Five Year Housing Land Supply Review

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Five Year Housing Land Supply Review Matter 2 Statement On Behalf of:- Avant Barratt DW Hallam Land Linden Miller Persimmon Redrow Taylor Wimpey LEEDS SITE ALLOCATIONS PLAN EXAMINATION FIVE YEAR HOUSING LAND SUPPLY REVIEW 23 AUGUST 2017 Leeds Five Year Housing Land Supply Review Date: 23 August 2017 Johnson Mowat Planning & Development Consultants Coronet House Queen Street Leeds LS1 2TW t: 0113 887 0120 e: [email protected] w. www.johnsonmowat.co.uk LIMITATIONS The assessments and interpretation have been made in line with legislation and guidelines in force at the time of writing, representing best practice at that time. All of the comments and opinions contained in this report, including any conclusions, are based on the information obtained by Johnson Mowat Planning Partnership LLP during our investigations. There may be other conditions prevailing on the site which have not been disclosed by this investigation and which have not been taken into account by this report. Responsibility cannot be accepted for conditions not revealed by the investigation. Any diagram or opinion of the possible configuration of the findings is conjectural and given for guidance only and confirmation of intermediate ground conditions should be considered if deemed necessary. Except as otherwise requested by the Client, Johnson Mowat Planning Partnership LLP is not obliged and disclaims any obligation to update the report for events taking place after: a) the date on which this assessment was undertaken; and b) the date on which the final report is delivered. Johnson Mowat Planning Partnership LLP makes no representation whatsoever concerning the legal significance of its findings or to other legal matters referred to in the following report. This report has been prepared for the sole use of the Clients set out in this report. No other third parties may rely upon or reproduce the contents of this report without the written permission of Johnson Mowat Planning Partnership LLP. If any unauthorised third party comes into possession of this report they rely on it at their own risk and the authors do not owe them any Duty of Care or Skill. CONTENTS 1.0 INTRODUCTION 2.0 RECENT APPEAL DECISIONS 3.0 FIVE YEAR HOUSING REQUIREMENT 4.0 THE COUNCIL’S PRESENT SUPPLY POSITION 5.0 FIVE YEAR HOUSING LAND SUPPLY 6.0 IMPLICATIONS OF SAP PHASING 7.0 CONCLUSIONS APPENDICES APPENDIX 1 – AIREBOROUGH HMCA HOUSING TRAJECTORY APPENDIX 2 – CITY CENTRE HMCA HOUSING TRAJECTORY APPENDIX 3 – EAST LEEDS HMCA HOUSING TRAJECTORY APPENDIX 4 – INNER AREA HMCA HOUSING TRAJECTORY APPENDIX 5 – NORTH HMCA HOUSING TRAJECTORY APPENDIX 6 – OUTER NORTH EAST HMCA HOUSING TRAJECTORY APPENDIX 7 – OUTER NORTH WEST HMCA HOUSING TRAJECTORY APPENDIX 8 – OUTER SOUTH HMCA HOUSING TRAJECTORY APPENDIX 9 – OUTER SOUTH EAST HMCA HOUSING TRAJECTORY APPENDIX 10 – OUTER SOUTH WEST HMCA HOUSING TRAJECTORY APPENDIX 11 – OUTER WEST HMCA HOUSING TRAJECTORY APPENDIX 12 – JOHNSON MOWAT TEN YEAR TRAJECTORY APPENDIX 13 – JOHNSON MOWAT FIVE YEAR SUPPLY CALCULATION APPENDIX 14 – PHASE 1, 2 & 3 SAP GREEN BELT RELEASES APPENDIX 15 – JOHNSON MOWAT SUB-AREA MONITORING (SP7) APPENDIX 16 – 2012 AMR TABLE A (HOUSING TRAJECTORY) APPENDIX 17 – LEEDS HOUSING BACKGROUND PAPER (APRIL 2013) APPENDIX 18 – DELOITTE CRANE SURVEY, FEBRUARY 2017 APPENDIX 19 – BNP PARIBAS, CITY CENTRE HOUSING MARKET (15TH AUGUST 2017) APPENDIX 20 – LCC 2017 SHLAA SITES IN ALTERNATIVE ACTIVE USE APPENDIX 21 – LCC 2017 SHLAA SITES WITHOUT PLANNING PERMISSION 1.0 INTRODUCTION 1.1 This Report has been prepared by Johnson Mowat to assist the Leeds Site Allocations Plan (‘the SAP’) examination and Matter 2 Hearings concerning compliance with the adopted Leeds 2014 Core Strategy (CS). This Report has been prepared on behalf of the following developers/housebuilders:- i. Avant ii. Barratt DW iii. Hallam Land iv. Linden v. Miller vi. Persimmon vii. Redrow viii. Taylor Wimpey 1.2 This Report has been reviewed by several planning consultancy and land agents prior to final publication. 1.3 The purpose of this Report is to provide a review of recent housing delivery performance in the District following the first 5 years of the adopted Core Strategy (period 2012-2017) and to consider the likely outcomes for achieving the aims and objections of the CS housing delivery over the coming years. In undertaking this assessment, we look back to the material presented by the Council regarding delivery in the early years and also consider the likely effect of the phasing policy in CS H1 as now played out in the SAP. 1.4 The Council are now five years into the years 2012-2017. Housebuilding delivery rates have failed to meet the early ‘lower years’ target of 3,660 over each of the first consecutive five years of the CS. 1.5 Johnson Mowat working in contact with developers, land owners and agents have reviewed all sites contained within the Publication Draft Site Allocations Plan (‘the SAP’) together with the draft August 2017 SHLAA review. Sites identified in all of these documents have been included in our comprehensive ten year trajectory covering the period 1st April 2017 to 31st March 2022, as set out through Appendices 1-11. To align with the Council’s Publication Draft SAP, the trajectory has been broken down into each of the 11 sub-areas to include:- 1 Johnson Mowat Leeds Five Year Housing Land Supply Review August 2017 Identified sites (including those with planning permission and sites under construction); Phase 1 SAP Sites; Phase 2 SAP Sites; and Phase 3 SAP Sites. 1.6 The Council’s most recent five year supply assessment was set out and tested through a series of 78 appeals in 2016. A summary of the housing land supply position tested through recent appeals is set out at Table 1.1 below:- Table 1.1 – Recent Leeds 5 Year Supply Appeals Appeal Inquiry Closed Five Year Supply Position Boston Spa Inquiry closed late 2014 SoS DL confirms the Council cannot demonstrate a deliverable five year housing land supply East Ardsley Inquiry closed April 2016 SoS DL confirms the Council cannot demonstrate a deliverable five year housing land supply Collingham Inquiry closed April 2016 SoS DL confirms the Council cannot demonstrate a deliverable five year housing land supply Bramhope Inquiry closed April 2016 SoS DL confirms the Council cannot demonstrate a deliverable five year housing land supply Kippax Inquiry closed July 2016 LPA do not dispute a five year housing land supply cannot be demonstrated. No evidence presented. Farsley Decision quashed. Inquiry closed LPA do not dispute a five year housing land supply January 2017. cannot be demonstrated. No evidence presented. 1.7 The Council have recently published a ‘draft’ 2017 SHLAA position for comment. Our initial review of the draft 2017 SHLAA informs of a lower supply position. At first sight, it appears the Council’s approach to assessing the deliverability of proposed sites has been overly optimistic in the same manner as rejected by Inspector’s and the Secretary of State in the S78 in Table 1.1 above. The Council continue to place a high degree of faith in sites without planning permission, sites subject to expired planning permission, sites in alternative active uses and a dramatic upturn in housebuilding activity in and around the City Centre market. 1.8 This Report has been produced to update the Council’s position further to recent Inquiries and establish a five year housing land supply to reflect an updated 1st April 2017 base date. 1.9 In responding to the 2017 SAP Examination, we are aware of housebuilders concerns that later phases of Allocations (Phase 2 and 3) have no release date and note this Council has a history of opposing greenfield allocations as proven by a long run of S78 public inquiries 2 Johnson Mowat Leeds Five Year Housing Land Supply Review August 2017 in 2009, 2010 and 2011. In considering the need to phase the SAP Allocations in line with Policy H1 of the CS we explore the material on housing delivery presented to the CS examination and examine how accurate those predictions have been. Commentary on the need for phasing is found in Section 6 of this Report. 3 Johnson Mowat Leeds Five Year Housing Land Supply Review August 2017 2.0 RECENT APPEAL DECISIONS 2.1 As shown on Table 1.1 in section 1 of this Report, there is now extensive commentary on the Leeds District housing land supply which is relevant to this five year supply assessment. This section sets out key points arising from the Council’s supply position tested through recent Inquiries. Grove Road, Boston Spa – APP/N4720/A/13/2208551 2.2 Johnson Mowat (formerly Johnson Brook) presented housing land supply evidence to the Grove Road, Boston Spa Inquiry which took place between May and June 2014, with the Inspector’s report subsequently issued to the SoS on 3rd July 2015. 2.3 Both Johnson Mowat’s and the Council’s housing land supply positions were considered in extensive detail throughout this appeal, cumulating in correspondence from the SoS in December 2015 seeking both the Appellant’s and the Council’s views with respect to the most recent figures on housing delivery across Leeds, that being a poor delivery performance against the CS requirement post 2012. 2.4 This was an important consideration as while the Council had consistently projected a ‘healthy’ forward looking supply, a looking back exercise (as expected by the NPPG) revealed the Council had a relatively poor track record of making an accurate forward looking forecast of likely delivery. In other words, the Council’s view of sites with a ‘realistic prospect’ of delivering in the coming years had been proven to be over-optimistic in each successive SHLAA. 2.5 The looking back exercise on matters of housing land supply was acknowledged within the SoS Decision Letter (DL) issued 8th June 2016, which stated at §5:- “In November 2015 the Secretary of State sought your views and those of the Council on the latest housing supply figures following the publication of the live table on net supply of housing updated on 12 November 2015.
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