London Borough of Tower Hamlets Assessment of 5 Year Housing Land Supply, position at April 2016 London Borough of Tower Hamlets Assessment of 5 Year Housing Land Supply, position at April 2016 (Published November 2016) 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 London Borough of Tower Hamlets’ five year supply position as of 1 April 2016. The assessment takes into account known completions at the end of March 2016, with the “five year period” covering between 1 April 2016 and 31 March 2021. 1.2 As at 1 April 2016, the Council is able to demonstrate a deliverable supply of 5.1 years or 21,502 homes over 1 April 2016 to 31 March 2021. The assessment assumes past under delivery would be addressed within the next five years of the plan and includes an additional 5% buffer requirement. 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 proposal 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, March 2015 . 3. London Plan housing requirement 3.1 The current London Plan 2015 was published in March 2015. The plan identified 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 2025 1. 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 HMOs). 3.2 Between 1 April 2015 and 31 March 2016, a total of 3,634 additional homes have been delivered in Tower Hamlets (included 417 units for student accommodation 2). This is equivalent to a shortfall of 297 homes (since the start of the London Plan period). 1 The London Plan, March 2015, Mayor of London, Table 3.1 2 LBTH planning application reference - PA/10/01481 1 London Borough of Tower Hamlets Assessment of 5 Year Housing Land Supply, position at April 2016 4 Tower Hamlets’ five year housing land supply requirement Dealing with past under delivery 4.1 The London Plan 2015 is clear that the identified housing targets takes into account housing backlog and anticipated delivery up to 31 March 2015 3. 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 For the purpose of this document, the Council has included the entire shortfall of 297 homes as part of the five year supply requirement (over the period 1 April 2016 – 31 March 2021). NPPF Buffer requirement 4.2 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. 4.3 At the time of writing, it is acknowledged that the Council fell short the target in three non- consecutive years of the previous five years (see table 1 below). This resulted an under delivery of 600 homes (around 4%) against a target of 13,943 homes (London Plan housing targets 2011 – 2015) over the last five year. 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 PPG in the context of Tower 4 Hamlets Table 1 – Performance against targets over last 5 years Housing completions Housing targets Performance against targets London Plan 2011 2011/12 1,840 2,503 -663 2012/13 3,062 2,503 559 2013/14 2,285 2,503 -218 2014/15 2,522 2,503 19 London Plan 2015 * 2015/16 3,634 3,931 -297 Source: LBTH Building Control; LBTH Planning * Note: figures for 2015-16 includes non-self-contained units 4.4 The current target for Tower Hamlets (period over 2015-25) is based upon development capacity identified through the London Strategic Housing Land Availability Assessment 2013 5. A significant proportion of the intended housing supply for Tower Hamlets is from larger / 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 master planning of site, completing of a Section 106 legal agreement, securing necessary infrastructure and affordable housing contribution before the commencement of development. This, together with the tendency for housing developments (for 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 3 Paragraph3.16b of The London Plan 2015, GLA 4 Planning Practice Guidance, reference ID: 3-035-20140306 5 London Strategic Housing Land Availability Assessment 2013, GLA, published 2014 6 The Mayor 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 – paragraph 1.1.37 of London Housing SPG, March 2016 2 London Borough of Tower Hamlets Assessment of 5 Year Housing Land Supply, position at April 2016 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). 4.5 Based on the above, it is the Council’s view that only a 5% buffer should be applied to Tower Hamlet’s 5 year housing supply requirement for the purpose of this document. Applying a 5% buffer to five year target (London Plan 2015 annual target x 5), including the entire shortfall (297 homes), Tower Hamlets has a total 5 year housing land supply requirement of 20,950 homes over 1 April 2016 and 31 March 2021. Table 2 – Five year supply requirement, April 2016 London Borough Calculations of Tower Hamlets A. Homes required over 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 3,634 (1 April 2015 – 31 March 2016) D. Delivery shortfall so far 297 (1 April 2015 – 31 March 2016) E. Homes remaining to be provided 35,680 (1 April 2016 – 31 March 2025) F. Number of remaining years 9 yrs (1 April 2016 – 31 March 2025) G. 5 year supply requirement excl. buffer 19,952 (B * 5) + D (Shortfall addressed within next 5 years) H. 5 year supply requirement incl. 5% buffer 20,950 G * 105% (1 April 2016 – 31 March 2021) 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 7: “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. Sites with planning permission should be considered deliverable until permission expires, unless there is clear evidence that schemes will not be implemented within five year, for example they will not be viable, there is no longer a demand for the type of units or sites have long term phasing plans.” 5.2 The Planning Policy Guidance (PPG) provides further guidance on what constitutes a deliverable site in the context of housing policy 8: “Deliverable sites for housing could include those that are allocated for housing in the development plan and sites with planning permission (outline or full that have not been implemented) unless there is clear evidence that schemes will not be implemented within five years. However, planning permission or allocation in a development plan is not a prerequisite for a site being deliverable in terms of the five year supply. Local planning authorities will need to provide robust, up to date evidence to support the deliverability of sties, ensuring their judgements on deliverability are clearly and transparently set out. If there are no significant constraints (e.g. infrastructure) to overcome such as 7 National Planning Policy Framework, CLG, footnote 11 8 Planning Practice Guidance, CLG, reference ID: 3-031-20140306 3 London Borough of Tower Hamlets Assessment of 5 Year Housing Land Supply, position at April 2016 infrastructure [,] sites not allocated within a development plan, or without planning permission, [sites] can be considered capable of being delivered within a five year timeframe.