Five-year housing land supply position statement (as at 01 April 2023)
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 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 2023) 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 (November 2023) 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 land supply. This approach is frequently used by local planning authorities when publishing their own position statements and was robustly defended during the examination of the Council's Local Plan Part 2.
In doing so, this position statement uses the latest available evidence (up to November 2023) to determine the deliverability of sites (as advocated by paragraphs 4 and 7 of the PPG). For example, where it is known that after the April 2023 base date that 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. For consistency, where it is known that planning consents have since lapsed, between 01 April and 01 November 2023, this has also been discounted from the deliverable housing land supply.
The Planning practice guidance on housing and economic land availability assessment and on housing supply and delivery 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 (paragraph 14) details the types of information to be included when detailing such sites, for example:
- 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 October 2023, but builds upon feedback received from developers and agents between 2019 and 2022 which informed the examination of the Council's Local Plan Part 2. Together, 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 (2023-24), with the first housing completions anticipated to occur in the second year (2024-25). 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 (2025-26). 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 on known sites and also feedback received from completed site deliverability questionnaires received between 2019 and 2023.
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, has been 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 has 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 (2025-26) 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 paragraph 7 of the PPG 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.
The NPPF (paragraph 70) 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. This focused on windfall housing delivered since the start of the plan period (April 2023) 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;
- any houses completed on sites previously approved under the Council's former Interim Housing Land Supply Policy - as the Council would no longer be able to rely upon this to bring suitable sites forward following the adoption of the Local Plan Part 2.
In total, a windfall rate average of 92 dwellings per year has been calculated. This figure has then been revised down by 30% (to 68 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.