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Representation ID: 7898

Received: 24/09/2021

Respondent: Home Builders Federation

5. When considering the growth strategy to be delivered in this local plan the Council will need to ensure that there is sufficient variety of sites to either avoid or minimise the stepped requirement as well as ensure flexibility in its supply to make certain planned needs are met in full. This will require the Council to adopt a spatial strategy that enables it to allocate a wide range of sites in terms of both size and location with small and medium sites delivering in the early years of the plan allowing sufficient time for large strategic sites to come forward to meet needs in the second half of the plan period.
6. In our experience local plans that rely too heavily on large strategic sites within their local plans to meet needs can struggle to show their local plans are deliverable. In order to meet needs and show a five-year land supply councils often include overly optimistic delivery rates on larger sites which are often revised before or at examination as these are challenged. This can leave shortfalls in supply that need to be addressed through additional allocations or an early review. For example, at the recent Brentwood Local Plan examination where the Council went from having to a 10% buffer in supply to a shortfall of 5% from submission to hearings as delivery trajectories on strategic sites were revised.
The Council is also no doubt is aware of the Uttlesford Local Plan that was withdrawn by the Council on the recommendation of the Inspectors examining that plan. The Uttlesford Local Plan relied heavily on three new towns which delivered the vast majority of their housing needs at the end of the plan period. As well as considering two of these settlements to be undeliverable they also concluded that the trajectories for delivery were overly optimistic and that, even if all the new settlements were delivered, they could not show a five-year land supply with significant shortfalls against the requirement in the middle of the plan period. The inspectors noted in their overall conclusions that the strategy would lead to a stepped trajectory that unreasonably delayed addressing the issue of housing affordability and failed to test options with fewer homes in new settlements with more homes in other settlements.
8. This is not to say that a new settlement, or the strategic expansion of an existing settlement, should not be a key element of the land supply in this local plan. Such allocations provide a secure supply of land for development well into the future. However, in making such allocations we would advise the Council to take a cautious approach recognising the complexity of delivering such development and the impact this has on the point at which such schemes will start delivering new homes. Too often Councils are overly optimistic about the delivery of new settlements in the early stages of plan preparation ultimately leading to trajectories being pushed back later on in plan preparation once the strategy has been decided upon in order to maintain a five-year land supply. In some cases, this can lead to plans being found unsound.
9. A sound approach is therefore one that seeks to balance the delivery of larger strategic sites with the allocation of small and medium sized sites that come forward in the forward in the first half of the plan period. Such an approach can provide a consistent supply of homes that will help meet housing needs earlier than if the Council rely on new settlements to deliver the majority of their housing towards the end of the plan period.
10. In our experience local authorities can rely too heavily on larger sites within their local plans to meet their needs in full and fail to allocate sufficient smaller sites as contingency against the delays in delivery on larger strategic sites. This often leads to local authorities reaching examination and having to revise delivery expectations as they no longer have a five-year land supply or sufficient developable sites in years 6 to 10 of the local plan.
We also note that none of the options expect to deliver much beyond the Council’s housing requirement. The HBF recommends that the Council includes a substantial 20% buffer in supply to ensure that it can meet needs and that any sudden changes in delivery expectations are compensated for in the local plan and limit the need for amendments to be made to the plan at a later date in order to include further allocations.