The allocation of sufficient and appropriate sites for development is a crucial element of the plan-led system. Our research has shown that 31% of English LPAs (90 of the 293 excluding London and National Parks) have acknowledged that they have less than five years of housing land supply. 28 authorities have not published a figure, leaving 175 that claim a five year land supply.
60% of those which accept that they have less than five year land supply, have a post-NPPF plan in place, demonstrating that this does not necessarily lead to sufficient (five years or more) housing supply. Not having an identifiable five year supply of deliverable housing land (with the necessary 5 or 20% buffer) has direct consequences with the council’s relevant housing policies being determined as ‘out of date’.
To enable a like-for-like comparison of the adequacy of land supply we have adopted a standard method of calculating five year land supply, using data published by the local authorities (see ‘Our Calculations’). This method makes no assessment of the deliverability of the identified sites within the LPA’s land supply.
Our analysis indicates that 76 authorities out of the 175 (43%) have less than 4.5 years of supply. A further 45 (26%) are classed as borderline, having 4.5 to 5.5 years of supply. This leaves 54 (31%) that have over 5.5 years of supply on this measure.
In those LPAs that do not have a five year supply of housing land, the NPPF requires that decisions on proposed housing sites be made in accordance with the ‘presumption in favour of sustainable development’. This often results in sites being proposed that are outside the LPA’s adopted spatial strategy, giving rise to conflict with the expectations of local communities and sites being delivered by the ‘planning by appeal’ route.
The Welsh Way
In contrast to the lack of guidance on five year land supply in England, since 2006 the Welsh planning system has ensured that local authorities calculate five year land supply by the same method, leading to far less variation.
More recently in January 2015, the Welsh government produced Technical Advice Note 1 which provides a template for the method of calculation, including stipulating how shortfall must be calculated (spread across all remaining years – Liverpool method). This should lead to robust figures that are comparable across the country.
In an attempt to encourage LPAs to adopt up-to-date plans, the Welsh government has stated that all authorities in Wales without an adopted local plan are automatically presumed to have zero years of land supply. This kind of bold approach in England could provide the incentive needed to ensure plans are prepared and adopted in a timely fashion.
The test of whether or not a LPA has a five year supply of housing land is one of the key tests prescribed in the NPPF and has been a key driver to the increase in planning permissions granted for housing sites, often through the appeal process. Introducing a standard formula with which to calculate the five year land supply position would add clarity and certainty to this key area of national policy and potentially give a further boost to land supply.