The NPPF seeks to significantly boost the supply of housing. To encourage this, LAs that have fallen behind with past delivery are required to make up for this by bringing forward an extra 20% of housing supply. Others are required to add 5% more homes. A lack of five year land supply is often the trigger for an application being prepared and submitted, particularly where such a proposal would be contrary to the development plan.

LAs can be pressured by local interests to limit the planned development of housing. This is evident in the reduction in the planned housing provision in many areas from that contained within the Regional Strategies. However, there is strong evidence that Planning Inspectors are increasingly challenging LAs.

The overall five year land supply in the Southern Half of England is marginal. The average position is 5.7 years’ supply. Given the ‘minimum’ required by the NPPF is 5.25 years, and that the majority of the data is that prepared and published by the LAs themselves, this does not represent a healthy position, and it is one which often leaves LAs open to challenge.

The 20% buffer applies to 34% of LAs reviewed. This indicates a degree of past poor performance of housing delivery. Savills research suggests that many LAs do not apply this buffer when reporting their supply. Overall, 63 of the 190 LAs reviewed by Savills (33%) do not report a five year supply. 117 (62%) do not report a six year supply or more (all based on the most recent figures (see Map 2).

Chris Rees (Director – Southampton) comments: “What we have witnessed since the NPPF came into force is a shift towards the Sedgefield Method of calculating the five year land supply and this position being supported by the Secretary of State and Appeal Inspectors.

In contrast to the Liverpool Method, this places the shortfall of housing within the five year period, as opposed to averaging the shortfall over the remainder of the Plan Period. This ensures the current housing shortfall is made up quickly, and not simply averaged out over a much longer time frame”.

Falling Planned Housing

Both Savills and the Policy Exchange have reported that the quantity of planned housing is smaller than that within the Regional Strategies. Savills analysis of locally planned housing on a like for like annual basis is as follows:

• Total dwellings p.a. as per relevant Regional Strategies: 113,769 (190 LAs)

• Total dwellings p.a. as per locally derived figures: 106,927 (190 LAs)

• Fall: 7,027 dwellings p.a (6.1%)

The situation in the South East Region is summarised as:

• South East Plan: 32,208 p.a.

• South East dwellings p.a. as per locally derived figures: 29,379

• Fall: 2,829 dwellings p.a. (8.8%)

However, the situation includes locally planned levels of housing, which are yet to be tested at Examination.

In London, where the London Plan remains as the top level development plan, the least fall is demonstrated: 2.2%.

Mid Sussex: Case Study

Mid Sussex District Council has recently announced plans for “more realistic” delivery of 10,600 homes in the period to 2031 (530 dwellings p.a.). This is a fall of 325 dwellings p.a from the South East Plan. Production has been delayed against published time frames on a number of occasions, owing to the delay in the actual revocation of the South East Plan, and they will now have their Local Plan examined in the absence of the Regional Strategy.

Following the announcement of the formal revocation of the South East Plan (with the exception of two policies), Council Leader Garry Wall stated, “We can now focus on delivering a sustainable plan, in partnership with our parish and town councils, that supports housing and economic growth while protecting the unique character and diversity of Mid Sussex”.

The situation in Mid Sussex is not unique. The NPPF is clear in that LAs should provide for the objectively assessed housing needs of the administrative area, while also taking into account the Duty to Co-operate. Savills continues to witness a conflict in this process, where LAs acknowledge high levels of affordable housing need, but a reluctance to identify and allocate sufficient land to meet both housing need and demand.

Taken from
Spotlight: National Planning Policy Framework - One Year On