Revised Housing Topic Paper (TP3(REV))
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TP3(rev) Plymouth & South West Devon Joint Local Plan Revised Housing Topic Paper (Provision and Supply) January 2018 Note: This Housing Topic Paper (January 2018) relates to updated supply evidence provided by a suite of housing trajectories produced by the JLP Councils that have an end March 2017 Monitoring Point. Those trajectories are the Councils’ response to the request made by the Inspectors for the JLP examination in their letter of 4 September 2017 (EXC2) for March 2017 Monitoring Point trajectories. The end March 2017 Monitoring Point trajectories (TP3F; TP3G, TP3H- and as amalgamated in EXC9) provide the latest evidence and therefore supersede the end March 2016 Monitoring Point trajectories (TP3A; TP3B, TP3C) that were part of the March 2016 Housing Topic Paper (TP3) and the amalgamated EXC3C. They also supersede the reformatted end March 2016 Monitoring Point Trajectories TP3Ai; TP3Bi, TP3Ci) published in October 2017. Plymouth & South West Devon JLP Revised Housing Topic Paper January 2018 Plymouth & South West Devon Joint Local Plan Housing Topic Paper (Provision and Supply) January 2018 CONTENTS Executive summary i Main report 1. Introduction : the purpose of this document and the policy it supports 1 2. Context 7 3. Evidence: SHMA and the Objective Assessment of Housing Need 16 Strategic Housing Market Assessment Plymouth HMA justification Demographic forecasts Market signals Employment forecasts Scenarios 4. The JLP Councils’ consideration of the Objective Assessment of Housing Need – HMA and District Totals 28 5. Converting need to JLP and Policy Area housing provision 32 PPG paragraph 29 Affordable Housing Need Duty to Cooperate – strategic cross boundary issues Total provision Distribution of housing need 6. Policy development – Housing Requirement Targets 53 7. Forecast Housing Supply 55 Housing trajectories – Plan, Monitor, Manage Scale of supply Supply categories 8. Maintaining Supply 85 the Housing Implementation Strategy 5 year housing land supply Flexibility Contingency 9. Affordable Housing – need, supply & provision requirements 98 10. Sustainability Appraisal of housing provision policy 113 11. Housing provision and supply - Tests of Soundness summary 116 i Plymouth & South West Devon JLP Revised Housing Topic Paper January 2018 Appendices Appendix 1 –SHMA process – robustness and quality assurance 1.1 Scenarios - summary statistics – District level data 1.2 2016 Mid year population estimates Appendix 2 – Duty to Cooperate – evidence 2.1 Dartmoor National Park Authority letter regarding DNP ‘allowance’ 2.2 Housing completions in Dartmoor National Park by District Appendix 3 – Distribution of housing need - Compatibility of selected distribution with Vision and Strategic Objective Appendix 4 – Housing trajectories (March 2017 monitoring point) – published separately 4.1 Methodology and evidence 4.2 Illustrative graphs Appendix 5 – Historic annual housing completions Appendix 6 – 5 year housing land supply (5YLS) 6.1 Methodology and evidence 6.2 Rolling 5 YLS graphs (March 2017 monitoring point) 6.3 Maintaining supply in the two Policy Areas Appendix 7 – Sources of Housing Supply (March 2017 monitoring point) 7.1 Delivery from completions 2014-2017 7.2 Delivery from commitments (planning permissions) as at 1 April 2017 7.3 Lapse rates 7.4 Delivery from windfalls 7.5 Delivery from Allocations 7.6 Delivery from Sustainable Villages (Neighbourhood Plans) Allowance 7.7 Delivery from release of HMOs when Student Accommodation is built 7.8 SHLAA disclaimer Appendix 8 - Affordable Housing 8.1 Methodology for forecasting affordable housing supply 8.2 SHMA Part 2 and NPPG paragraphs 21 and 29 Annex 1 Note on 35% affordability threshold) Appendix 9 – How has consultation informed Policy SPT3? Appendix 10 – Compatibility Table – JLP policy & evidence base compared to NPPF Appendix 11 – Lead in times and delivery rates used in the trajectories 11.1 Schedule of agreements with main developers of housing sites 11.2 Evidence on lead in times in South Hams and West Devon ii Plymouth & South West Devon JLP Revised Housing Topic Paper January 2018 Executive summary ES1 Revised Housing Topic Paper (January 2018) (TP3(rev)) is part of the evidence base for the Plymouth and South West Devon Joint Local Plan (JLP). TP3(rev) is the evidence audit trail document which revises Housing Topic Paper (March 2017 – TP3). The latter was based on 2016 Monitoring Point housing trajectories (TP3A/Ai, TP3B/Bi and TP3C/Cii). ES2 After the start of the JLP Examination the Inspectors for the Examination requested that the 2016 Monitoring Point housing trajectories to be updated to the 2017 Monitoring Point. The JLP Councils responded to that request and published the new trajectories on 30 November 2017. Consequently Housing Topic Paper TP3 no longer referred to the latest published information and was not up to date. The JLP Councils concluded that it was necessary to revise TP3 so that it was up to date. ES3 Work to update TP3 was undertaken in December 2017, with TP3(rev) published when the JLP Councils submitted the document to the Examination in early January 2018, before the scheduled Examination hearings. ES4 This document TP3(rev) therefore contains the latest evidence and analysis about housing need and supply in the plan period, and justification of the housing provision policy targets in submission JLP policy SPT3. It also amplifies the analysis and provides greater clarity, partly in response to representations received on the Pre-Submission JLP. ES5 HOUSING NEED: The JLP Councils endorse the conclusions in the Strategic Housing Market Assessment Part 1 (February 2017 HO13) and, for the purposes of National Planning Policy Framework (NPPF) paragraphs 159 and 47, the Councils accept the recommendations relating to: 1. the extent of the Plymouth Housing Market Area, and 2. the Objectively Assessed Need (OAN) relating to housing need in the Plymouth HMA. ES6 The JLP Councils agree with the scale of the uplift for market signals which is included in each District’s OAN. The scale of uplift reflects the different circumstances in each District. The uplifts are necessary because of previous market undersupply relative to demand, and affordability. The uplifts are significant, particularly in the South Hams where affordability is challenging. This is in accordance with current national Planning Practice Guidance (PPG). There is no justification for a further uplift to the OAN regarding undersupply and no ‘backlog’ of need requiring additional policy provision to be made. Moreover, no further uplift is necessary for employment trend reasons because the uplift for market signals already enables sufficient labour supply to be housed within the plan area. ES7 Table 71 replicates the results in SHMA Part 1 Table 19 (HO13) 1 To avoid confusion, all references to tables, graphs and figures in this Executive Summary use the same reference numbers as in the main report of this Housing Topic Paper. i Plymouth & South West Devon JLP Revised Housing Topic Paper January 2018 Table 7 Plymouth HMA OAN 10 year migration trend projections uplifted-Scenario 2 10-year trend Market Signals OAN projections uplift (dwellings) 2014-2034* 2014-2034 Plymouth City 16,561 10% 18,217 South Hams 3,139 25% 3,924 West Devon 4,302 20% 5,162 PLYMOUTH HMA 24,002 27,303 ES8 As well as the overall OAN of 27,300 total for the Plymouth HMA as recommended in SHMA Part 1, the JLP Councils also accept the individual OAN results for the administrative areas of Plymouth City, South Hams District and West Devon Borough Councils. This enables the Councils to understand the need in their areas. ES9 JLP HOUSING PROVISION POLICY TARGET The JLP Councils considered whether the housing requirement target should be higher than the OAN because of affordable housing need. They concluded that there was no evidence to justify a further uplift for any administrative area or Policy Area in the JLP area, or for the JLP plan area for affordable housing need reasons. ES10 There is evidence to justify deducting from the 27,300 Plymouth OAN an allowance of 600 dwellings for that part of the Plymouth HMA which lies within the Dartmoor National Park (DNP). This is justified by supply-side evidence. It avoids double counting and avoids over provision in the HMA that could otherwise undermine the ability of the DNP Authority to plan effectively for its area. This leaves 26,700 dwellings need to be accommodated in JLP area. ES11 There is no evidence to justify the JLP area accommodating housing need arising from other LPAs outside the JLP. So there is no need to add external need when calculating the housing provision policy requirement targets for the JLP. ES12 There is also no evidence to justify accommodating housing need from the Plymouth and South West Devon JLP area outside the JLP area. Sufficient supply has been identified in the JLP area to accommodate the need for the plan period and provide sufficient headroom. ES13 A total JLP area housing provision policy target, expressed as a minimum, of at least 26,700 dwellings in the plan period is therefore justified. ES14 DISTRIBUTION OF THE 26,700 REQUIREMENT IN THE PLAN AREA. Latest evidence in the housing trajectories (TP3E, TP3F and TP3G) demonstrates a housing supply forecast to be delivered in plan period totalling of just over 30,000 dwellings in the JLP plan area. At 3,360 above the 26,700 dwellings JLP area need and minimum requirement, this equates to 12.6% headroom which is sufficient flexibility. However, housing