Breckland Council Statement of Five-Year Housing Land Supply (1.11.2020) Published December 2020 SUMMARY Breckland Council can demonstrate a 5-year supply of housing land as set out below. The Council will review the 5-year land supply position in March 2021. Breckland Council’s 5 Year Housing Position Statement (October 2020) Housing Requirement A Local Plan annual target 612 B 5 Year Target 612*5 3,060 C Shortfall in delivery since 2011 866 D Requirement with shortfall (Sedgefield) 3,060 +866 3,926 E 5% Buffer 5% of 3,926 196 F Total Requirement (November 2020 – D+E 4,122 October 2025) G Annual Requirement F/5 824 Housing Supply G Major Sites with Planning Permission 4,380 H Minor sites with planning permission 886 I Local Plan allocations with undetermined planning 216 applications J Windfall 242 K Total Supply 5,724 L 5 Year Housing Supply (5% buffer) K/G 6.95 1. Introduction 1.1 This Five-Year Housing Land Supply Statement sets out Breckland District Council’s residential land supply position as at 31 October 2020. 1.2 The Council is required to make provision for land to be available to build a certain number of houses either through allocations in Local Plans or by approving applications on suitable sites. The scale and location of development is governed by national and local plan policy that essentially is to develop in sustainable locations and to meet objectively assessed local needs. In Breckland this means a predominantly urban orientated strategy. The National Planning Policy Framework (2019) 1.3 The National Planning Policy Framework (the Framework) is a material planning consideration in both plan and decision making and therefore it must be given due weight. 1.4 Strategic policies should include a trajectory of housing delivery illustrating the expected rate over the plan period, and all plans should consider whether it is appropriate to set out the anticipated rate of development for specific sites. Local planning authorities should identify and update a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against their agreed housing requirement. 1.5 The requirement should also include an additional figure (a buffer) that is taken from later years in the plan period. This could be: • 5% to ensure choice and competition in the market for land; or • 10% where the local planning authority wishes to demonstrate a 5-year supply of deliverable sites through an annual position statement or recently adopted plan, to account for any 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. 1.6 A five-year supply of deliverable housing sites, with the appropriate buffer, can be demonstrated 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 the Secretary of State; and • incorporates the recommendation of the Secretary of State, where the position on specific sites could not be agreed during the engagement process. 1.7 If there is compelling evidence, the Framework supports the inclusion of a windfall allowance in the 5-year supply figures. 2. Background 2.1 In November 2019 Breckland Council adopted its Local Plan. Paragraph 74 of the NPPF states: A five year supply of deliverable housing sites, with the appropriate buffer, can be demonstrated where it has been established in a recently adopted plan, or in a subsequent annual position statement which: a) has been produced through engagement with developers and others who have an impact on delivery, and been considered by the Secretary of State; and b) incorporates the recommendation of the Secretary of State, where the position on specific sites could not be agreed during the engagement process Footnote 38 states: For the purposes of paragraphs 73b and 74 a plan adopted between 1 May and 31 October will be considered ‘recently adopted’ until 31 October of the following year; and a plan adopted between 1 November and 30 April will be considered recently adopted until 31 October in the same year. 2.2 The Council was therefore able to demonstrate that it could demonstrate a 5 Year of Housing Land by virtue of having a recently adopted Local Plan. This assumption ended on 31 October 2020. 2.3. The usual monitoring year for housing supply calculations is April to March. It is therefore important that this continues to be reflected in the Council’s Monitoring processes. 2.4 Therefore this report includes the following information1. • Completions for the Period 1 April 2019 – 31 March 2020 • Planning permissions as at 31 March 2020 • Completions 1 April 1 2020 – 31 October 2020 • Planning permissions as at 31 October 2020 2.5 The 5 Year Housing Land Supply position is set out for the period ending 31 October 2020. 1 Please note: Due to the restrictions imposed by Covid 19 lockdown restrictions it was not possible for onsite monitoring to be undertaken between April and August 2020. The total dwellings completed therefore covers the period April 2019 – October 2020. This Report makes some assumptions on the number of dwellings completed in the year ending March 31 2020 and the subsequent 7 months ending October 2020. This is set out in this Report 3. Housing Requirement 3.1 The first step in assessing a Council’s 5-year land supply is to establish the correct housing requirement against which to test the identified supply. 3.2 The national Planning Practice Guidance (PPG) sets out what the starting point for calculating a 5-year land supply is. It states2: Housing requirement figures identified in adopted strategic housing policies should be used for calculating the 5-year housing land supply figure where: • the plan was adopted in the last 5 years, or • the strategic housing policies have been reviewed within the last 5 years and found not to need updating. 3.3 This guidance provides a clear steer as to the most appropriate requirement figures that should be used to calculate the 5-year land supply position. In 2019, Breckland adopted its Local Plan with an annual housing requirement of 612 dwellings. 3.4 Over the next 5-year period the requirement is therefore 3,060 dwellings (612*5) Shortfall 3.5 Table 1 below sets out the total completions since 2011. After a slow start from 2011, recent years (up to 2019) have shown there to be an upward trend in completions post-recession. This was a positive indicator of the strength of housing delivery in Breckland going forward. 3.6 Between April 2019 and October 2020 753 dwellings were completed. This can be assessed against the required target of 969 dwellings for the period April 2019 – October 2020 (19 months)3 3.7 This represents a shortfall over the 19-month period of 216 dwellings (969 – 753) 3.8 For monitoring and consistency purposes, it is necessary to seek to apportion the completions by the standard monitoring year (April – March). Lockdown restrictions meant that on-site monitoring was not possible until after August 2020. Consequently, it is not known whether a completion occurred between April 2019 and March 2020 or between April and October 2020. What is known is that nationally there has been a very significant drop in completions since March 2020 due to the covid pandemic. Information from MCLG suggests that, in England the number of dwellings completed on site was 15,390 from April to June 2020. This is a 62% decrease compared to the last quarter and 64% below their level in the same quarter a year ago4. This reflects the decision of most of the biggest housebuilders to shut down operations on site as well as closing sales offices and showhomes in order to prevent the spread of the virus. A Report by Savills (Impact of Covid-19 on social 2 Paragraph: 005 Reference ID: 68-005-20190722 3 Based on 612 per annum. This equates to an average of 51 per month. 19 months = 969 4 MCLG Report: Housing supply: Indicators of new supply, (England Statistical Release January to June 2020 housing supply and residential construction (Savills June 2020)5 estimated that in 2020-21 completions will fall by 33% on the previous year. 3.9 Following the introduction of restrictive measures in March 2020, as a result of the covid pandemic, It is evident that there have been significant implications on the construction industry 3.10 Based on the anecdotal and statistical evidence above and for the purposes of this Report it is assumed that completions for 7-month period beginning (April 2020) were an average of 60% of those achieved in 2019/2020. This percentage is a reasonable level that balances the MCLG of 64% decrease in Q2 (April – June 2020) with the conclusions of the Savills Report. 3.11 The total of 753 completions recorded over the 19-month period means that there was an average of 40 completions per month. A simple extrapolation of this average would result in 476 completions in the year ending March 2020 and a further 277 in the 7 months to the end of October 2020. However, due to the impact of the pandemic it is clear that the level of completions has been below average since April 2019. For the purposes of this Report it is considered reasonable to apply an assumed 40% reduction to the 7-month period ending October 2020.