Five-year housing land supply position statement (as at 01 April 2024)
Executive summary
This statement presents Great Yarmouth Borough Council's housing land supply position as of 31 March 2024, for the period between 01 April 2024 and 31 March 2029.
The Council is able to demonstrate a 5.82 year supply of deliverable land for housing through this statement.
Position statement methodology
The National Planning Policy Framework (2024) (opens new window) requires all local planning authorities to identify and update annually a rolling five-year supply of housing land. Whether a five-year housing supply does or doesn't exist is an important material consideration when determining planning applications for new housing.
The position statement explains the approach and method undertaken. It is made up of three component parts:
- Calculating the five-year housing land supply requirement
- Identifying and assessing deliverable sites to inform the housing land supply
- Calculation of the five-year housing land supply position
The Borough Council did not initially prepare a five-year housing land supply position statement to cover the period between 1 April 2024 and 31 March 2029. Paragraph 90 (since revoked) of the December 2023 NPPF did not require Local Authorities to identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years' worth of housing if their adopted plan is less than five-years old and it identified at least a five-year supply at the time the examination concluded. Given that the Borough Council demonstrated a five-year supply of housing land upon adoption of the Local Plan Part 2 on 9 December 2021 (and revised the housing target as explained in section 3 of this report), the borough council was not therefore previously required to prepare a position statement.
However, the December 2024 NPPF (opens new window) removed this exemption and reinstated the requirement for Local Authorities to identify and update annually a supply of specific deliverable sites. The Borough Council has therefore published its annual five-year housing land supply position statement in accordance with the latest NPPF.
Calculating the five-year housing land supply requirement
The Council's approach to calculating the housing requirement, which the five-year housing land supply will be measured against, involves the following stages:
- determining the base housing requirement
- assessing the scale of any past underdelivery or overdelivery
- determining an appropriate housing supply buffer
- calculating the five-year housing land supply requirement
Determining the base housing requirement
The planning practice guidance (PPG) is clear that housing requirement figures identified in strategic housing policies should be used for calculating the five-year housing land supply where a plan was adopted in the last five years (see PPG paragraph 005 (opens new window)), otherwise the housing requirement will need to be measured against the area's local housing need (LHN), calculated using the 'standard method'.
The Council's strategic housing policies are included in the adopted development plan which comprises the Local Plan Part 1 (Core Strategy) (opens new window) and Local Plan Part 2 (opens new window). The Local Plan Part 2 is the most recently adopted plan (09 December 2021) and amends the Core Strategy housing target through Policy UCS3 (opens new window). This policy readjusted the overall housing requirement down to 5,303 dwellings (previously 7,140 dwellings) over the plan period (2013 to 2030), setting an annualised housing requirement (between 2019 to 2030) at 363 per year. For the purposes of this position statement, the base housing requirement is taken as 363 per year.
Assessing the scale of any past underdelivery or overdelivery
Paragraph 22 of the PPG (opens new window) states that any shortfall against a housing target in an adopted plan should be added to the plan's housing requirement over the next five years. Alternatively, where areas deliver more completions than required, the additional supply can be used to offset any shortfall against requirements from previous years.
Policy UCS3 (opens new window) sets the plan's housing target base date from April 2019, therefore delivery between the years 2019-2020, 2020-21, 2021-22, 2022-23 and 2023-24 needs to be considered to identify any potential shortfall. To date (April 2019 to March 2024), 1,868 dwellings have been completed against a requirement of 1,815 resulting in a surplus of 53 dwellings accrued since April 2019. This 'overdelivery' has been deducted from the plan's requirement over the next five years.
Determining an appropriate housing supply buffer
The National Planning Policy Framework (2024) (opens new window) (Paragraph 78) requires local planning authorities to apply an additional buffer of 5% or 20% to ensure choice and competition, or where there has been a significant underdelivery of housing, as measured against the Housing Delivery Test (HDT).
In December 2024 the Government published its most recently announced HDT results which demonstrated that the Council's housing delivery over the preceding three years (2020-21, 2021-2022, 2022-23) was 118% (accounting for corrections to the number of homes delivered and required to align with the annual average housing requirement and dwelling completions). This is beyond the 85% threshold whereby an automatic 20% buffer is applied through national policy; therefore the Council is only required by national policy to apply a 5% buffer to the housing requirement.
Calculating the five-year housing land supply requirement
The five-year housing land supply requirement is therefore calculated as being 1,850 new homes between April 2024 and March 2029. This is inclusive of the required 5% housing buffer. This calculation is set out in Table 1 below:
Calculation codes | Five-year housing land supply component | Number of dwellings |
---|---|---|
A | Five-year housing supply target (5 times 363) | 1,815 |
B | Housing surplus | 53 |
C | 5% buffer ((A minus B) times 5%) | 88 (rounded) |
D | Total five-year supply target ((A minus B) plus C) | 1,850 |
Identifying and assessing deliverable sites to inform the housing land supply
The NPPF sets out the requirements for sites that may be included within the five-year supply.
It states that for a site to be considered within the five-year supply it must:
- be 'deliverable' (NPPF (opens new window) Annex 2) which means it must be available for development now
- offer a suitable location for development now
- be achievable with a realistic prospect that housing would be delivered on the site within five years
As a starting point, the beginning of the current financial year (01 April 2024) has been used as the base date to determine which deliverable sites may be included within the housing land supply. Using the beginning of a financial year is not a requirement of national policy but is consistent with the Council's previous five-year housing land supply statements, and its annual monitoring mechanisms.
The publication of this position statement (December 2024) after the base date is due to the time needed to sufficiently gather, analyse, and interpret the most up-to-date deliverability information to inform the housing supply. This approach is frequently used by local planning authorities when publishing their own position statement and was robustly defended during the examination of the Council's most recently adopted Local Plan. The delay in publication is also a result of the revisions to the NPPF that require this statement to be published (as outlined within the introduction to this statement).
In doing so, this position statement uses the latest available evidence (up to 12 December 2024) to determine the deliverability of sites (as advocated by the PPG (opens new window)). For example, where it is known that after the April 2024 base date a reserved matters have since been consented on an outline permission or a decision notice has since been issued on a site which only had a committee resolution to approve planning consent, then this has been taken into account when projecting likely delivery over the next five-years. The calculation also includes sites that have been granted planning consent, or received a committee resolution to approve since the base date. For consistency, where it is known that planning consents have since lapsed, between 1 April 2024 and 12 December 2024, this has also been discounted from the housing supply.
The Planning practice guidance on housing and economic land availability assessment (opens new window) and on housing supply and delivery (opens new window) sets out further guidance on what five-year housing land supply statements need to include and what constitutes a deliverable site, informing the categories listed below.
Sites below ten dwellings/0.5 hectares or which have full planning permission
Sites that do not involve major development (are below 10 dwellings, or less than 0.5 hectares) and have planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within five years.
The Council's starting point for sites which fall within this definition is that they are deliverable. The PPG (opens new window) requires the publication of certain information in relation to such sites as follows:
- details of number of homes under construction and completed each year
- commentary indicating reasons for acceleration or delays to commencement on site or effects on build out rates
- current planning status and record of completions and homes under construction by site
- details of demolitions and planned demolitions
The Council regularly contacts landowners, developers, agents, and other applicants with extant planning consents to understand, for example, site progress, expected build-out rates or the status of any known site developer options. This was most recently updated in November 2024. Combined with an analysis of past deliverability tends, this monitoring intelligence has been used to inform the types of delivery assumptions used, as explained in more detail below.
In circumstances where development has not yet commenced, it has been assumed that for minor sites (under 10 dwellings) construction would start in the first year (2024-25), with the first housing completions anticipated to occur in the second year (2025-26). For major sites (10 dwellings and above), it has been assumed that up to two years would need to pass before the first housing completions are anticipated to occur in the third year (2026-27). Where appropriate, adjustments have also been made to the exact start dates of sites depending on the level and granularity of feedback received from site questionnaires and/or internal officer knowledge and experience.
Where construction has already commenced on sites, likely build out rates have been assumed depending on the size of the site. Build out rates have been informed through an analysis of historic build out rates that was undertaken to inform the 2023 Five-year housing land supply position statement.
To ensure that build-out rate assumptions are not unduly skewed, historic delivery within year one (the year of the first completion), on large sites, was excluded from historic build out rate analysis, unless the first completion occurred within the month of April (the beginning of the monitoring year). Uncompleted large sites with less than three years of data were also excluded from build out rate analysis, as well as the last year of site completions due to the likelihood of annual delivery being skewed by the site completing which would not be representative of typical dwellings per annum.
Medium and small sites were also subject to the same analysis of build out rates, though were not subject to the same exclusions due to the limited number of years over which such sites are typically delivered.
This analysis generated the following build out rate assumptions for developments in the borough, which are broadly consistent with previous built-out rate assumptions used within previous five-year housing land supply statements:
- small developments (up to and including nine dwellings) - maximum of two dwellings per year, per site
- medium developments (between 10 and 150 dwellings) - maximum of 20 dwellings per year, per site
- large developments (over 150 dwellings) - maximum of 66 dwellings per year, per site
The build out rate assumptions above are an initial starting point and may be fine-tuned for specific sites where further housing delivery intelligence has been gathered such as in terms of the likely capacity of a settlement to absorb new sites. Where alternative build out rates have been used, these are considered to be reasonable and achievable where regard has been made to historic housing delivery.
Where outline permission has been granted for sites of less than ten dwellings, the assessment anticipates housing completions occurring no earlier than the third year (2026-27) to take account of the likely time required to secure the reserved matters element of the planning consent.
Sites of ten or more dwellings/0.5 hectares or more with outline permission and allocations
National policy states that where a site has outline planning permission for major development or allocated in an adopted plan it should only be considered as deliverable where there is clear evidence that housing will be completed on the site within five years.
The range of evidence to help demonstrate site deliverability is listed within the PPG (opens new window) and includes:
- current planning status - for example, on larger scale sites with outline or hybrid permission, how much progress has been made towards approving reserved matters, or whether these link to a planning performance agreement that sets out the timescale for approval of reserved matters applications and discharge of conditions
- firm progress being made towards the submission of an application - for example, a written agreement between the local planning authority and the site developer(s) which confirms the developer's delivery intentions and anticipated start and build out rates
- firm progress with site assessment work
- clear relevant information about site viability, ownership constraints or infrastructure provision, such as successful participation in bids for large-scale infrastructure funding or other similar projects
The Council contacted relevant developers, agents, landowners and applicants through the use of a site questionnaire. This was undertaken with a high level of scrutiny, having regard to deliverability intelligence gathered from past completed site questionnaires, and where relevant, deliverability recommendations provided by the planning inspector to confirm the Council's housing land supply in 2021 as part of the adoption of the Local Plan Part 2. Other delivery assumptions used, such as likely site commencement dates and build out rates, are consistent with those listed earlier in this position statement, unless robustly justified intelligence from completed site proformas confirm alternative rates.
Windfalls
The NPPF (opens new window) (paragraph 75) states that an allowance for windfalls may be included in the five-year assessment where there is compelling evidence that they provide a reliable source of supply, having regard to the strategic housing land availability assessment, historic windfall rates and expected future trends.
Windfalls make an important contribution to housing delivery in the borough providing a limited alternative supply of housing, often via certain changes of use, conversions, infill development, permitted development and affordable housing on rural exception sites etc.
An analysis of past windfall completions of the type that would likely continue to be supported by policies in the Great Yarmouth Local Plan has been undertaken and follows on from the general approach which was justified and accepted by Independent Inspector during the examination of the Local Plan Part 2 (opens new window). This focused on windfall housing delivered since the start of the plan period (April 2024) and excluded:
- any housing completed on allocated sites;
- any houses completed on major sites i.e. over ten dwellings, as such major sites would typically form the basis a potential housing allocation
In total, a windfall rate average of 91 dwellings per year has been calculated. This figure has then been revised down by 30% (to 64 windfall dwellings per year) to take in account any potential and unforeseen changes to national policy which might further limit the number of windfalls that may come forward.
To avoid double counting, no contributions from windfalls are identified in the first two years of the supply period, and a 25%, 50% and 100% windfall rate has been ascribed in years 3, 4 and 5 respectively.
Calculation of the five-year housing land supply position
Tables 2 and 3 summarise the sources of supply for the five-year period (2024 to 2029) and the total number of years of deliverable housing land. A full breakdown of each individual site assessed within this position statement can be accessed below:
Sources of supply | 2024-29 | 2025-26 | 2026-27 | 2027-28 | 2028-29 |
---|---|---|---|---|---|
Major sites (sites of 10 or more dwellings, or 0.5ha or more) with full or detailed planning consent | 273 | 276 | 345 | 290 | 71 |
Small sites (sites below 10 dwellings or 0.5ha) with planning consent (full/outline) | 112 | 106 | 49 | 25 | 9 |
Allocations (Local Plan) | 0 | 0 | 0 | 94 | 210 |
Major sites (sites of 10 or more dwellings or 0.5ha or more) with outline planning consent | 0 | 0 | 14 | 80 | 88 |
Windfall | 0 | 0 | 16 | 32 | 64 |
Subtotals | 385 | 382 | 424 | 521 | 442 |
Grand total (2024-25 to 2028-29) | 2,154 |
Calculation codes | Five-year housing land supply component | Number of dwellings |
---|---|---|
A | Five-year supply requirement including 5% buffer | 1,850 |
B | Annual requirement (A divided by 5) | 370 |
C | Total number of units identified | 2,154 |
D | Number of units above or below five-year supply requirement (C minus A) | 304 |
E | Number of years of deliverable housing land (C divided by B) | 5.82 |
Results summary
This position statement has identified sites within the borough of Great Yarmouth that are capable of delivering 2,154 new homes within the next five-year period (April 2024 to March 2029). The target requirement over this period is 1,850 therefore this represents an over provision of 304 new homes.
In conclusion, this statement identifies sites capable of delivering 5.82 years of housing land supply.