That there is a need for more genuinely affordable housing in the South Hams is not in dispute. But as Policy TTV25 of our Joint Local Plan makes clear, ‘the JLP does not identify sites for development in Sustainable Villages.’

Instead the Local Planning Authority supports the preparation of Neighbourhood Plans and leaves it to the Neighbourhood Plans themselves to determine which sites to bring forward.

And significantly many of those Neighbourhood Plans, such as those for Aveton Gifford, Bigbury, Brixton, Dartmouth, Kingsbridge, Kingston, Malborough, Newton & Noss, Ringmore, Salcombe, South Huish, Stoke Fleming, Strete, Thurlestone and Ugborough, undertook and included a Housing Needs Survey as part of their evidence base.

Residents in each of those areas were asked about their current and future housing requirements, so establishing how many homes would need to be planned for and to identify where best they could be built.

Yet according to a report presented to councillors at a meeting of the District Council’s Executive on 6 June ‘The Council recognises that traditional housing needs surveys are only a snapshot of the situation, based on various opinions at a point in time. Furthermore, they can be divisive, and the methodology relied upon does not always reflect the need or the content of other nationally recognised data sources.

‘Instead, officers have created the Parish Profile – a broader basket of data and information. This easily digestible, short document provides information from secondary data for use by developers, Registered Providers (RP’s) and Members on a defined parish.’

Extolling their virtues Council Leader Julian Brazil said: ‘I would challenge anyone who lives in the South Hams to find anywhere in the South Hams where there’s not a housing need. And so why are we spending a lot of time and money doing these housing needs surveys when all they do is confirm what we know already?

‘We have had examples where people use the housing needs survey to basically act like a nimby and say we don’t need anything. What they mean is I don’t need anything and I don’t want anybody else moving in to the beautiful area where I live, which I don’t think is helpful, and it also starts contention. I think if we just have a factual sheet like this, there it is, can’t argue with it…’

In his opinion Housing Needs Surveys are being used to block the development of affordable housing and should be replaced by Parish Profiles, a two-page document detailing the number of bids received by Devon Home Choice for affordable housing in the parish; the number of second homes, holiday lets and AirBnBs sourced from Council Tax records; average property prices taken from Land Registry data and average rental prices from Rightmove; while the number of bedrooms per property and the occupancy ratings for bedrooms, along with some further data, has been derived from the Census.

Leaving aside the fact that many of those who spent many hours producing their Neighbourhood Plans would take issue with Cllr Brazil’s dismissal of their efforts, it’s also worth noting that when a Neighbourhood Plan and its supporting documents are first submitted to the Local Planning Authority, the Authority has the responsibility for checking the Plan has properly followed the legal process, including the legal requirements for consultation. And, at this point, the local planning authority can propose changes to the Neighbourhood Plan.

In other words, were the LPA were to consider the submitted Plan was failing to properly address the affordable housing need, the LPA is in a position to ensure that it does. And, should it fail to do so, the LPA has nobody to blame but themselves.

Instead, as Cllr Brazil told members, quoting the Devon Home Choice numbers from the Salcombe Parish Profile: ‘Average bids for a two-bedroom house in Salcombe, average bids 45, I think that shows a housing need in that area. I don’t think you need to go out and ask people if there’s a housing need, that says it.’

He went on to say: ‘I think housing needs surveys are history. I think we need to move on and be more sophisticated about how we actually make decisions to decide where we want plots to be developed.’

As developers are being encouraged to make use of Parish Profiles, and that they could be used to justify development in places where no need has previously been identified, it’s obviously crucial the ‘evidence’ they provide is conclusive. There is also the question of whether they will actually ensure we get the genuinely affordable housing we need.

And on both counts the answer is almost certainly ‘No’.

For example, the Devon Home Choice data only details the total number of ‘bids’ received, and as presumably there is no limit to the number of bids anyone registered with Devon Home Choice can make there is no way of telling either the number of individuals in need of affordable housing or, of those, how many actually need to live within the parish. It should be important to differentiate between those who ‘need to’ and those who would ‘like to’.

Similarly data taken from the 2021 Census is already three years out of date, and cannot be updated until 2031. Nor are the average property prices any more reliable. Green Party Councillor Jacqi Hodgson made the point that the ‘average’ property price in Staverton of £1.6m was based on a single sale. The information about the primary school was also inaccurate.

Fortunately the Council’s executive lead for Housing, Cllr Denise O’Callaghan, has since confirmed to the Society that ‘Devon Home Choice cannot be used in isolation to determine need’ and that Parish Profiles will not be used in isolation to support planning applications.

Instead, she added, ‘on a case-by-case basis, dependant on the evidence of need, we will create a bespoke process working with the community to further understand the need in a particular location. This will not be a custom process as each community is different. A ‘drop in and talk to us’ event may not work as well as a tailored light touch ‘Survey’ aimed at those on the Housing Register. In some areas a drop in event has proven to be very positive. South Hams District Council will work alongside the parish council to ensure that all members of the community have had the option to express their opinion and needs.’

All of which is very welcome, in particular the commitment to work alongside parish councils to ensure all members of the community have had the option to express their opinion and needs, even if some might argue they had that opportunity when their housing needs survey was undertaken.

Yet the fact remains that unless our Joint Local Plan is amended Parish Profiles will not deliver the genuinely affordable housing we need, and may well be exploited by developers when appealing any refusal. Even though JLP Policies TTV25 and TTV27 are relevant to ensure we secure more than 30% Affordable Housing on a development site, Policy TTV27 fails to require ‘affordable housing’ to be genuinely affordable.

According to TTV27.1 11.65 the ‘policy uses the same definitions for affordable housing as taken from the NPPF, which includes discount open market housing, as long as it is secured in the form of a s106 requirement that restricts open market values to no more than 80 per cent of the open market average’, while TTV27.2 11.69 goes on to say that: ’40 per cent is the maximum permissible amount of open market housing, both in terms of the number of units, and site area, and is not the default threshold.’

So in theory an application for five houses could be policy compliant were two to be offered for sale at the full open-market price and the remaining three at a discount of 20% to the open-market price. According to the Land Registry the average house price in the South Hams in May 2024 was £377,000. Even with 20% off, that’s still more than £300,000!

However in practice matters may not be quite so bad as TTV27.2 11.69 continues: ‘the proportion of tenures within the affordable housing offer needs to comply with the most up-to-date needs figures held by the relevant LPA. A proposal that only seeks to deliver discount open market housing will be resisted where there is evidence of need for alternative tenures.’

Nonetheless TTV27 makes such an outcome entirely possible. It also means that although some of the affordable tenures may be genuinely affordable, as it stands we will still have to countenance many that are not and accept a noticeable number of additional open market properties, particularly within protected landscapes.

And it is also pertinent that TTV27 11.62 additionally: ‘provides the basis for bringing forward proposals that are an exception to adopted policy providing that they are demonstrably Affordable Housing-led. This policy may be applied to proposals of any scale, including single dwellings.’

So even though Cllr O’Callghan offered the reassurance ‘the Council will use TTV25 and TTV 27 when recommending a planning decision’ and ‘that need must be evidenced to support a development coming forward under these policies’, the danger is that developers will exploit Parish Profiles to evidence that need and then, should their application be refused, use that fact in conjunction with the Council having declared a housing crisis as the basis on which to appeal.

Disingenuously Parish Profiles are now being presented on the Council’s website as ‘Housing Needs Survey Results’. You can find them here: https://www.southhams.gov.uk/housing/housing-needs-survey-results. Arguably this is far from honest.

And, before Cllr Brazil continues with his desire to ignore the findings of actual Housing Needs Surveys and replace them as a material consideration with evidentially inadequate Parish Profiles he might first like to amend the JLP to ensure that the affordable housing we need is genuinely affordable.

Otherwise he runs the not inconsiderable risk of encouraging yet more unaffordable executive-style open-market properties being plastered around our countryside, without really doing anything to solve our housing crisis.