistics sector. The BPF Report comments on the modern-day growth drivers which are often not properly taken into account in estimating future demand, and also the extent to which future requirements are underestimated because the sector has been supply constrained for the majority of the last decade. To understand and address this imbalance Savills and St Modwen have developed a new methodology built upon the principle of “suppressed demand” that accounts for demand that has been lost due to supply shortages. The calculation of suppressed demand can then be added as an uplift to projections to give a more accurate picture of likely demand into the future rather than relying on assumed allowances around flexibility. The methodology is NPPG-compliant. It builds on past trends but with an adjustment for historic supply shortages (evident for example in particularly low vacancy rates) and the subsequent loss in take-up. This suppressed demand is added to the historic demand trend, and a further adjustment made for e-commerce growth. A calculation might first be made at FEMA level, and then apportioned to constituent districts to arrive at an estimate of the total industrial and logistics requirement for the area or conducted directly in relation to a specific authority. The amount of land to plan for should have regard to this requirement but will also depend on factors such as developable land capacity, qualitative considerations, and cooperation discussions between authorities. Such an exercise needs to be completed for South Warwickshire. The results from the HEDNA do not accommodate this issue and cannot be relied upon. Notwithstanding these shortcomings, the commentary in the HEDNA about the greater potential for South Warwickshire to accommodate strategic B8 growth, including in the M40 corridor, is supported. Expanding the distribution of such development in this manner, rather than solely replicating past patterns, is appropriate.