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ASSESSMENT of FIVE YEAR HOUSING LAND SUPPLY EPPING FOREST DISTRICT COUNCIL April 2016 Green Planning Studio

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ASSESSMENT of FIVE YEAR HOUSING LAND SUPPLY EPPING FOREST DISTRICT COUNCIL April 2016 Green Planning Studio Unit D, Lunesdale, Upton Magna Business Park, Upton Magna, Shrewsbury, SY4 4TT ASSESSMENT OF FIVE YEAR HOUSING LAND SUPPLY EPPING FOREST DISTRICT COUNCIL April 2016 Green Planning Studio Ltd Unit D Lunesdale Upton Magna Business Park Shrewsbury SY4 4TT Tel: 01743 709364 Fax: 01743 709385 Email: [email protected] GPS Ref: 15_685_SPEA1 Client: Richard Spearman 1 CONTENTS 1. INTRODUCTION_______________________________________________________3 2. EPPING FOREST DISTRICT COUNCIL 5 YEAR HOUSING LAND SUPPLY POSITION___4 3. EPPING FOREST DISTRICT COUNCIL HOUSING REQUIREMENT_________________5 4. HOUSING SUPPLY_____________________________________________________8 5. CONCLUSIONS_______________________________________________________10 APPENDICES APPENDIX A – EPPING FOREST DISTRICT COUNCIL’S ‘5 YEAR ASSESSMENT OF LAND SUPPLY’ - APRIL 2016 APPENDIX B – EPPING FOREST DISTRICT COUNCIL’S AUTHORITY MONITORING REPORT 2014/15 - APRIL 2016 APPENDIX C – OPINION RESEARCH SERVICES’ WEST ESSEX AND EAST HERTFORDSHIRE STRATEGIC HOUSING MARKET ASSESSMENT - SEPTEMBER 2015 2 1. INTRODUCTION 1.1. Green Planning Studio Ltd has been instructed by Mr Richard Spearman to undertake an assessment of Epping Forest District Council’s current five year housing land supply position. This assessment is undertaken in line with advice and guidance set out in both the National Planning Policy Framework and the Planning Practice Guidance. 1.2. The assessment will address the following in turn: - Epping Forest District Council 5 year housing land supply position - Epping Forest District Council housing requirements - Appropriate NPPF Buffer - Epping Forest District Council’s supply of housing land - Green Planning Studio Ltd’s assessment 1.3. At the time of Green Planning Studio’s assessment the following documentation and information was available and has been fully considered: - National Planning Policy Framework (March 2012) - Planning Practice Guidance (March 2014) - Epping Forest District Council’s ‘5 Year Assessment of Land Supply’ - Epping Forest District Council’s AMR 2014/15 - West Essex and East Hertfordshire Strategic Housing Market Assessment 3 2. EPPING FOREST DISTRICT COUNCIL 5 YEAR HOUSING LAND SUPPLY POSITION 2.1. Epping Forest District Council’s most recent update in relation to 5 year housing land supply is provided within their 2014/15 AMR, and 5 Year Assessment of Land Supply – 2016 to 2021, both published in April 2016. 2.2. It is stated in both documents, that the Council are able to demonstrate a supply of sites sufficient to provide 747 dwellings between 2016/17 and 2020/21. The Council states in the 2014/15 AMR that; ‘The trajectory continues to predict a slight over-provision of the target within the former East of England Plan’ 2.3. The Council does not, in either document, actually state or calculate the 5 year requirement figure. However they do state in the 5 Year Assessment of Land Supply document that their supply equates to 150.34% of requirement based on the East of England Plan. The Council’s calculations from April 2016 can be seen below: Outside 5 year 5 year supply Total for supply site type - (with a 10% non-build rate) 15/16 16/17 17/18 18/19 19/20 20/21 PP granted, not yet commenced, 10 gross units or 0 30 46 39 18 8 126.9 more PP granted, not yet commenced, less than 10 4 86 65 73 37 4 238.5 gross units PP granted, commenced but not completed, 10 gross units 65 98 73 45 34 10 234 or more PP granted, commenced but not completed, less than 10 67 42 16 0 0 0 52.2 gross units Informally identified - adopted 0 0 51 30 25 0 95.4 development brief Total 136 256 251 187 114 22 830 Total - (with a 10% non- 122.4 230.4 225.9 168.3 102.6 19.8 747.0 build rate) 5 year supply TOTAL 5 Year East of England Plan 5 year supply (residual target, based on what has been built Net units Supply from 2001/02 to 2012/13, then the remaining period of the Plan) 5 year supply (10% 747.0 85.37% 150.34% non-build rate) 5 year 830.0 94.86% 167.04% supply (all) 4 3. EPPING FOREST DISTRICT COUNCIL REQUIREMENT 2016/17 -2020/21 3.1. Epping Forest District Council Development Plan consists of a mixture of policies from the Adopted 1998 Local Plan and the Adopted 2006 Local Plan Alterations. 3.2. The Council’s most recently adopted housing target comes from the Regional Spatial Strategy which was the East of England Plan (EEP), published in May 2008. The EEP set a housing target of 3,500 dwellings in the 20 year plan period from 2001 – 2021. 3.3. However since the EEP was adopted there has been significant change in national policy and guidance in terms of housing targets, this housing requirement pre-dates the NPPF and is outdated. Moreover, the EEP was revoked on the 3 January 2013 and therefore no longer applies. 3.4. The existing Local Plan and the now revoked East of England Plan were adopted before the publication of the National Planning Policy Framework in 2012 (NPPF). With regard to housing supply, paragraph 47 of the Framework sets out that Local Authorities should look to significantly boost the supply of housing in their areas through their local plan. Part of this requirement is seeking to meet in full the objectively assessed needs for market and affordable housing in their housing market area, as far as is consistent with the policies set out in the Framework. 3.5. In addition, paragraph 47 states that the Council must identify and update annually a supply of specific deliverable sites sufficient to provide five years’ worth of housing against their housing requirements with an additional buffer of 5% (moved forward from later in the plan period) to ensure choice and competition in the market for land. 3.6. The Council’s most up to date measure of local housing need is set out in the’ West Essex and East Hertfordshire Strategic Housing Market Assessment’ published in September 2015, which was prepared as part of the evidence for the new Local Plan. 5 Base Requirement 3.7. The West Essex and East Hertfordshire Strategic Housing Market Assessment, published September 2015 states; ‘Considering the needs in each local authority, the SHMA concludes that the Objectively Assessed Need for Housing over the 22-year period as being... - 11,300 dwellings in Epping Forest (514 per year) This is the average number of dwellings needed every year over the period 2011-33’ 3.8. Green Planning Studio Ltd understands that this OAN figure has not been tested through an EiP by an inspector. However, the OAN figure is derived from the latest CLG household projections, which is the 2012-based release published in February 2015 over the plan period 2011-33, and is the most up to date assessment of the housing need in Epping Forest. 3.9. Using this OAN figure, the Council’s base 5 year requirement is 2,570 dwellings (514 DPA) before taking into consideration any shortfall of housing due to under-delivery in the plan period or NPPF buffer. This can be seen below: Base requirement 514 DPA taken from SHMA 514 x 5 years 2,570 Backlog/Shortfall 3.10. It must also be taken into consideration that the new SHMA takes a baseline date of 2011, and any backlog/shortfall from 2011 onwards needs to be taken into consideration. 3.11. Epping Forest’s performance since 2011 can be seen in the table below: Monitoring Year Completions Requirement (OAN) Shortfall 2011/12 288 514 226 2012/13 89 514 425 2013/14 299 514 215 2014/15 230 514 284 TOTAL 906 2,056 1,150 6 3.12. As shown above, the Council have fallen drastically short of the OAN requirement figure each year from 2011 onwards and accrued a shortfall of 1,150 dwellings in this period. 3.13. When this shortfall is added to the base requirement figure of 2,570, it gives a 5 year requirement of 3,720 dwellings before an NPPF buffer is applied. 3.14. There is a strong possibility that, in light of the latest housing requirement evidence, the Council have a record of persistent under-delivery and a 20% NPPF buffer should therefore be applied to the Council’s requirement figure. However, Green Planning Studio Ltd does not rely on this argument to prove that the Council are unable to demonstrate a robust 5 year housing land supply, and consequently use a 5% NPPF buffer in this assessment. 3.15. Adding a 5% buffer to the requirement increases the Council’s 5 year requirement to 3,906 dwellings. The full calculation of the Council’s 5 year housing land supply can be seen below: Base requirement - 514 DPA taken from 2015 SHMA 514 DPAx 5 years =2,570 Addition of Shortfall 2,570 + 1,150 = 3,720 Addition of NPPF buffer 3,720 x 1.05 = 3,906 7 4. EPPING FOREST DISTRICT COUNCIL HOUSING SUPPLY 2016/17 – 2020/21 4.1. Epping Forest District Council 5 year housing land supply comprises of a number of sites as identified within their April 2016 ‘5 Year Assessment of Land Supply – 1/04/2016 - 31/03/2021’. 4.2. Within the Council’s assessment, they identify a number sources of housing land, these sources include; • PP granted, not yet commenced, 10 gross units or more • PP granted, not yet commenced, less than 10 gross units • PP granted, commenced but not completed, 10 gross units or more • PP granted, commenced but not completed, less than 10 gross units • Informally identified - adopted development brief 4.3. The 5 year period which the Council identifies sites for is 2016/17 – 2020/21 and has a base date of March 2015 and has a housing trajectory to show how they expect the listed sites to deliver in each year of the 5 year period.
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