For and on behalf of Peer Group PLC Regulation 19 Detailed Objection in Relation to the Housing Strategy based upon the Impact for Five Year Housing Land Supply and Whole Plan Supply Prepared by Emma Raine BA (Hons) MA Strategic Planning Research Unit DLP Planning January 2018 Prepared by: Emma Raine BA (Hons), MA Planner Approved by: Alex Roberts BSc (Joint Hons) Director Date: January 2018 Strategic Planning & Research Unit 4 Abbey Court V1 Velocity Building Fraser Road Ground Floor Priory Business Park Tenter Street Bedford Sheffield MK44 3WH S1 4BY Tel: 01234 832740 Tel: 01142 289190 Fax: 01234 831 266 Fax: 01142 721947 DLP Consulting Group disclaims any responsibility to the client and others in respect of matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence. This report is confidential to the client and DLP Planning Limited accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own risk. 2 Contents Page 1.0 Introduction ................................................................................................................ 4 Methodological Approach 4 2.0 National Policy Background Regarding the Status of Development Plans and Five-Year Land Supply ............................................................................................. 6 National Planning Policy Framework 6 Planning Practice Guidance 6 The Housing White Paper 7 Conclusions 8 3.0 Recent Appeal Decisions ........................................................................................ 10 White Moss, Butterton Lane, Crew Appeal Decision APP/R0660/W/17/3166469 10 Epping Forest District Council Appeal Decisions 10 4.0 Assumptions Regarding Timescales and Delivery Rates ..................................... 11 Other Research on Delivery Rates and Lead-In Times 11 5.0 Local Evidence on Delivery and Lead-in Times ..................................................... 15 Past Rates of Delivery 15 Local Market Evidence- Past Delivery 15 Local Market Evidence- Lead-In Times 18 Summary 19 6.0 Epping Forest Local Plan - Housing Trajectory ..................................................... 20 Liverpool vs Sedgefield 20 New Garden Town Communities 20 Housing Allocations 22 Sites with Planning Permission 26 Application of a Non-Delivery Rate 29 7.0 Conclusion ............................................................................................................... 30 Appendix A- Epping Forest and SPRU’s Adjusted Housing Trajectory ......................... 36 Appendix B- White Moss, Butterton Lane, Crewe Appeal Decision (app/r0660/w/17/3166469) ....................................................................................... 37 Appendix C- Woodlands, 152 High Road, Chigwell Appeal Decision (app/j1535/w/17/3174835) ........................................................................................ 38 Appendix D- Cornerways, Turpins Lane, Chigwell Appeal Decision (APP/J1535/W/17/3173140) ..................................................................................... 39 Appendix E- Analysis of Local Lead-In Times for Epping Forest District Council ........ 40 Appendix F- Analysis of Local Lead-In Times for Uttlesford District Council ............... 42 Appendix G- Analysis of Local Lead-In Times for East Herts Council ........................... 44 3 Regulation 19 Detailed Objection to Housing Strategy Impact for Five Year Housing Land Supply and Whole Plan Supply on Behalf of Peer Group PLC 1.0 INTRODUCTION 1.1 This report has been prepared by the Strategic Planning & Research Unit of DLP Planning Ltd on behalf of Peer Group Plc and assesses the housing land supply position of Epping Forest District Council for the period 2017-2022 and the whole plan period to 2033. This is the most recently available set of data contained within the Housing Implementation Strategy (December 2017). 1.2 Given the Council’s intended submission date of March 2018, we consider that when the Council’s five year supply of housing is discussed at the examination, then an up-to-date assessment of land supply in the District is made available to participants within a reasonable amount of time, prior to the hearings. 1.3 This report utilises the most up-to-date research of timescales and delivery rates including those nationally and locally to further inform the conclusions. 1.4 The main areas of difference between the approach taken by Epping Forest and the SPRU approach are: • SPRU’s contention that some sites are not considered genuinely available in the five-year period to deliver homes; • There are several sites which have been double counted in their supply; • The Council has been over optimistic in the delivery rates for certain sites; • It is SPRU’s contention that there has been persistent under delivery and that a 20%, rather than a 5% buffer, should be applied in this case. 1.5 It is of note that there are several errors contained within the evidence on housing. Such issues include mixing up the site capacity of Latton Priory and East of Harlow in the trajectory and references to sites SP4.1, SP4.2 and SP4.3 in the trajectory are actually referenced as SP5.1, SP5.2 and SP5.3 in the plan, as well as the double counting of sites as outlined in section 6. It is issues like these that questions the accuracy and credibility of the Local Plan evidence base. Methodological Approach 1.6 SPRU have combined Appendix 3 and Appendix 4 of the Council’s Housing Implementation Strategy (2017) into one trajectory, which we consider to be the Council’s position. 1.7 This provides an overall total supply to 2033 of 11,827 dwellings (excluding completions from 2011 to date which provides an overall total of 13,157 dwellings to 2033) and a five-year supply figure of 3,486 dwellings. The Council incorrectly calculate their existing commitments supply by 5 dwellings which accounts for the figure of 13,157 and not 13,152 as proposed. 1.8 The starting point for the Council’s trajectory demonstrates that Epping Forest have 5.28 years of housing land supply when applying a 5% buffer to the supply, and the application of the Liverpool method. 1.9 We challenge the use of the Liverpool method for addressing the backlog for two reasons, firstly the Council have failed to engage neighbouring authorities via the Duty to Cooperate to assist in addressing this shortfall, as required by paragraph 3.035 of the PPG. Second there is clear evidence that suitable, available and 01.27.18.ER.E5045PS.5YRHLSREP.Final 4 Regulation 19 Detailed Objection to Housing Strategy Impact for Five Year Housing Land Supply and Whole Plan Supply on Behalf of Peer Group PLC deliverable sites have been omitted from the plan and that these smaller non strategic sites could be allocated to address the shortfall sooner without compromising the balance of the plan or the delivery of the larger strategic site allocations (as suggested in paragraph 2.11 (i) of the Housing Implementation Strategy). We have therefore calculated the Council’s five year land supply position using both the Liverpool, and the correct approach, the Sedgefield Method. 1.10 This trajectory will be used as the basis for calculating the revised housing land supply position of the district using the housing requirement identified by Epping Forest District Council in their emerging Local Plan of 11,400 dwellings across the plan period to 2033 or 518 dwellings per annum. 1.11 This assessment reviews the projected delivery of housing sites set out in the 2017 Housing Implementation Strategy, according to the most up-to-date national and local research of timescales and delivery rates. 01.27.18.ER.E5045PS.5YRHLSREP.Final 5 Regulation 19 Detailed Objection to Housing Strategy Impact for Five Year Housing Land Supply and Whole Plan Supply on Behalf of Peer Group PLC 2.0 NATIONAL POLICY BACKGROUND REGARDING THE STATUS OF DEVELOPMENT PLANS AND FIVE-YEAR LAND SUPPLY National Planning Policy Framework 2.1 The Framework seeks to deliver, as a main objective, a wide choice of high quality homes. It states at paragraph 47 that in order to boost significantly the supply of housing, the local planning authority should: • Use their evidence base to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area. • Identify and update annually a supply of specific deliverable sites sufficient to provide five years’ worth of housing against their housing requirements with either: i. A 5% buffer; or ii. A 20% buffer where there has been a record of persistent under delivery of housing 2.2 Footnotes 11 and 12 of the Framework define “deliverable” sites as: a. Being available now; b. Offering a suitable location; c. Being achievable with the prospect that housing will be delivered within five years; and d. Being viable. e. To be considered developable, the site should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged. 2.3 Sites with planning permission are to be considered deliverable until permission expires, unless there is clear evidence that schemes will not be implemented within five years. 2.4 Windfall sites can only be included in the five-year supply where there is compelling evidence that such sites have consistently become available in the local area and will continue to provide a reliable