The Strategic Housing Land Availability Assessment has been published as part of the Guildford Borough Council Evidence Base and not as a consultation draft. Weighing in at almost 400 pages this seems more daunting than the reality – many pages are made up of individual site assessments.
The first observation is that there is no estimated target number of housing units to provide over the plan period (although on page 5 there is reference to “our interim housing number is currently 322 homes a year“).
If we assume the Borough-wide housing need of 322 units, this would suggest the required number of housing sites to find over the fifteen years of the Local Plan would be 4,830 homes. NPPF says that, for any five year period, Local Authorities must have identified their five year need plus 5% or 20% depending on their prior ability to satisfy housing need.
Figure one on page 9 shows that the number of housing units completed in 2008/9, 2009/10, 2010/11 and 2011/12 has remained resolutely below 250 units per year, suggesting that the 20% margin would apply to 5-year housing numbers.
Consequently, at any time during the plan period, Guildford Borough Council would need to have identified available and viable land for 1,932 dwellings for delivery within five years.
So, over the plan period, this suggests that housing need is 4,830 homes (fifteen years at, 322 units plus a floating allocation of 65 units to cover NPPF obligations).
The SHLAA identifies land for 11,799 new homes (no indication as to what percentage increase in new homes across the borough that would represent) and does not explain why the Report has seen fit to aim to provide around double the likely level of supply (for example, if there is a need to make up for several years of underdevelopment).
Any statement of need for housing should be kept under constant review as Local Plan policies emerge and as, say, employment land is identified so as to ensure that there is sufficient housing to accommodate the needs of employers and their staff.
The SHLAA was prepared in conjunction with the Employment Land Assesment (ELA) – published on 7th August – and the Strategic Housing Market Assessment (SHMA) – not yet published at the time of writing this review.
The tables 1-6 set out the results of the assessments for Guildford Town Centre, Guildford Urban Area, Western Urban Area, Identified Village Settlements, Rural Exception Sites and Previously Developed Land in the Green Belt respectively.
The figures from tables 1-6 should have been sub-totalled and the shortfall identified so that:
Years 1-5 631 units (required 1,675, hence shortfall 1,044 units)
Years 6-10 1,096 units (required 1,610, hence shortfall 514 units)
Years 11-15 1,896 units (required 1,610, hence surplus of 286 units)
The next stage would be to assess how many housing units could be brought forward from later periods to meet some or all of the shortfall. Assuming the basis of the Report is sound and that all such units have been accelerated (not totally clear from the text), there would be a need to find the additional dwellings from Green Belt or Countryside beyond the Green Belt.
Table 7 identifies 724, 1,280 and 0 potential new homes for the three periods respectively from Land in the Countryside but Outside the Green Belt.
If implemented, these housing units would still leave a nominal shortfall in Years 1-5 of 320 (64 dwellings per year), a nominal surplus in years 6-10 by 766 (153 dwellings per year surplus) and years 11-15 are unaffected with a surplus of 286 units.
OVER THE PLAN PERIOD, THIS SUGGESTS THERE WOULD BE 732 MORE HOMES THAN TARGET CREATED BETWEEN YEARS 1 AND 15 (AN OVERALL TOTAL OF 5,562 HOMES) WITHOUT NEEDING TO REDRAW ANY GREEN BELT BOUNDARIES.
The main problem, however, is that the five year supply from Years 1-5 is insufficient to meet the requirements set out in NPPF without using land in the Green Belt.
Table 8 sets out the summary of assumed development on land assessed as suitable for housing that is currently in the Green Belt.
Table 8 shows Years 1-5 at 1,214 in the Green Belt as currently drawn (an oversupply of 894 units against the 322 homes target per year referred to above). No justification is given as to why such oversupply should be provided;
At Years 6-10 table 8 suggests an additional 4,873 homes (on top of the surplus from tables 1-7), making a total surplus of 5,639 homes. Again no justification is given as to why such oversupply should be identified.
At Years 11-15 table 8 suggests 115 homes could be provided in the Green Belt, adding to the surplus of 286 from tables 1-7, totalling 401 homes above target level.
Further analysis of the various sites will follow although it is not expected that this analysis will be a thorough one for each plot proposed.
[to be continued…]