Plymouth, South Hams & West Devon Local Planning Authorities’ 2018, 5 Year Housing Land Supply Position Statement December 2018 Contents 1. Introduction ............................................................................................................................................... 2 2. What is the 5 year land supply? ............................................................................................................ 2 3. What is the Housing Delivery Test? .................................................................................................... 5 4. National Policy & Guidance - Demonstrating a 5 Year Supply ...................................................... 8 5. Plymouth LPA 2018 HDT & 5 Year Housing Land Supply ........................................................... 11 6. South Hams LPA 2018 HDT & 5 Year Housing Land Supply ...................................................... 17 7. West Devon LPA 2018 HDT & 5 Year Housing Land Supply .................................................... 26 8 The HDT and 5 Year Land Supply Position 2018 on adoption of the Joint Local Plan ......... 35 Appendices Appendix 1. Plymouth LPA 5 Year Land Supply Appendix 2. South Hams LPA 5 Year Land Supply Appendix 3 West Devon LPA 5 Year Land Supply Appendix 4. Plymouth LPA – Sites removed from 5 Year Land Supply (lapsed and undeliverable consents & sites considered developable not deliverable 2018- 2023) Appendix 5. South Hams LPA – Sites removed from 5 Year Land Supply (lapsed and undeliverable consents & sites considered developable not deliverable 2018- 2023) Appendix 6. West Devon LPA– Sites removed from 5 Year Land Supply (lapsed and undeliverable consents & sites considered developable not deliverable 2018- 2023) Appendix 7. Plymouth LPA - List of Small sites in 5 year land supply Appendix 8. Plymouth LPA - Communal accommodation consents & forecast demolitions Appendix 9. Plymouth LPA – Small sites windfall allowance evidence Appendix 10. South Hams LPA –list of small sites in 5 year land supply Appendix 11. West Devon LPA – list of small sites in 5 year land supply 1 1. Introduction 1.1 This position statement presents the five year housing land supply position for the Joint Local Plan (JLP) Authorities 1 as of 31 st March 2018 for the five year period from 1 st April 2018 to 31 st March 2023. It sets out an updated methodology and five year land supply calculation based on the relevant changes in the: revised National Planning Policy Framework (NPPF) published 24 th July 2018, updates to the National Planning Practice Guidance (NPPG) published 13 th September 2018, the Government’s current ‘technical consultation on updates to national planning policy and guidance’ published October 2018, the publication of the 2016 based household projections for England on 20 th September 2018 and the publication of the 2014 household projections for England on 12 th July 2016. 1.2 The Plymouth and South West Devon Joint Local Plan was submitted for independent examination in July 2017. The hearings were held between January and March 2018. The JLP inspectors considered that the plan could be made sound with some main modifications and these have been consulted on between October and December 2018 2. The consultation has now closed and representations on the modifications are now been considered by the Inspectors. The examination period will finish when the inspector’s final report is received and therefore this paper represents the council’s interim Housing Land Supply position until adoption of the JLP. 2. What is the 5 year land supply? 2.1 The NPPF was revised and published in July 2018. Paragraphs 67 and 73 of the NPPF 2018 require local planning authorities to identify a 5 year supply of deliverable sites. Paragraph 73 specifically states: “Local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against their housing requirements set out in the adopted strategic policies, or against their local housing need where strategic policies are more than five years old. The supply of specific deliverable sites should in addition include a buffer (moved forward from later in the plan period) of: a) 5% to ensure choice and competition in the market for land; or b) 10% where the local planning authority wishes to demonstrate a five year land supply of deliverable sites through the annual position statement or recently adopted plan, to account for any fluctuations in the market during that year; or c) 20% where there has been significant under delivery of housing over the previous three years, to improve the prospect of achieving the planned housing supply.” 1 Plymouth City Council, South Hams District Council and West Devon Borough Council 2 22 nd October 2018 to 3 rd December 2018 2 What is the starting point for the JLP authorities to demonstrate a 5 Year Land Supply? 2.2 All three of the JLP Authorities adopted development plans containing their strategic housing policies and Housing Requirements are more than 5 years old. The revised NPPF and NPPG 3 make clear therefore that the starting point for calculating the 5 year land supply will be the Government’s new standard method for ‘Local Housing Need’ (LHN). 2.3 As the JLP is yet to be adopted the Government has stipulated that until adoption of the JLP the 5 year land supply must be assessed at the individual Local Planning Authority (LPA) level. This also applies to the application of the Housing Delivery Test (HDT) discussed further below. 2.4 This position statement therefore sets out the 5 year supply position for each of the JLP authorities for 2018 individually and the final section of this position statement sets out the 5 year land supply position when set against the JLP Housing Requirement post adoption of the JLP. How is the minimum annual Local Housing Need (LHN) figure calculated? 2.5 The method for calculating the minimum LHN is set out in the NPPG 4 and is calculated in 3 steps. Step 1 setting the baseline 2.6 The baseline is set using the most recent household growth projections (2016) 5 and calculating the projected average annual household growth over a 10 year period (this should be 10 consecutive years, with the current year being the first year). 2.7 The Government however has recently consulted on changes to step 1. The consultation 6 set out the Government’s intention to amend the methodology contained in the NPPG, specifying that the latest household projections are not to be used. The consultation states that in the short term the 2014 based household projections are to be used in the calculation until such time that the Government established a new method in the longer term prior to the release of the next household projections. 7 3 NPPG paragraph 030 Reference ID:3-030-20180913 4 NPPG paragraph 004 Reference ID:2a-004-20180913 5 The most recent Household projections are the 2016 based Household projections https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populationprojections/datasets/ho useholdprojectionsforengland 6 MHCLG, Technical consultation on updates to national planning policy and guidance, October 2018 (consultation period – 26 th October 2018 to 7 th December 2018) 7 The JLP authorities assume this to mean prior to the 2018 based household projections that it is assumed would be scheduled for release in the autumn of 2020 3 2.8 In light of the Government’s consultation document the 5 year land supply position statements for each LPA have been set out against both the 2016 based household projections in line with the current NPPG and the 2014-based household projections, in the event that the Government amends the NPPG according to the intentions set out in the consultation document in the very near future. Step 2 – an adjustment to take account of affordability 2.9 The average annual projected growth figure (as calculated in step 1) is adjusted based on the affordability of the area. The most recent median workplace-based affordability ratios, published by the Office for National Statistics (ONS) at a local authority level, should be used 8. 2.10 For each 1% increase in the ratio of house prices to earnings, where the ratio is above 4, the average household growth should be increased by a quarter of a percent. No adjustment is applied where the ratio is 4 or below. Where an adjustment is to be made, the precise formula is as follows: Adjustment factor = (Local affordability ratio – 4/4) x 0.25 Step 3 – Capping the level of any increase 2.11 A cap may then be applied which limits the increase in the minimum annual LHN figure an individual local authority can face. Where the relevant strategic policies for housing were adopted more than 5 years ago (which is the case for all three JLP authorities) the local housing need figure is capped at 40% above the projected household growth for the area over the 10 year period identified in step 1. The 40% cap above projected household growth applies only to South Hams LPA and this is explained in the South Hams LPA 5 year land supply position set out below. 2.12 The precise formula for the minimum LHN figure and the cap (if applicable) is set out below. If ‘A’ is greater than ‘B’ then ‘B’ becomes the minimum LHN for the 5 year land supply A= Minimum LHN= (1+adjustment factor) x projected household growth B = Cap= Annual average household growth over 10 years (as per step 1) x 1.4 2.13 The minimum LHN figure is identified for each of the JLP authorities in the 5 year land supply sections of each authority’s position statement later in this report. 8 https://www.ons.gov.uk/peoplepopulationandcommunity/housing/datasets/ratioofhousepricetoworkplacebasedearni ngslowerquartileandmedian 4 3. What is the Housing Delivery Test? 3.1 The government have introduced the Housing Delivery Test (HDT) to determine Local authorities’ performance against its LHN or adopted plan housing requirement (whichever is the lower). The HDT measures 9 in percentage terms the net additional dwellings provided in a local authority area over the past three years against the lower of the Adopted Housing Requirement or the authority’s LHN over the past three years.