To report to the Planning Policy and Local Plan Committee:
· The Planning Inspector’s latest conclusions on the housing requirement for Tendring;
· The number of new homes built in Tendring during the 2019/20 financial year and the up-dated year-by-year ‘trajectory’ for future housebuilding (taking the impact of COVID-19 into account);
· The current housing land supply position (the ‘five-year’ supply); and
· The implications for Section 2 of the Local Plan and the determination of planning applications.
Councillors Allen, Bush and Chapman each had earlier declared interests in relation to Agenda Item 7 – Report A.1 – Updated Housing Supply Position and Housing Trajectory insofar as there were development sites mentioned in the report and/or its appendices for which they were a Ward Member and/or a parish/town councillor.
Councillor G V Guglielmi had earlier declared an interest in relation to Agenda Item 7 – Report A.1 – Updated Housing Supply Position and Housing Trajectory insofar as Site SGG9 (Land off Colchester Road, Lawford) in Appendix 5 (Assessment of Alternative Sites) of the Strategic Housing Land Availability Assessment (SHLAA) was opposite his dwelling.
The Committee had before it a comprehensive report (and appendices) of the Corporate Director (Place and Economy) (A.1) which reported:-
· the Planning Inspector’s latest conclusions on the housing requirement for Tendring;
· the number of new homes built in Tendring during the 2019/20 financial year and the up-dated year-by-year ‘trajectory’ for future housebuilding (taking the impact of COVID-19 into account);
· the current housing land supply position (the ‘five-year’ supply); and
· the implications for Section 2 of the Local Plan and the determination of planning applications.
Members were informed of the key points of the report as follows:
· the Planning Inspector for the Section 1 Local Plan had again confirmed 550 homes per year as a ‘sound’ housing requirement for Tendring;
· 784 new homes had been built in the 2019/20 financial year, meaning that the housing requirement had been achieved for the fourth year running – however, the COVID-19 coronavirus outbreak was expected to have a significant impact on the rate of housebuilding in 2020/21 and future years;
· even with adjustments for the impact of the COVID-19, there was still sufficient land allocated for housing development in the emerging Local Plan, or with planning permission, to comfortably achieve the District’s housing requirement up to 2033 without the need for any additional sites; and
· the Council could only demonstrate a 4.45 year supply of deliverable housing sites against the Government requirement to demonstrate a 5 year supply – but this was only because of a technicality within Government planning policy which required Councils to measure housing delivery against nationally set targets until such time as their Local Plan was formally adopted. This had implications for the way the Council currently dealt with planning applications.
In respect of the housing requirement it was reported that, following the further examination hearings for Section 1 of the Local Plan, the Planning Inspector had concluded, in his 15 May 2020 letter, that the ‘objectively assessed housing need’ (OAN) of 550 homes a year, as set out in the emerging plan, was still based on sound evidence and that there was no need to increase the figure in response to objections from some developers and landowners. The housing requirement for the period of the Local Plan 2013-2033 should therefore remain at 11,000 homes. With approximately 3,600 homes already built between 2013 and 2020, the remaining requirement between now and 2033 stood at approximately 7,400.
The Planning Inspector had also concluded that the Tendring Colchester Borders Garden Community could reasonably be expected to contribute 1,000 homes towards Tendring’s housing requirement between now and 2033; if the North Essex Authorities decided to proceed with that proposal.
Housing Completions and Future Trajectory
In relation to housing completions and future trajectory the Committee was made aware that in the period 1 April 2019 to 31 March 2020, a net total of 784 new homes had been completed in Tendring. This meant that the housebuilding target of 550 homes a year had now been achieved for a fourth year in succession. However, the COVID-19 coronavirus outbreak was already having a significant impact on rates of housebuilding and this was likely to continue some way into the future.
It was reported that Officers had updated the Council’s ‘Strategic Housing Land Availability Assessment’ (SHLAA) which contained a trajectory for future housing building and adjustments to predicted housing delivery that had been made in response to COVID-19 and various other factors and information. It was likely that housebuilding would fall to around 550 in the 2020/21 financial year, but that delivery would then gradually improve over subsequent years.
Implications for the Local Plan
The Committee was informed that when the Local Plan had been submitted to the Secretary of State in October 2017, the housing supply figures set out in the various tables within the Plan had provided a fairly accurate account of the position at that time. However, in the two and a half years that had passed since the Plan was submitted, more houses had been built, more sites had obtained planning permission (either through decisions of the Council or through the appeal process) and the anticipated timescales for certain developments had needed to be reviewed – particularly in light of the potential impacts of the COVID-19 outbreak, the Planning Inspector’s conclusions on Section 1 of the Local Plan and more up to date information supplied by developers and landowners.
It was therefore proposed that, ahead of the examination of Section 2 of the Local Plan, the Council should submit a ‘topic paper’ to the Planning Inspector which updated all of the housing figures in the Local Plan. Therefore the Committee was requested to agree the proposed updates, which included ‘pushing back’ the expected timescales for some of the larger developments in the Local Plan which were yet to obtain planning permission and for which more time was likely to be required for master planning and negotiations with landowners and developers. The ‘Hartley Gardens’ development proposed for north-west Clacton was the most notable of the developments that were expected to require more time for landowner discussions and master planning.
However, the ‘good news’ was that, even with adjustments for COVID-19, the updated SHLAA demonstrated that the sites allocated for housing development in the emerging Local Plan, along with sites that had already obtained planning permission, were more than sufficient to deliver the remaining 7,400 homes needed between now and 2033 – incorporating a healthy level of ‘headroom’ flexibility. There was subsequently no need, at this time, to include any additional sites in the Local Plan for housing.
Five Year Housing Supply and Decision Making
Members were aware that the Government required Councils to demonstrate an ongoing ‘five year supply’ of deliverable housing sites in order to ensure that they were well placed to meet their future housing needs. However, in February 2019, the Government had amended the National Planning Policy Framework (NPPF) which affected the way Councils calculated whether they could identify a five year housing supply – which had had particularly unfortunate implications for determining planning applications in Tendring.
The Committee was advised that where a Council’s adopted Local Plan housing policies were more than five years old (as was the case in Tendring), they were required to calculate housing supply against a ‘local housing need’ figure generated using the Government’s standard methodology which, for Tendring, had meant a housing target of 865 homes a year as opposed to the 550 homes a year target in the emerging (but yet to be adopted) Local Plan. This significantly higher figure was based on official population and household projections which, for Tendring, were known to contain errors and were considered to be substantially ‘over-inflated’.
Therefore, despite the Planning Inspector’s endorsement of 550 homes a year as the housing requirement for Tendring, and the very strong performance against that target in recent years, the change in Government planning policy meant that this Council could technically only demonstrate a 4.45 year supply of deliverable housing sites. Because of this, until Section 1 of the Local Plan was formally adopted or the Council was otherwise able to demonstrate a five year housing supply against the higher figure, planning applications for new housing would still have to be considered on their merits – weighing up the harm against the benefits, even where they were contrary to the emerging Local Plan.
During the consideration of this item the Temporary Assistant Director (Strategic Planning and Place) undertook to rename Appendix 5 of the SHLAA as “Assessment of Discounted and Alternative Sites” and to amend the key to the related Maps accordingly.
Having duly considered and discussed the contents of the report and its appendices:-
It was moved by Councillor G V Guglielmi, seconded by Councillor Bush and unanimously:-
RESOLVED that the Planning Policy and Local Plan Committee endorses the contents of this report and the new Strategic Housing Land Availability Assessment (SHLAA) (attached as Appendix 2) as evidence to support the deliverability of housing proposals in the new Local Plan and to demonstrate an up-to-date housing land supply position for the purposes of updating the Local Plan (as set out in Appendix 1), determining planning applications and contesting planning appeals.