Policy SS1 of the draft Local Plan identifies a target to deliver 12,800 homes over the plan period or 640 per annum. This responds to the objectively assessed need for 532 homes per annum identified in the Leicester and Leicestershire HEDNA, January 2017 with an allowance for 25 homes per annum to address the needs of employees at Magna Park and a contingency of 15% (or 83 homes per annum).

It is therefore necessary to consider each of these three elements to reach a conclusion on the housing requirement. The overall approach of the HEDNA broadly reflects the approach advocated in the NPPG. However, a number of the specific assumptions would either benefit from clarification or are not supported as described below:
1) Table 1 identifies that the population growth of the HMA was consistently under-estimated during the intercensal years, owing to unattributable population change (UPC). This is broadly recognized as being attributable to two factors, namely a potential misenumeration in one or other of the Census's (with either the 2001 Census under-estimating the actual population or the 2011 Census over-estimating the actual population) or an error in the estimated migration flows during the intervening years. It is impossible to attribute the UPC to one or the other of these factors, and so a large number of consultants preparing HEDNA's (including Neil McDonald who is quoted as a reliable source within the HEDNA) assume that 50% of the UPC is attributable to each factor. Such an approach has also been supported by numerous Local Plan Inspectors (including Inspector Pratt at the Stroud Local Plan examination). If such an approach was applied in Leicestershire, then this would uplift the population growth across the HMA by circa 742 people per year. However, the current approach of the HEDNA is equivalent to assuming that 100% of the UPC is attributable to errors within one of the Census's without any justification in support of this.
2) In paragraph 2.26, a number of sensitivity tests are identified. The first relates to rebasing the projection to 2015 and the second relates to applying a longer term migration trend. It is however, unclear whether the second sensitivity test also rebases the projection to 2015, which is required in order to align with the most recent evidence as required by the NPPG (2a-017).
3) Paragraph 4.48 identifies that the HEDNA has assumed the economic growth which occurred between 2011-15 and then projected forward the economic need from 2015 onwards. This in effect assumes that the objectively assessed need was met in full over the period 2011-15, which is clearly not the case given that the Council acknowledge that they have a record of persistent under delivery (as set out in the 5 Year Housing Land Supply Position Statement 2016/17). Any shortfall which arose during this period should therefore be added to the identified objectively assessed need across the plan period.
4) In paragraph 5.15, it is identified that changes are made to the commuting rates identified by the 2011 Census. However, the HEDNA does not identify which source (if any) the data comes from to make such an adjustment. It only alludes to "published data on jobs and population growth". This cannot be relied upon without the necessary reference as it is not justified in any way. Furthermore, data on jobs and population growth does not provide the necessary information about how those people and jobs interact through commuting. The only publicly available information on commuting rates is taken from the Census and this has the added advantage of being comprehensive as all households are legally required to submit returns. It would be virtually impossible to justify any adjustment from the comprehensive and robust figures provided by the Census in the absence of a comprehensive collection of primary data such as a survey with a high response rate (i.e. a new local Census).
5) In paragraphs 5.18 to 5.32, various sources for the employment rates are considered. It is identified that the OBR rates take account of the participation rates of different cohorts. These cohort-specific participation rates are a key determinant of the likely future workforce owing to the significant variance in participation of various cohorts (for example, a 16 or 64 year old is far less likely to be in full time employment than a 45 year old). The OBR rates also estimate the impacts of specific policy factors such as the change to retirement ages. These therefore provide robust and credible rates as relied upon by the Government. However, the HEDNA dismisses these and instead relies upon Experian rates which simply assume 80% participation without any justification and without taking any account of the participation rates of different cohorts, all of which is inconsistent with the Government's analysis (prepared by the OBR). Such an assumption relies upon a fundamental change in participation rates across all cohorts. In particular this requires that older people continue to work for a far longer period, regardless of their health and their ability to undertake more manual tasks. This departure from current rates is clearly a policy-on adjustment which should not be used to inform the objectively assessed need.

The preceding analysis suggests that the objectively assessed need of 532 homes per annum, identified by the Council is not robust and that it should be increased. Indeed, the DCLG have recently published the "Planning for the right homes in the right place" consultation which suggests that the objectively assessed need for Harborough should be 540 homes per annum. Whilst this is subject to consultation and as such it should not be afforded significant weight, this provides an indication of the Government's position on the objectively assessed need.

The Council have then identified a policy-on uplift to meet the needs of the employees of Magna Park. This is to be welcomed as it ensures that the employment development will be able to operate sustainably.

The Council then include a contingency of 15%. This contingency is identified to address the unmet needs of neighbouring authorities, to ensure that the objectively assessed need is delivered, and to provide choice and flexibility to the market as set out in paragraph 5.1.10 of the draft Local Plan.

The unmet needs of neighbouring authorities is unknown at present, although a final Memorandum of Understanding is due to be published in January 2018 which will detail the distribution across the authorities. This will be necessary to demonstrate that the duty to cooperate has been met. Pegasus Group therefore reserve the right to make further representations once this is available.

However, in the interim, the Emerging Options consultation for Leicester City identifies a housing requirement which produces a shortfall of between 7,900 and 15,000 homes (or 395 to 750 per annum). These unmet needs of Leicester City are likely to be most sustainably met within the authorities which neighbour the City, namely Blaby, Oadby & Wigston, Harborough and Charnwood. If as a broad proxy it was assumed that each of these were required to meet a quarter of the unmet needs of Leicester City, this would produce an additional requirement for 99 to 188 homes per annum in each authority. This compares to the contingency of 83 homes per annum identified in the draft Local Plan, which is also required to provide flexibility and to ensure that the objectively assessed need is provided for. This alone (although based on a very crude distribution) suggests that the housing requirement proposed in the draft Local Plan will be insufficient to meet the identified objectively assessed needs (which in themselves are under-estimated) and the unmet needs of Leicester City across the HMA.

However, the proposed housing requirement is supposed to fulfil these requirements as well as provide contingency to ensure delivery and provide choice and flexibility to the market. Whilst both of these objectives are supported, it is clear from the preceding analysis that the proposed housing requirement provides absolutely no contingency (or at the very best a much reduced contingency) once the objectively assessed needs are robustly determined and an appropriate allowance for the unmet needs of Leicester City is included. The result of this is that the housing requirement of the Local Plan is unlikely to be delivered and that there is no additional choice and flexibility available to the market.