Methodology – Stage 5: Final evidence base
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What are the core outputs?
The following set of standard outputs should be produced from the assessment to ensure consistency, accessibility and transparency:
- a list of all sites or broad locations considered, cross-referenced to their locations on maps;
- an assessment of each site or broad location, in terms of its suitability for development, availability and achievability including whether the site/broad location is viable) to determine whether a site is realistically expected to be developed and when;
- contain more detail for those sites which are considered to be realistic candidates for development, where others have been discounted for clearly evidenced and justified reasons;
- the potential type and quantity of development that could be delivered on each site/broad location, including a reasonable estimate of build out rates, setting out how any barriers to delivery could be overcome and when;
- an indicative trajectory of anticipated development and consideration of associated risks.
The assessment should also be made publicly available in an accessible form.
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How is deliverability (1-5 years) and developability (6-15 years) determined in relation to housing supply?
Assessing the suitability, availability and achievability (including the economic viability of a site) will provide the information as to whether a site can be considered deliverable, developable or not currently developable for housing. The definition of ‘deliverability’ and ‘developability’ in relation to housing supply is set out in footnote 11 and footnote 12 of the National Planning Policy Framework.
All aspects of a Local Plan must be realistic and deliverable but there are specific requirements in the Framework in relation to planned housing land supply.
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What is the starting point for the five-year housing supply?
The National Planning Policy Framework sets out that local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide five years’ worth of housing against their housing requirements. Therefore local planning authorities should have an identified five-year housing supply at all points during the plan period. Housing requirement figures in up-to-date adopted Local Plans should be used as the starting point for calculating the five year supply. Considerable weight should be given to the housing requirement figures in adopted Local Plans, which have successfully passed through the examination process, unless significant new evidence comes to light. It should be borne in mind that evidence which dates back several years, such as that drawn from revoked regional strategies, may not adequately reflect current needs.
Where evidence in Local Plans has become outdated and policies in emerging plans are not yet capable of carrying sufficient weight, information provided in the latest full assessment of housing needs should be considered. But the weight given to these assessments should take account of the fact they have not been tested or moderated against relevant constraints. Where there is no robust recent assessment of full housing needs, the household projections published by the Department for Communities and Local Government should be used as the starting point, but the weight given to these should take account of the fact that they have not been tested (which could evidence a different housing requirement to the projection, for example because past events that affect the projection are unlikely to occur again or because of market signals) or moderated against relevant constraints (for example environmental or infrastructure).
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What constitutes a ‘deliverable site’ in the context of housing policy?
Deliverable sites for housing could include those that are allocated for housing in the development plan and sites with planning permission (outline or full that have not been implemented) unless there is clear evidence that schemes will not be implemented within five years.
However, planning permission or allocation in a development plan is not a prerequisite for a site being deliverable in terms of the five-year supply. Local planning authorities will need to provide robust, up to date evidence to support the deliverability of sites, ensuring that their judgements on deliverability are clearly and transparently set out. If there are no significant constraints (e.g. infrastructure) to overcome such as infrastructure sites not allocated within a development plan or without planning permission can be considered capable of being delivered within a five-year timeframe.
The size of sites will also be an important factor in identifying whether a housing site is deliverable within the first 5 years. Plan makers will need to consider the time it will take to commence development on site and build out rates to ensure a robust five-year housing supply.
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What constitutes a ‘developable site’ in the context of housing policy?
The National Planning Policy Framework asks local planning authorities to identify a supply of specific developable sites or broad locations for growth in years 6-10 and where possible for years 11-15.
Developable sites or broad locations are areas that are in a suitable location for housing development and have a reasonable prospect that the site or broad location is available and could be viably developed at the point envisaged. Local planning authorities will need to consider when in the plan period such sites or broad locations will come forward so that they can be identified on the development trajectory. These sites or broad locations may include large development opportunities such as urban extension or new settlements.
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Updating evidence on the supply of specific deliverable sites sufficient to provide five years worth of housing against housing requirements
Applications for planning permission must be determined in accordance with the development plan, unless material considerations indicate otherwise. Up-to-date housing requirements and the deliverability of sites to meet a five year supply will have been thoroughly considered and examined prior to adoption, in a way that cannot be replicated in the course of determining individual applications and appeals.
The National Planning Policy Framework requires local planning authorities to identify and update annually a supply of specific deliverable sites sufficient to provide five years’ worth of housing. As part of this, local planning authorities should consider both the delivery of sites against the forecast trajectory and also the deliverability of all the sites in the five year supply. By taking a thorough approach on an annual basis, local planning authorities will be in a strong position to demonstrate a robust five year supply of sites. Demonstration of a five year supply is a key material consideration when determining housing applications and appeals. As set out in the National Planning Policy Framework, a five year supply is also central to demonstrating that relevant policies for the supply of housing are up-to-date in applying the presumption in favour of sustainable development.
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Can unmet need for housing outweigh Green Belt Protection?
Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the “very special circumstances” justifying inappropriate development on a site within the Green Belt.
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How should local planning authorities deal with past under-supply?
The approach to identifying a record of persistent under delivery of housing involves questions of judgment for the decision maker in order to determine whether or not a particular degree of under delivery of housing triggers the requirement to bring forward an additional supply of housing.
The factors behind persistent under delivery may vary from place to place and, therefore, there can be no universally applicable test or definition of the term. It is legitimate to consider a range of issues, such as the effect of imposed housing moratoriums and the delivery rate before and after any such moratoriums.
The assessment of a local delivery record is likely to be more robust if a longer term view is taken, since this is likely to take account of the peaks and troughs of the housing market cycle.
Local planning authorities should aim to deal with any undersupply within the first 5 years of the plan period where possible. Where this cannot be met in the first 5 years, local planning authorities will need to work with neighbouring authorities under the ‘Duty to Cooperate’.
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Can previous over-supply of housing be considered when determining the objectively assessed need for housing?
The housing requirement is set at the starting point of the plan, which can be earlier than the date the plan is adopted. For a plan to be found sound it would have to be based on an objectively assessed need for housing. In assessing this need, consideration can be given to evidence that the Council has delivered over and above its housing need in previous years.
Household projections are based on past trends. If a Council has robust evidence that past high delivery rates that inform the projections are no longer realistic – for example they relied on a particular set of circumstances that could not be expected to occur again – they can adjust their projections down accordingly.
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How should local planning authorities deal with housing for older people?
Older people have a wide range of different housing needs, ranging from suitable and appropriately located market housing through to residential institutions (Use Class C2). Local planning authorities should count housing provided for older people, including residential institutions in Use Class C2, against their housing requirement. The approach taken, which may include site allocations, should be clearly set out in the Local Plan.
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How should local planning authorities deal with student housing?
All student accommodation, whether it consists of communal halls of residence or self-contained dwellings, and whether or not it is on campus, can be included towards the housing requirement, based on the amount of accommodation it releases in the housing market. Notwithstanding, local authorities should take steps to avoid double-counting.
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How should local planning authorities deal with empty housing and buildings?
The National Planning Policy Framework encourages local authorities to bring empty housing and buildings back into residential use. Empty homes can help to contribute towards meeting housing need but it would be for individual local authorities to identify and implement an empty homes strategy. Any approach to bringing empty homes back into use and counting these against housing need would have to be robustly evidenced by the local planning authority at the independent examination of the draft Local Plan, for example to test the deliverability of the strategy and to avoid double counting (local planning authorities would need to demonstrate that empty homes had not been counted within their existing stock of dwellings when calculating their overall need for additional dwellings in their local plans).
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How does the five-year housing supply relate to neighbourhood planning?
Local planning authorities need to be able to demonstrate a five-year supply of deliverable sites in order to comply with national policies. The National Planning Policy Framework asks local planning authorities to use their evidence base to ensure that their Local Plan meets the full objectively assessed needs for market and affordable housing, identifies key sites that are critical to the delivery of the housing strategy and identifies and updates annually a supply of specific deliverable sites sufficient to provide a five-year supply.
Neighbourhood plans set out policies that relate to the development and use of land and can be used to allocate sites for development but the plans must be in general conformity with the strategic policies of the Local Plan. Where a neighbourhood plan comes forward before an up to date Local Plan is in place, the local planning authority should work constructively with a qualifying body to enable a neighbourhood plan to make timely progress and to share evidence used to prepare their plan. Neighbourhood plans should deliver against the objectively assessed evidence of needs.
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How often should an assessment be updated?
The assessment of sites should be kept up-to-date as part of local authorities’ monitoring report and should be updated yearly.
It should only be necessary to carry out a full re-survey of the sites/broad locations when development plans have to be reviewed or other significant changes make this necessary (e.g. if a local planning authority is no longer able to demonstrate a five year supply of specific deliverable sites for housing).
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What information should be recorded when monitoring?
The main information to record is:
- progress with delivery of development on allocated and sites with planning permission;
- planning applications that have been submitted or approved on sites and broad locations identified by the assessment;
- progress that has been made in removing constraints on development and whether a site is now considered to be deliverable or developable;
- unforeseen constraints that have emerged which now mean a site is no longer deliverable or developable, and how these could be addressed;
- whether the windfall allowance (where justified) is coming forward as expected, or may need to be adjusted.