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South Somerset District Council Five-Year Housing Land Supply Paper (July 2016)

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South Somerset District Council Five-Year Housing Land Supply Paper (July 2016) South Somerset District Council Five-Year Housing Land Supply Paper (July 2016) 1. Introduction 1.1. This report sets out the latest five-year housing land supply position for South Somerset District Council (SSDC). Information and evidence is accurate up to and including the 31st March 2016, and sets out the supply position for the five-year period starting at 1st April 2016 and ending on the 31st March 2021. 1.2. This report represents a progression of the supply position since the previous report published in September 2015. 1.3. The Council recognises that the five-year housing land supply position should be updated annually; but is also mindful that the information in these reports only ever represents a ‘snap-shot’ in time. The five-year housing land supply position is volatile and constantly subject to change. Every house built, each planning permission granted, and every major change to the delivery timetable for a housing site affects the five-year housing land supply position. As such, the five-year housing land supply position will be regularly monitored and updated to ensure that significant changes in circumstances are captured and publicised. 2. Background and Context National policy 2.1. The National Planning Policy Framework (NPPF) (2012) requires that local planning authorities (LPAs) should use their evidence base to ensure that their local plan meets the full, objectively assessed needs for market and affordable housing in the housing market area. 2.2. The NPPF requires LPAs to identify and update annually a supply of specific deliverable sites sufficient to provide five years’ worth of housing against their housing requirements. To this figure an additional buffer of 5% (moved forward from later in the plan period) should be added, to ensure choice and competition in the market for land. 2.3. If, and where, there has been a record of persistent under delivery of housing, the NPPF requires LPAs to increase the buffer to 20% (moved forward from later in the plan period) to provide a realistic prospect of achieving the planned supply and to ensure choice and competition in the market for land. 2.4. The National Planning Practice Guidance (NPPG) (March 2014) reiterates the importance of identifying a supply of deliverable sites to provide five years’ worth of housing against housing requirements. 1 2.5. The NPPG also provides a starting point for formulating the five-year HLS, clarifying that: “Housing requirement figures in up-to-date adopted Local Plans should be used as the starting point for calculating the five year supply. Considerable weight should be given to the housing requirement figures in adopted Local Plans, which have successfully passed through the examination process, unless significant new evidence comes to light”. Local policy 2.6. The Council adopted the South Somerset Local Plan (2006 – 2028) in March 2015. The adoption of the plan is important context as it represents the conclusion of the plan-making process and therefore confirms South Somerset’s housing requirement. 2.7. The local plan sets out a housing requirement of 15,950 dwellings to be delivered over the 22 year period. This equates to an annualised average of 725 dwellings per annum. 3. Determining the Five-year Housing Requirement Overview 3.1. Given the status of the local plan, the starting point for calculating the five-year housing land supply position is the housing requirement set out in Policy SS5 of the local plan. 3.2. In order to reach a conclusion on whether or not the Council can currently demonstrate a five- year supply of housing land, the following component parts need to be examined: What is the basic annual housing requirement; What is the five-year basic housing requirement; What are the net housing completions since the start of the local plan in 2006; Has there been any shortfall or overprovision against the local plan target; How should any shortfall be addressed; Does the Council have a track record of ‘persistent under delivery’; What is the appropriate buffer which should be added to provide choice and competition in the market for land; and How the buffer should be applied to the basic five-year housing requirement figure and the shortfall in housing delivery. 2 What is the basic annual housing requirement? 3.3. The NPPG is clear that adopted local plans should serve as the starting point for calculating the five-year housing land supply position. Given the South Somerset Local Plan (2006 – 2028) was only adopted in March 2015, the housing requirement figure in the plan provides the starting point for any calculation. 3.4. The basic housing requirement figures are therefore the: overall housing requirement between 2006 and 2028, which is 15,950 dwellings; and annualised housing requirement, which is 725 dwellings per annum (15,950 divided by 22 years). What is the five-year basic housing requirement? 3.5. As such, determining the five-year basic housing requirement is a straightforward calculation, multiplying the annual requirement over a five-year period. This equals: 725 x 5 = 3,625 dwellings. What are the housing completions since the start of the local plan? 3.6. In order to ensure that the identified housing need is being met, and to understand whether the local plan is ‘on track’ to deliver the agreed scale of growth, it is necessary to analyse housing provision over the local plan period. The level of completions in South Somerset since 2006 is set out in Table 1 below. Table 1: South Somerset District Council – Net Housing Completions (2006/2007 – 2015/2016) 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Total / / / / / / / / / / 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Local Plan 725 725 725 725 725 725 725 725 725 725 7250 Target Completions 620 724 547 482 984 480 528 511 770 606 6252 (net) Progress -105 -1 -178 -243 259 -245 -197 -214 45 -119 Against Target Per Annum Cumulative -105 -106 -284 -527 -268 -513 -710 -924 -879 -998 -998 Shortfall 3.7. Numbers of completions recorded are slightly different to those previously publicised in September 2015. The reason for this is that a comprehensive review of completions has taken place, where the information held in the Council’s databases has been re-assessed and a more rigorous judgement on net completions has occurred. Some discrepancies between gross and net dwelling numbers have now been removed. 3.8. It is promising that for the period April 2014 to March 2015 the recorded net completions have recovered to the extent that they have exceeded the annualised requirement. This is a positive change within the local housing market, and can to some degree be attributed to the certainty provided by the adopted status of the local plan. 3 3.9. Further analysis of housing completion data over this period provides the opportunity to answer two important questions. First, what is the level of any shortfall or over-provision since the start of the plan period? And, second, whether or not there has been a track record of persistent under delivery? 3.10. Confirming the answers to both questions has implications for how the final calculation of South Somerset’s five-year housing land supply position will be reached. Each of these issues is discussed in turn below. Has there been any shortfall or over-provision in housing delivery? 3.11. Analysing the level of net housing completions against the intended housing delivery target shows that there has been a shortfall in terms of meeting the housing target since 2006. The current shortfall in terms of what the local plan should have delivered versus what has been delivered is 998 dwellings. How should any shortfall be addressed? 3.12. Neither the NPPF nor the NPPG set out a clear methodology for how the shortfall be addressed. However, the consensus of opinion and legal precedent indicates that LPAs should use what is known as the “Sedgefield” method for addressing the shortfall. This would mean that the shortfall is addressed in the next five years of the plan period. This is in contrast to the method of apportioning the shortfall over the remainder of the plan period (known as the “Liverpool” method). 3.13. Adopting the “Sedgefield” method would mean that the entirety of the current shortfall is added to the five-year basic housing requirement figure. As such, the revised requirements would be: 3,625 plus 998, which equals 4,623 dwellings. Does the Council have a track record of ‘persistent under delivery’? 3.14. Looking back at net housing completions in Table 1 shows that the annualised housing requirement target has only been reached in two out of the last ten years (albeit in one further year the discrepancy is merely one dwelling). The impact therefore of the recession years, from 2008, which impacted upon developers’ appetite to build, apply for planning permission and ability to borrow money to build endures; and adds a backlog to what is already a challenging target over the next five years. 3.15. According to best practice, a review of planning appeal decision letters, and legal precedent, this track record would represent ‘persistent under delivery’. The Council is mindful that it does not build houses, and therefore under-delivery is also a symptom of the performance of the development industry and other market indicators than the sole responsibility of the LPA. What is the appropriate buffer to be added? 3.16. Given that the Council’s track record represents ‘persistent under delivery’, according to Paragraph 47 of the NPPF, the Council is required to increase the level of buffer that is applied to the five-year housing land supply position.
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