SITE ALLOCATIONS AND HOUSING SUPPLY: ASSESSMENT OF THE HOUSING LAND AVAILABILITY IN WYCOMBE DISTRICT ON BEHALF OF “KEEP BOURNE END GREEN” PREPARED BY: SIMON CARTER NOVEMBER 2017 SITE ALLOCATIONS AND HOUSING SUPPLY ASSESSMENT CONTENTS PAGE 1. Foreword 3 2. Introduction 4 3. Methodology 7 4. Housing Supply 10 5. Office to Residential Windfall 13 6. Small Sites Windfall 19 7. Housing Policy Sites 24 8. The Adopted Development Plan 25 9. Planning Applications Pending Decision 26 10. Green Belt 27 11. Conclusion 28 APPENDICES: Appendix 1 – Delivered Housing Appendix 2 – Deliverable Housing Appendix 3 – Developable Housing Appendix 4 – Student Accommodation Appendix 5 – Windfall Sites Appendix 6 – ‘Prior Approval’ Office to residential Appendix 7 – ‘Full Planning Permission’ Office to residential Appendix 8 – Planning Applications Pending Decision Cover image: Hollands Farm and Bourne End Page 2 of 31 SITE ALLOCATIONS AND HOUSING SUPPLY ASSESSMENT 1. Foreword 1.1. I have undertaken this assessment of site allocations and housing supply upon instruction from and in the context of my involvement with Keep Bourne End Green (KBEG). The principal objectives for the assessment were defined as - • Validate the status of the housing supply in Bourne End and wider Wycombe District (including whether alternate brownfield sites are generally available), and; • Assess whether the release of Green Belt land at Hollands Farm is necessary to meet the unmet housing need. 1.2. I have a professional background founded in information technology with a long (25-year) history specialising in data services and for the past decade delivering data analytics to blue- chip companies. This gives me the necessary experience, expertise and understanding to co- ordinate the KBEG sub-group team in the core tasks required to fulfil the aims of this assessment including defining, collecting and processing data from planning records and site information embedded across a wide body of reports. 1.3. I, Simon Carter, confirm that I believe the facts stated in this report are true and that the opinions I express here are my true opinions based on the facts as I have found them. Simon Carter Page 3 of 31 SITE ALLOCATIONS AND HOUSING SUPPLY ASSESSMENT 2. Introduction 2.1. The Wycombe District Local Plan1 (WDLP) together with the Adopted Delivery and Site Allocations Plan2 (DSA) contain housing policies and site allocations to meet the objectively assessed need (OAN) for housing in Wycombe during the 2013 – 2033 plan period. 2.2. The OAN is determined in the Housing and Economic Needs Assessment3 (HEDNA) which forecasts the housing requirement for Wycombe through to 2033. The HEDNA assessed housing need for Wycombe is not challenged by this assessment, except to comment that it is considered less desirable to employ a 20% uplift for market signals4 (front-loaded into the OAN for Wycombe) as result of long-term projection forecasts including data based on the highest net migration5. In contrast a modest uplift combined with a strategy of annualised monitoring reports would allow Wycombe District Council (WDC) to respond to local changes in market signals - especially considering unknown future impacts of Brexit, uncertainty over international migration, changes to government legislation (such as targeting the release of developer held land banks) and economic challenges that are all reasonably beyond scope of the applied projection forecasts. It is noted that the National Planning Policy Framework (NPPF) further requires a 5% (or 20%) buffer in the five-year housing land supply which compounds the initial market signals uplift embedded within the OAN. 2.3. The HEDNA concludes6 Wycombe should deliver 13,108 net dwellings (albeit this total has been commonly rounded up to 13,200) comprising 10,100 market houses and 3,100 affordable homes. The WDLP states that the full qualified housing need cannot be wholly met within Wycombe District owing to site constraints and landscape designations – some 2,275 homes have necessarily been transferred to be delivered by Aylesbury Vale District Council (AVDC) which operates in the same functional economic and housing area. AVDC has opportunity to deliver greater housing numbers since it is less constricted by Green Belt and 1 Wycombe District Local Plan, Regulation 19 Publication Version, October 2017 is the Plan that is the subject of this consultation. 2 Wycombe District Adopted Delivery and Site Allocations Plan, July 2013 includes specific policies that allocate residential use to areas of land that were prepared against the national Framework policies and subject of sustainability appraisal and examination. These adopted policies will persist in the Local Plan. 3 Opinion Research Services/Atkins, Buckinghamshire Housing and Economic Needs Assessment Update, Addendum Report, September 2017 4 HEDNA Update, December 2016, Market Signals. Paras 7.84 – 7.87. 5 HEDNA Update, December 2016, International Migration. Paras 7.7 – 7.9. 6 HEDNA Addendum, Amended Figure 122, Page 42 Page 4 of 31 SITE ALLOCATIONS AND HOUSING SUPPLY ASSESSMENT AONB. Evidence to support the preparation of AVDC’s own Local Plan demonstrates7 strong housing supply that can accommodate the transferred dwellings. It is also considered that Buckinghamshire could become a Unitary Authority during the Plan period. A Memorandum of Understanding was jointly signed in July 2017 resulting that Wycombe will deliver housing supply against an OAN of 10,925 net dwellings. 2.4. NPPF requires8 a Housing and Economic Land Availability Assessment9 (HELAA) as necessary evidence to identify the supply of land for housing in support of the Plan. The HELAA is prepared against NPPF policies and guidance, and the Central Buckinghamshire Housing and Economic Land Availability Assessment Methodology10 (the HELAA methodology). The base date for the publication version11 of the HELAA is stated as 31st March 2016 which in practical terms means the monitoring information is at least nineteen (19) months out-of-date (as at the date of this report). The aged data is not considered of particular issue for strategic developable sites but is a concern for small and medium sized windfall developments: The interval since the base date provides sufficient time for unexpected planning applications to have come into the planning system and been approved and/or implemented which should be accounted as part of the ‘delivered’ or ‘deliverable’ housing supply. 2.5. WDC states a thorough review12 was undertaken in preparation of the Local Plan for meeting housing need. As result, all available sites for delivering housing supply against the OAN are detailed in specific housing policy or the HELAA. Other unexpected housing supply which comes forward during the Plan period is considered windfall. In terms of WDLP housing policy, the ‘windfall’ is expected to be small scale and well related to the HELAA windfall allowance13 of 43 dwellings per year. It is noted that office to residential windfall14 was subject to separate analysis by WDC which was forecast to deliver between 19 – 26 dwellings per year though carries no specific allowance in WDLP policies or the HELAA. 7 Aylesbury Vale Housing and Economic Land Availability Assessment, Report v4 to inform AVDC Proposed Submission Plan, January 2017. A total of 26,872 dwellings are identified in the AVDC HELAA against a full objectively assessed need of 19,385 homes (HEDNA Addendum, September 2017). 8 NPPF, Para. 159 9 Wycombe District Housing and Economic Land Availability Assessment, Publication Version, September 2017 10 Aylesbury Vale/Chiltern District/Wycombe District, Central Buckinghamshire Housing and Economic Land Availability Assessment Methodology, May 2015 11 HELAA. Para 1.ii 12 WDLP, Para 4.38 13 HELAA, Appendix 5 – Small Sites Windfall Assessment, Para 1 14 HELAA, Office to residential Windfall, Paras 48 - 52 Page 5 of 31 SITE ALLOCATIONS AND HOUSING SUPPLY ASSESSMENT 2.6. The first purpose of this report is to provide an up-to-date assessment of site availability for housing supply. As far as is practically possible this assessment uses the most recent planning data that is publicly available. This report does not provide an assessment of employment or retail land which underlying data is not readily available. 2.7. The HELAA states11 WDC is in the process of updating the monitoring information to a 31st March 2017 base date (to be completed before WDLP submission in March 2018). In that regard, much of this assessment work pre-empts WDC’s own HELAA update. However, given WDC’s pre-submission update is expected to consider data up to 31st March 2017 it will still exclude a further seven (7) months of potential housing supply data (up to the base date of this assessment) or twelve (12) months data (up to the submission date). It is noted that, by contrast, AVDC’s HELAA in support of its own proposed submission version of the AVDC Plan is dated January 2017 and includes the latest progress on development sites which have planning permission up to 20 December 201615. 2.8. This assessment therefore provides a chance to gain an early view on the latest and most up- to-date progress of development sites with planning permission. It provides opportunity to test the soundness of the HELAA by analysing all sites (which together are stated to meet the OAN) against those which have unexpectedly come forward into the planning system. 2.9. The second purpose of this assessment tests whether the unmet housing need justifies the delivery of homes in whole, or in part, on designated Green Belt land. It specifically reviews deliverable sites and net dwellings identified in the Wycombe District planning system to establish whether exceptional circumstances exist for the proposed Green Belt boundary change at BE2 Hollands Farm for the supply of housing. 2.10. The base date for this assessment is 31st October 2017, though some large development sites up to the 25 November 2017 have subsequently been included.