OFFICIAL Plymouth, South Hams & West Devon Local Planning Authorities’ 2020, 5 Year Housing Land Supply Position Statement December 2020 OFFICIAL Contents 1. Introduction ............................................................................................................................................... 2 2. What is the 5 year land supply? ............................................................................................................ 2 3. What is the Housing Delivery Test? .................................................................................................... 3 4. National Policy & Guidance - Demonstrating a 5 Year Land Supply ............................................ 9 5. JLP whole plan delivery 2014-2020 & 5 Year Housing Land Supply Position (2020 monitoring point) ........................................................................................................................................... 12 Appendices Appendix 1. MHCLG letter confirming recalculated 2018 HDT measurement for the 3 JLP authorities Appendix 2. Plymouth LPA supply over the next 5 years (2020-2025) Appendix 3 South Hams LPA supply over the next 5 years (2020-2025) Appendix 4. West Devon LPA supply over the next 5 years (2020-2025) Appendix 5. Sites removed from 5 Year Land Supply (lapsed and undeliverable consents & sites considered developable not deliverable 2020-2025) Appendix 6. Amendments to past net additional dwelling delivery due to NPPF/NPPG changes regarding counting student and communal accommodation Appendix 7. List of small sites in 5 year land supply Appendix 8. Small sites windfall allowance – historic evidence Appendix 9. List of sites with consent for communal accommodation & list of losses forecast in the 5 YLS Appendix 10 Progress towards JLP policy area and LPA monitoring targets at 2020 monitoring point Appendix 11 JLP Whole Plan Area Delivery & Supply 2014-2025 mapped by Policy Area and Local Planning Authority Area 1 OFFICIAL 1. Introduction 1.1 This position statement presents the 5 year housing land supply position for the Joint Local Plan (JLP) Authorities1 as of 31st March 2020 for the five year period from 1st April 2020 to 31st March 2025. It sets out the JLP Authorities 2019 Housing Delivery Test result and 2020 five year land supply position in accordance with the National Planning Policy Framework (NPPF) and National Planning Practice Guidance (PPG). 1.2 The Plymouth and South West Devon JLP was adopted by South Hams District Council on 21st March 2019, Plymouth City Council on 26th March 2019 and West Devon Borough Council on 26th March 2019. The 2020 5 Year Land Supply (5YLS) position is therefore set against the Housing Requirement in the JLP. 2. What is the 5 year land supply? 2.1 Paragraphs 67 and 73 of the NPPF 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, South Hams & West Devon Local Planning Authorities 2 OFFICIAL What is the starting point for the JLP authorities to demonstrate a 5 Year Land Supply? 2.2 The NPPF and PPG2 make clear that the starting point for calculating the 5YLS is the Housing Requirement figures identified in strategic policies provided they are less than 5 years old or more than 5 years old, but have been reviewed and are found not to need updating. In other circumstances the starting point for calculating the 5YLS will be the Government’s new standard method for ‘Local Housing Need’ (LHN). 2.3 As the JLP has recently been adopted (March 2019) the Housing Requirement (HR) within the JLP is the starting point for calculating the 5 YLS figure and therefore the 5 year land supply is not set against the Government’s new standard method for LHN. 3. What is the Housing Delivery Test? 3.1 The government introduced the Housing Delivery Test (HDT) to determine local authorities’ performance against its new standard method for LHN or adopted plan housing requirement (whichever is the lower). The HDT measures3 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. 3.2 The NPPF indicates that the HDT results are to be published every November however the Secretary of State published the 2019 HDT results for each local authority in England in February 20204. 3.3 The HDT has the following policy consequences 1. If delivery falls below 95% then an Action Plan must be published. 2. If delivery falls below 85% then a 20% buffer should be added to the five year supply5 3. If delivery falls below 75% then there is a presumption in favour of sustainable development6 3.4 There are however transitional arrangements in place in relation to the application of the presumption in favour7 and this is set out in Annex 1 of the NPPF. For 2019 the 2 NPPG paragraph 005 Reference ID:68-005-20190722 3 The method for calculating the HDT measurement is set out in the HDT measurement rule book https://www.gov.uk/government/publications/housing-delivery-test-measurement-rule-book Further details of the HDT and its implications are contained within the NPPG https://www.gov.uk/guidance/housing-supply-and-delivery 4 https://www.gov.uk/government/publications/housing-delivery-test-2019-measurement 5 The buffer to be applied to the 5 year supply is now set by the result of the HDT 6 NPPF paragraph 11d and footnote 7 7 NPPF paragraph 11d and footnote 7 3 OFFICIAL presumption in favour would apply the day after the publication of the HDT8 if delivery falls below 45%. HDT Calculation - Total net homes delivered over the last three years 3.5 The HDT measurement rulebook explains that the number of net homes delivered to be used in the HDT (which is measuring delivery against plan requirement and LHN) is the National Statistic for net additional dwellings9 with adjustments for net student accommodation and net other communal accommodation.10 How to count student cluster flats and communal accommodation? 3.6 As a result of the guidance contained in the HDT measurement rulebook it is now the case that student cluster flats are to be counted as single dwellings11 against plan requirement and LHN figures. Furthermore the Government introduced ratios to be applied to student communal and other communal accommodation12 which are also to be counted against plan requirement and LHN. 3.7 As the HDT applies to the past three years the Government has required local authorities to make adjustments to the net supply statistics retrospectively to account for the changes introduced in the guidance. The three JLP authorities have therefore adjusted their past delivery figures and future supply figures to ensure it complies with the requirements of the HDT and is consistent with the NPPF/NPPG. The amendments and implications for each authority individually and collectively are set out below in the HDT result and 5 year supply position statement for the JLP authorities. HDT Calculation - Total number of homes required over the last three years Housing requirements more than five years old 3.8 The HDT measurement rulebook indicates in paragraph 14, that where the latest adopted housing requirement figure is over five years old the figure used will be, for areas with a local plan or a joint local plan, the minimum annual local housing need figure.13 Paragraph 21 of the rulebook then explains that there are transitional arrangements in place in 8 14th February 2020 9 https://www.gov.uk/government/collections/net-supply-of-housing published by MHCLG annually in November 10 As defined in the Housing Flow Reconciliation (HFR) guidance notes at https://www.gov.uk/guidance/dwelling- stock-data-notes-and-definitions-includes-hfr-full-guidance-notes-and-returns-form 11 Provided they meet the government definition of a dwelling (see link to HFR guidance in footnote 13) 12 Not previously accounted for in the JLP authority statistics due to the provisions of the old PPG which is superseded by the new guidance. 13 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/728523/HDT_Mea surement_Rule_Book.pdf 4 OFFICIAL relation to the minimum annual local housing need figure. It states “in identifying the correct housing requirement figure for the calculation, for the financial years 2015-16, 2016-17 and 2017-18, the minimum annual local housing need figure is replaced by household projections in all aspects of the Housing Delivery Test measurement stated in this Rule Book14” 3.9 Paragraph 22 of the rule book then identifies the