Five-year housing land supply position statement (as at 01 April 2022)
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 2022) 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 (October 2022) 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 October 2022) 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 2022 base date 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 on major developments, between 01 April and 01 October 2020, this has also been discounted from the 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 September 2022, but builds upon feedback received from developers and agents between 2019 and 2021 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 (2022-23), with the first housing completions anticipated to occur in the second year (2023-24). 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 (2024-25). 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 2022. This has generated the following build out rate assumptions for developments in the borough:
- 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 22 dwellings per year, per site
- large developments (over 150 dwellings) - maximum of 58 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, and consistent with the recommendations of the planning inspector during the examination of the Local Plan Part 2.
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 (2024-25) 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.
The Council undertook a comprehensive analysis of potential windfall to support the examination of the Local Plan Part 2. This focused on housing delivered since 2010 and excluded:
- any houses completed on allocated sites (and from 2013-14 onwards)
- those houses delivered 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, the Council calculated a windfall rate of 99 dwellings per year. In accepting the method and calculated figure, the examining planning inspector concluded that it reflected an appropriately restrained and justified approach, and continues to be applied within this updated position statement.
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.