South Somerset District Council Five-Year Housing Land Supply Paper November 2020
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South Somerset District Council Five-Year Housing Land Supply Paper November 2020 1. Introduction 1.1. This report sets out the latest position on the five-year housing land supply for South Somerset District Council (SSDC), for the five-year period from 1st April 2020 to 31st March 2025. The information on extant planning applications and pending applications is accurate up to 31st May 2020. 1.2. The Council recognises that the information in this report can only represent a ‘snap- shot’ in time. The position regarding the five-year housing land supply is constantly subject to change, whilst every house built, each planning permission granted, and every major change to the delivery timetable for a housing site will affect the position. 2. Background and Context National Policy 2.1. The National Planning Policy Framework (NPPF) (2019) requires that Local Planning Authorities (LPAs) should use their evidence base to ensure that their Local Plan meets the identified housing need for their area. 2.2. Separate guidance1 sets out a standard method for LPAs to use to determine the minimum number of homes needed over the plan period, which will be used to inform the Local Plan Review currently in preparation. 2.3. The NPPF requires LPAs to identify and update annually a supply of specific deliverable2 sites sufficient to provide five years’ worth of housing against their housing requirements. 1 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/728247/How_is_a_minimum _annual_local_housing_need_figure_calculated_using_the_standard_method.pdf 2 The NPPF (2019) defines a deliverable site – “To be considered deliverable, sites for housing 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. In particular: a) sites which do not involve major development and have planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within five years (for example because they are no longer viable, there is no longer a demand for the type of units or sites have long term phasing plans). b) where a site has outline planning permission for major development, has been allocated in a development plan, has a grant of permission in principle, or is identified on a brownfield register, it should only be considered deliverable where there is clear evidence that housing completions will begin on site within five years “ For housing, a scheme is considered to be “major development” where 10 or more homes will be provided or the site has an area of 0.5 hectares or more. 1 2.4. The supply of specific deliverable sites should include a buffer (moved forward from later in the plan period). The buffer can range between 5-20% in accordance with the following circumstances set by the NPPF: 5% to ensure choice and competition in the market for land; or 10% where a LPA wishes to demonstrate a five year supply of deliverable sites through an annual position statement, or recently adopted plan, to account for fluctuations in the market during that year, or 20% where there has been significant under delivery of housing over the previous three years, to improve the prospect of achieving the planned supply. 2.5 A five year supply of deliverable housing sites, with the appropriate buffer, can be demonstrated in a number of circumstances; including where it has been established in a recently adopted plan, or in a subsequent annual position statement which has been produced through engagement with developers and others who have an impact on delivery, and been considered by, and incorporates the recommendations where necessary of the Secretary of State. 2.6 Since it was introduced in 2018 any significant under-delivery will be measured through the Housing Delivery Test (HDT). The HDT is an annual measurement of housing delivery over the previous three years and a measurement rule book is produced to set out how this is calculated3. 2.7 In the HDT results published in February 2020, South Somerset District Council achieved a result of 97% therefore for the purposes of this Five-Year Housing Land Supply position statement, a buffer of 5% is being applied. 2.8 In broad terms, the NPPF sets out the following process for assessing the housing requirements of a Local Planning Authority: i). For plan making (if submitted after 24 Jan 2019), to determine local housing need, the ‘standard method’ should be used, unless exceptional circumstances justify an alternative. ii) Local Planning Authorities must produce an annual assessment of the 5 Year Housing Land Supply against the housing requirement in strategic policies, or 3 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/728523/HDT_Measurement_ Rule_Book.pdf 2 against their local housing need where the strategic policies are more than five years old. iii) Unless these strategic policies have been reviewed and found not to require updating. Where local housing need is used as the basis for assessing whether a five year supply of specific deliverable sites exists, it should be calculated using the standard method set out in national planning guidance. iv) ‘Local housing need’ is defined as “The number of homes identified as being needed through the application of the standard method set out in national planning guidance (or, in the context of preparing strategic policies only, this may be calculated using a justified alternative approach as provided for in paragraph 60 of this Framework)”. 2.9 The South Somerset District Council Local Plan was adopted in March 2015. Its strategic policies on housing requirement have not been reviewed since. Therefore, as per ii) (above), as the policies are more than five years old, the requirement for the Council is set out in the ‘local housing need’. The ‘local housing need’ is calculated through the application of the standard method as per the method in national guidance. 2.10 The national guidance also sets out the approach to dealing with past under delivery/ shortfalls. It is clear at that: where the standard method for assessing local housing need is used as the starting point in forming the planned requirement for housing, the standard method factors in past under-delivery as part of the affordability ratio, so there is no requirement to specifically address under-delivery separately when establishing the minimum annual local housing need figure. 2.11 The Local Plan is presently undergoing a Review. An Issues and Options consultation was undertaken between October 2017 and January 2018; responses informed the Preferred Options consultation, which ran from June until September last year. 3 Determining the Five-year Housing Requirement Overview 3.1 In order to reach a conclusion on whether or not the Council can currently demonstrate a five-year supply of housing land, the following component parts need to be examined: The basic annual housing requirement; The five-year basic housing requirement; 3 The net housing completions since the start of the Local Plan period in 2006; Any track record of ‘significant under delivery’ determined through the HDT; and The buffer to be applied to the basic five-year housing requirement figure The basic annual housing requirement 3.2 National Guidance states that the standard method can be used to calculate a minimum annual local housing need figure as follows: Step 1 - Setting the baseline - Set the baseline using national household growth projections (2014-based household projections in England, table 406 unitary authorities and districts in England) for the area of the local authority. Using these projections, calculate the projected average annual household growth over a 10 year period (this should be 10 consecutive years, with the current year being used as the starting point from which to calculate growth over that period). Note that the figures displayed are rounded and individual cells need to be viewed in order to see the full number. Step 2 - An adjustment to take account of affordability - Then adjust the average annual projected household growth figure (as calculated in step 1) based on the affordability of the area. 3.3 The Local Plan sets out a housing requirement of 15,950 dwellings to be delivered over the 22 year period. This equates to an annualised average of 725 dwellings per annum. However, applying the national standard formula for the District, the basic Need Housing figure per annum is 685, or 13,690 over a Plan period of 20 years. The five-year basic housing requirement 3.4 Determining the five-year basic housing requirement is calculated by multiplying the annual requirement, over a five-year period. This equates to 3,425 dwellings (685 x 5). The appropriate buffer to be added 3.5 The new NPPF (2019) at paragraph 73 requires a 20% buffer to be applied where there has been significant under delivery of housing over the previous three years. It states in footnote 39 that from November 2018, this will be measured against the Housing Delivery Test. Significant under delivery is where the result indicates that delivery was below 85% of the housing requirement. 4 3.6 Based on the Government’s own methodology for calculating the test result as set out in the Housing Delivery Test Measurement Rule Book, July 20184, in February 2020 South Somerset District Council achieved a Housing Delivery Test result of 97% therefore a 5% buffer has been applied. 3.7 The PPG clarifies that the appropriate buffer should be applied to the housing requirement. This should be addressed in the first five years. Buffers are not in themselves cumulative and the appropriate one should be applied depending on the circumstances.