The Housing Land Supply Position Statement (HLSPS) identified the supply of dwellings on sites that were allocated or had planning permission and allocations and, showed the extent to which existing plans fulfilled the requirement to maintain a rolling 5-year supply of deliverable land in accordance with the National Planning Policy Framework (NPPF).  In November 2020, the Council’s latest HLSPS was published which detailed its Housing Land Supply (HLS) position as at 1 April 2020.

As the adopted Local Plan Core Strategy (CS) was now more than five years old, in accordance with the NPPF, the Council was required to measure the 5-year HLS position against its minimum local housing need (LHN) using the new standard method calculation detailed in the Planning Practice Guidance.  As at 1 April 2020, the LHN figure for Rother was 736 dwellings per annum.  This was based on household projections, affordability and any appropriate cap to the LHN and a sharp contrast to 484 dwellings per annum identified in the CS.

As of April 2020, the number of outstanding dwellings with planning permission was 2,823; an increase in permitted sites since the beginning of the Local Plan (LP) timeframe.  From April 2011, 1,826 net additional dwellings had been completed; an average of 203 per annum.  It was noted that the annual housing requirement had not yet been achieved during the plan period.  Due to the considerable uplift in the housing figure from the adopted CS target to the LHN figure, the Council was only able to identify 2.87 years of housing supply.

The absence of a 5-year supply of deliverable housing sites meant that the development boundaries and related restrictions on development in the countryside would need to be acknowledged as being ‘out-of-date’.  As the Council could no longer demonstrate a 3-year supply, the general presumption in favour of sustainable development would now be a critical reference point when determining planning applications involving the provision of housing in neighbourhood areas that had a made Neighbourhood Plan (NP) e.g. Crowhurst, Rye, Salehurst and Robertsbridge, Sedlescombe and Ticehurst.  Therefore, development was no longer constrained by policies in the adopted NP.

Members noted that work had commenced on developing the Council’s new LP in conjunction with the Housing and Economic Land Availability Assessment.  A new housing target for the District would be established within the new LP and a timetable to produce the document would be published in early 2021.

During discussion the following salient points were noted:

·         The new LHN figure (736 units per annum) did not take account of local circumstances; a significant percentage of the District was designated as an Area of Outstanding Natural Beauty (AONB).  The Council had a duty to protect and enhance the natural beauty of the AONB, as well as RAMSAR (wetlands of importance) and green spaces across the District.

·         Disappointing that the Council was expected to achieve unrealistic targets set by the Government (not evidence based).  Important to lobby both MPs to address set targets.

·         Targets should reflect and meet the District’s need.

·         Clarity was sought on whether ‘made’ NPs were now powerless.  The Head of Strategy and Planning advised that all policies within ‘made’ NPs would still be considered, as stipulated in the NPPF, but they were considered ‘out of date’ and the weight afforded to the policy would depend on its consistency with the NPPF.

·         Parish and Town Councils with a ‘made’ NP were entitled to 25% of Community Infrastructure Levy funding.

·         Important to encourage landowners / developers not to land bank and progress developments.

·         Currently approximately 2,800 outstanding planning permissions of which 2,535 were anticipated to progress over the next five years (see Table 16 of HLSPS).

·         Quantitativeeasing was elevating prices.

·         Telescope the timetable of the LP to ensure a robust evidence-based and realistic LP was in place as soon as possible.

·         Quarterly countywide meetings were held with developers and relevant statutory bodies to discuss development progression.

·         Nationally approximately 30% of local authorities (presume mainly in the south east because of high housing need) did not have 5-year HLS; this included Eastbourne Borough Council (not 3-year), Tunbridge Wells Borough Council and Wealden District Council (WDC).  Locally only Lewes District Council was over the 5-year threshold with a 5.4-year HLS.

·         Impact of LHN figures in other areas – Hastings Borough Council’s adopted plan figures were 215 up to 451, Rother District Council 165 up to 711 and WDC 450 up to 1,225.

·         No direct sanctions to developers – development should commence before the expiration of three years from the date of permission (this was reduced from five years).  Developers would build when there was a need.

·         The NPPF (paragraphs 11 and 172) stated that major development (without a 5-year supply) would not be allowed in AONB area unless there were very specific circumstances.

·         Important to get the right houses in the right places for the right people. 

RESOLVED: That the report be noted.