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Leeds City Council Site Allocations Plan Examination Five Year Housing Land Supply Update Note Leeds City Council Site Allocatio

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Leeds City Council Site Allocations Plan Examination Five Year Housing Land Supply Update Note Leeds City Council Site Allocatio Leeds City Council Site Allocations Plan Examination Five Year Housing Land Supply Update Note 1.1 The following note has been prepared pursuant to the Appeal decision1 issued 18th June 2018 in respect of land south of Pool Road, Pool in Wharfedale. This note has been prepared to assist the SAP Inspectors and to inform of the most recent findings of the Pool Inspector relevant to the consideration of the Council’s five year supply position. A copy of the Appeal decision is appended to this note. 1.2 The decision followed a formal Public Inquiry held between 15th to 23rd May 2018. Amongst other matters, the Inquiry considered in great detail the Council’s current five year housing land supply position as of a 1st April 2018 base date. The Appeal decision therefore represents the most recent and up to date test of the Council’s five year supply. 1.3 Whilst the absence of a deliverable five year housing land supply2 was common ground at Inquiry between both the Council and the Appellants, the extent of the shortfall against the five year required remained in dispute. 1.4 At close of the Inquiry, the following points relative to five year supply were common ground between the two parties:- i. The agreed base date of the five year housing land supply assessment was 1st April 2018. The five year housing land supply period tested on appeal was therefore 1st April 2018 to 31st March 2023; ii. The agreed housing requirement is taken from the adopted Core Strategy and is equivalent to 36,412 dwellings or 7,282 d/pa inclusive of shortfall accrued since the beginning of the plan period and the application of a 20% buffer; and iii. On the Council’s best evidence, no more than 4.4 years supply could be demonstrated in contrast to the Appellant’s figure of circa 3 years. 1.5 The five year housing land supply evidence put forward by the Appellants included the joint work undertaken by Johnson Mowat & ID Planning. The SAP Inspectors have been provided with a copy of the most recent iteration of this work through the jointly prepared Matter 2 Statement3. 1.6 The Council’s five year supply position tested at Pool Inquiry was derived from the 2017 SHLAA update, with site specific assumptions revised as part of a shift toward a 1st April 2018 base date. This is the same evidence base which has been put forward to the SAP examination. 1 Appeal Reference APP/N4720/W/17/3187334 2 As required by NPPF paragraph 47 3 Examination Documents List Reference M2/92/AMI Leeds City Council Site Allocations Plan Examination Five Year Housing Land Supply Update Note 1.7 Sites currently subject to existing policy constraints (i.e. Green Belt) were excluded from both parties supply assessments, given that these could not be considered ‘available now’4 until such time the SAP can be adopted. The Council’s breakdown of deliverable supply at close of the Pool Inquiry is set out within the Table below. Total Five Year Requirement 1st April 2018 to 31st March 2023 36,412 Annual Requirement 7,282 Identified Supply (SHLAA excl. Green Belt) 29,245 Windfall 2,500 Empty Homes 500 Demolitions -225 Total Supply 32,020 Five Year Supply 4.40 Years 1.8 The Pool Inspector’s conclusions in respect of the Council’s five year housing land supply position are set out through paragraphs 56 to 70 of the Appeal decision. Paragraph 62 sets out the Inspector’s conclusions on the Council’s claim to a supply figure of 4.4 years, and states:- “For these reasons and notwithstanding the efforts being made to accelerate housing supply, I am not convinced that the Council’s assessment of its five year housing land supply provides a realistic prospect that the quantity of housing envisaged will be delivered on the identified sites within five years.” 1.9 Paragraph 63 of the Inspector’s conclusions then follows on:- “I therefore conclude that, for the purposes of this Inquiry, the current housing land supply is somewhere between 3 and 4.4 years of the current annual requirement, probably tending towards the lower end of that range.” 1.10 A ‘halfway house’ between the two parties supply figures would be equivalent to 3.7 years. With reference however to the Inspectors final comments highlighted above, we have assumed a lower end figure broadly equivalent to 3.5 years supply has been advocated. 1.11 Taking therefore the agreed five year requirement for the period 1st April 2018 to 31st March 2023 of 36,412 dwellings, a supply of 3.5 years would be broadly equivalent to 25,487 dwellings5. This is some 6,533 dwellings short of the 32,020 dwellings considered deliverable by the Council at the Pool Inquiry. 1.12 The overall balance between five year requirement and five year supply therefore stands at a shortfall of -10,925 dwellings6. This is the balance of deliverable supply to be demonstrated by the Council upon adoption of the SAP, i.e. newly identified ‘Phase 1 sites’ must 4 As required by NPPF Footnote 11 5 7,282 dwellings * 3.5 6 36,412 dwellings (Requirement) - 25,487 dwellings (Deliverable Supply) Leeds City Council Site Allocations Plan Examination Five Year Housing Land Supply Update Note demonstrably contribute over 10,000 units in the immediate five year period 1st April 2018 to 31st March 2023. 1.13 The Council have yet to publish a detailed breakdown of their supply figure, and specifically a clear calculation which demonstrates how the adoption of the SAP will deliver a five year housing land supply. This remains a significant concern put forward by others through recent Hearing Statements. As set out above, the Council’s latest supply position only very recently tested on appeal considers the Authority to be over 10,000 units short of a deliverable five year supply. 1.14 The revised March 2018 SAP Background Paper7 includes at Figure 1 a Housing Trajectory, which demonstrates cumulative completions over the plan period. The trajectory is presented in the form of a simple graph, and provides no specific breakdown of figures, though these are confirmed as being derived from the 2017 SHLAA Update. 1.15 The trajectory includes all Phase 1 SAP Allocations, including those currently within the Green Belt. Paragraph 4.4 of the Background Paper confirms an estimated contribution of 5,598 dwellings from Green Belt land by 2022/23. 1.16 Paragraph 4.4 of the Background Paper confirms that the Council anticipate a total of 47,643 dwellings to be delivered by 31st March 2023. Completions since the start of the plan period through to 31st March 2018 were agreed through common ground at the Pool Inquiry as totalling 16,157 dwellings. The Figure 1 Housing Trajectory can therefore be taken as advocating the delivery of 31,486 dwellings across the five year period 1st April 2018 to 31st March 2023 (i.e. 47,643 dwellings less 16,157 confirmed completions). 1.17 By contrast, Table 1 of the Council’s response to the Inspectors Initial Questions8 sets out housing trajectory figures across each HMCA to year 11 of the plan. Column 3 of Table 1 provides a supply total for the period 1st April 2017 to 31st March 2023 of 35,390 dwellings. This is a six year total, not a five year total. 1.18 Completions for the 2017/18 monitoring year were confirmed at the Pool Inquiry as totalling 2,333 dwellings. If the Council’s position at Table 1 were therefore taken as being the most up to date position, the supply total for the period 1st April 2018 to 31st March 2023 would be 33,057 dwellings9. 1.19 Whichever figure is preferred, this remains someway short of the agreed five year requirement for the period 1st April 2018 to 31st March 2023 of 36,412 dwellings before any adjustment has been made in light of the Pool Inspector’s conclusions on the Council’s less than robust supply position. 7 Core Document Reference CDR1/4a 8 Dated 8th May 2018 9 35,390 dwellings - 2,333 completions achieved in the 2017/18 monitoring year Leeds City Council Site Allocations Plan Examination Five Year Housing Land Supply Update Note Conclusions 1.20 Over recent years the Council have persistently over estimated the deliverable five year supply resulting in a number of lost s.78 appeals. Those arguments are not repeated here, however are already before the SAP Inspectors within our recent submissions10. 1.21 It is a requirement that the SAP must demonstrate a deliverable five year supply upon adoption. The correct starting point for calculating the Council’s five year supply position is the adopted 2014 Core Strategy requirement. This was agreed through common ground at the recently closed Pool Inquiry. 1.22 Whilst the Council are currently proceeding with a selective review of the Core Strategy (‘the CSSR’) which considers a lower housing figure, that figure is yet to be tested, remains subject to objections11 and can currently be given little weight. 1.23 The most appropriate base date for considering the Council’s five year supply position is 1st April 2018. The five year period is therefore 1st April 2018 to 31st March 2023. Through the recently closed Pool Inquiry, the calculation of the five year requirement was common ground between the two parties and calculated as follows. Element Figure Calculation Base Requirement 1st April 2018 to 31st March 2023 23,500 4,700 * 5 Backlog against CS target to 31st March 2018 6,843 23,000 - 16,157 Base Requirement + Shortfall 30,343 23,500 + 6,843 20% Buffer 6,069 30,343 * 20% Total Five Year Requirement 36,412 Annual Requirement 7,282 36,412 / 5 1.24 Evidence before the SAP examination points to the Council advocating a total deliverable supply for the period 1st April 2018 to 31st March 2023 of either 31,486 or 33,057 dwellings.
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