Using the Council’s figures there is a 5.13 years supply of housing land or a
surplus of about 86 dwellings. However, on the supply side the Council has
changed its assumptions concerning build rates and lead in times from those
used in its 2012 assessment. Lead in times have been reduced by a year and
the annual rates of dwellings delivered on sites accommodating more than 500
dwellings increased. At my request the Council analysed the lead in times and
build rates on large sites given planning permission since 2000. The
experience at a number of sites does show that short lead-in times are
possible. However, for the most part these sites had a history and in a number
of instances the starting point of the analysis was a renewed or revised
planning permission rather than the original grant of permission. Overall it is
difficult to conclude from this information that average lead in time is not
similar to that assumed in the 2012 analysis. If this were the case then there
would not be a 5 years supply with a 20% buffer.
22. There are no historic sites that have delivered more than 500 dwellings and
although I agree that large sites are likely to be built out by more than one
developer, each attempting to supply a different part of the overall market,
without more evidence, the proper course of action in circumstances where
there is no indication of widespread building industry support for the Council’s
new position, would have been to take a cautious and conservative approach
on build rates. Paragraph 03-0020 of the National Planning Practice Guidance Appeal Decision APP/R0660/A/13/2196044
6
(Guidance) says that the advice of developers and local agents will be
important in assessing lead-in-times and build-out rates by year.
23. Additionally about 40% of the houses that are assumed to be delivered within
five years do not have planning permission. These dwellings would be built at
strategic sites, sites awaiting legal agreements and windfalls. I accept that
there is evidence that justifies the inclusion of windfalls in later years.
However, although some development may be achieved on strategic sites, if
the Council takes a liberal view in granting planning permission in advance of
the adoption of the Core Strategy, their early development is by no means a
certainty. Given the level of objections to some of them, legal challenges
cannot be ruled out and significant infrastructure requirements will
undoubtedly cause delays at some sites.
24. There was a distinct lack of credible hard evidence to justify the projections for
some of these sites and consequently it would be unwise to place too much
reliance on the potential for delivering a significant amount of the housing
requirement from such sources. About half of these sites are not yet the
subject of planning applications and matters such as Environmental Impact and
traffic assessments have still to be determined at some of them, not
withstanding the need to relocate existing occupiers from more than one of the
sites. 18% of the dwelling requirement is meant to come from this source. I
am not persuaded that the evidence confirms that such optimism is justified.
25. Whilst I note that the Council intends to improve the delivery of legal
agreements that are necessary to enable planning permissions to be granted,
until this begins to happen there is no certainty that nearly 20% of the five
year supply could be delivered from this source. In any event legal
agreements will only be executed speedily if all parties wish them to be and
that is not always the case.
26. The 2012 analysis was prepared in full consultation with the development
industry. It appears to have been less involved with the more recent analysis.
There was a workshop held for members of the Housing Market Partnership in
December 2013 but the minutes suggest that it fell far short of approving the
Council’s revised approach. Unlike the position in 2012, the Housing Market
Partnership does not appear to have endorsed the methodology and
conclusions of the updated Strategic Housing Land Availability Assessment and
the Five Year Housing Land Supply Position Statement. This further
undermines the confidence that I have in the findings.
27. Following a consultation on the publication of the Planning Practice Guidance
(Guidance), the Council pointed out that at paragraph 3-037 the guidance
introduced accommodation for older people into the supply of housing. The
Council suggests that six residential institutions (use class C2) granted
planning permission since 2012 would accommodate about 360 elderly
persons, although it does not suggest how many households this
accommodation would replace. The Appellant questioned the legitimacy and
deliverability of some of these schemes, some of which were initially granted
planning permission before 2012. There is also no information as to how this
group was treated when the RS was establishing future housing requirements.
However, such is the likely overall shortfall that I am not persuaded that even
if 360 beds were to be provided in residential care homes over the next five
years and that provision resulted in a similar reduction in the overall dwelling Appeal Decision APP/R0660/A/13/2196044
7
requirement, there would be a five year supply. I conclude that the Council
has not demonstrated a five year supply of deliverable housing sites.
Paragraph 49 of the Framework says that in such circumstances relevant
policies for the supply of housing should not be considered up–to-date.
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