London Borough of Tower Hamlets Five Year Housing Land Supply and Housing Trajectory Statement
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London Borough of Tower Hamlets Five-Year Housing Land Supply and Housing Trajectory Statement London Borough of Tower Hamlets Five Year Housing Land Supply and Housing Trajectory Statement 1. Introduction 1.1 The government requires local planning authorities to identify and maintain a five year supply of deliverable land for housing. This document sets out the London Borough of Tower Hamlets five-year supply position as of 1 February 2018, covering between 1 April 2017 and 31 March 2022. 1.2 The council is able to demonstrate a deliverable supply of 5.2 years or 21,321 homes over 1 April 2017 to 31 March 2022. This is a surplus of 744 homes when compared to the overall housing requirement of 20,578 homes. The assessment assumes that past under or over delivery would be addressed within the next five years of the plan and includes an additional 5% buffer requirement. 1.3 Assessed in conjunction with the five-year housing supply, chapter 7 of this document sets out the borough’s fifteen-year housing trajectory for the Local Plan period (2016-2031) which includes a total projected housing supply of 54,543 new homes. 1.4 This statement is an update of the statement published in October 2017 and has been produced to support the submission of the Tower Hamlets Local Plan and to reflect the most recent information available. This further endorses the approach set out in the housing delivery strategy which anticipates that housing output would be increased. Note that the housing figures set out in the Tower Hamlets Local Plan and Infrastructure Delivery Plan will remain the same as those published at the regulation 19 stage. 2. National policy requirement 2.1 Paragraph 47 of the National Planning Policy Framework (NPPF) requires local planning authorities to identify and update annually a supply of specific “deliverable” housing sites sufficient to provide five years’ worth of housing supply against their housing requirement - together with an additional buffer requirement of 5% or 20% where there has been a record of persistent under delivery of housing (moved forward from later in the plan period). 2.2 Paragraph 49 of the NPPF is clear that where the local planning authority cannot demonstrate a five year supply of deliverable housing sites, relevant policies for the supply of housing should not be considered “up to date” – for decision taking, this means, development proposals for housing should be approved unless doing so would significantly and demonstrably outweigh the benefits or specific policies in the NPPF indicate development should be restricted. 2.3 For the purpose of this document, Tower Hamlets’ five year supply requirement is derived from the current London Plan (Greater London Authority, 2016). 1 London Borough of Tower Hamlets Five-Year Housing Land Supply and Housing Trajectory Statement 3. London Plan housing requirement 3.1 The current London Plan (2016) identifies a minimum housing target of 39,314 homes (equivalent to 3,931 homes per annum) for the London Borough of Tower Hamlets between 1 April 2015 and 31 March 20251. This target includes additional homes provided by development and redevelopment of residential and non-residential properties, long term vacant properties brought back into use and non-self-contained accommodations (including accommodations for students, older people, hostels and homes for multiple occupation). 3.2 Between 1 April 2015 and 31 March 2017, a total of 7,919 additional homes have been delivered in Tower Hamlets (included 417 units for student accommodation2). This is equivalent to a surplus of 57 homes since the start of the London Plan period. 4. Tower Hamlets’ five year housing land supply requirement Dealing with past delivery 4.1 The London Plan (2016) is clear that the identified housing target takes into account both past and anticipated housing delivery (including any shortfalls) up to 31 March 20153. Therefore, the housing target for Tower Hamlets is effectively “reset” for the new plan period, starting at 1 April 2015 and it will not be necessary for the Council to consider housing targets prior to that date (from London Plan 2011). 4.2 Therefore, for the purposes of this document, the council has included the surplus of 57 homes as part of the five year supply requirement (over the period 1 April 2017 – 31 March 2022). NPPF buffer requirement 4.3 Paragraph 47 of the NPPF requires an additional buffer requirement of 5% to ensure choice and completion in the market for land, but a 20% where there is a record of persistent under delivery of housing. 4.4 We have considered our performance over the past five years (see table 1 below). Although the council fell short the target in two non-consecutive years of the previous five years, overall, we exceeded the housing target by 417 homes. It is considered that this does not constitute a record of persistent under delivery in regards to paragraph 47 of the NPPF and guidance from the Planning Policy Guidance in the context of Tower Hamlets4. 1 The London Plan (Mayor of London, 2016) - table 3.1 2 London Borough of Tower Hamlets: planning application reference - PA/10/01481 3 Paragraph 3.16b of the London Plan 4 Planning Practice Guidance: reference ID: 3-035-20140306 2 London Borough of Tower Hamlets Five-Year Housing Land Supply and Housing Trajectory Statement Table 1 – Performance against targets over last five years Housing Performance against Housing targets completions targets 2012/13 3,062 2,503 559 London Plan 2013/14 2,285 2,503 -218 2011* 2014/15 2,522 2,503 19 London Plan 2015/16 3,121 3,931 -810 2015 ** 2016/17 4,798 3,931 867 Source: London Borough of Tower Hamlets and London Development Database * All figures for 2011/12 to 2014/15 exclude non-self-contained units. ** All figures for 2015-16 and 2016-17 include non-self-contained units. Housing completions for these years are based on LDD data given its increased reliability. As a result, the 2015/16 reporting year includes the previously published figure of 3,634 (April 2016) assessed against completions data set out in the London Development Database in order to avoid double counting of units. This has reduced the completions figure in 2015/16 to 3,121. 4.5 The current housing target for Tower Hamlets (in the period between 2015 and 2025) is based upon development capacity identified through the London Strategic Housing Land Availability Assessment (SHLAA)5, although it is important to note that this target will decrease to 3,511 homes per annum as a result of the GLA’s 2017 SHLAA, which was published alongside the new London Plan in November 2017. Until the new London Plan is adopted, the current target will be used for all housing supply assessment. 4.6 A significant proportion of the intended housing supply for Tower Hamlets is from large, strategic brownfield sites. While it is envisage that these sites would make a significant contribution towards meeting the identified target within the 10-year plan period, the development of these sites are often complex, and would require a reasonable amount of time. This can include time required for site master planning, completion of section 106 legal agreements, securing necessary infrastructure and affordable housing contribution prior to commencement of development. This, together with the tendency for housing developments (i.e. flats and other high density developments) in Tower Hamlets to be delivered in phases means there is potential for housing delivery to be “lumpy”6 and for the annual average target to be missed in some years of the plan (with delivery higher than the target in some years, and below the target in others). 4.7 Based on the above, it is the council’s view that only a 5% buffer should be applied to Tower Hamlet’s five-year housing supply requirement for the purpose of this document. Applying a 5% buffer to the five-year target, taking into account the current surplus of homes (57 homes), Tower Hamlets has a total five-year housing land supply requirement of 20,578 homes over 1 April 2017 and 31 March 2022. 5 London Strategic Housing Land Availability Assessment 2013 (GLA, 2014) 6 The Mayor of London recognises that there is potential for housing supply in some boroughs to be “lumpy” due to the phasing of key large sites and evitable economic changes – see paragraph 1.1.37 of the London Housing Supplementary Planning Guidance (GLA, March 2016) 3 London Borough of Tower Hamlets Five-Year Housing Land Supply and Housing Trajectory Statement Table 2 – Five year supply requirement London Borough of Tower Hamlets A. Homes required over the London Plan period 39,314 (1 April 2015 – 31 March 2025) B. Annual average requirement over period 3,931 (1 April 2015 – 31 March 2025) C. Homes completed so far 7,919 (1 April 2015 – 31 March 2017) D. Delivery shortfall/surplus to date +57 (1 April 2015 – 31 March 2017) E. Homes remaining to be provided 31,395 (1 April 2017 – 31 March 2025) F. Number of remaining years 8 years (1 April 2017 – 31 March 2025) G. 5-year supply requirement excl. buffer 19,598 (1 April 2017 – 31 March 2022) H. 5-year supply requirement incl. 5% buffer 20,578 (1 April 2017 – 31 March 2022) Source: LBTH Planning 5. Tower Hamlets’ deliverable housing land supply Definition of “deliverable supply” 5.1 Footnote 11 of the National Planning Policy Framework states: “To be considered deliverable, sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular that development of this site is viable.