The Chairmen of Committees to answer any questions by the public of which notice has been given no later than midday three clear working days before the day of the meeting in accordance with Council Procedure Rule No. 11.
Minutes:
“The data selected to arrive at the Babergh CS 4.1-yrs Housing Land Supply published in the 2017 Joint Annual Monitoring Report does not directly compare with the data used for the 2016 Joint Annual Monitoring Report when the Babergh CS Housing Land Supply was 5.7-yrs.
Babergh claims (FOI BE94-1718) that 14 validated applications were excluded from the current assessment (as well as the April 2017 Interim Assessment) on the grounds that they had not been granted planning permission nor were they sites allocated in the Local Plan and would therefore fail NPPF footnote 11.
Please explain the justification for applying these exclusions when NPPF Planning Practice Guidance (Para 031 Ref ID 3-031-20140306) states “However, planning permission or allocation in a development plan is not a prerequisite for a site being deliverable in terms of the 5-year supply” and “If there are no significant constraints (eg infrastructure) to overcome……sites not allocated within a development plan or without planning permission can be capable of being delivered within a 5-year timeframe.”
Councillor Lee Parker, Cabinet Member for Planning, responded as follows:-
“The approach to the use of data and the calculation of the 5 year land supply for the Annual Monitoring Reports is the same. The key differences in the sites identified in the assessments is principally a result of the delivery status of each site ie. whether a site has now been fully built out, is under construction, or has recently gained planning permission.
For sites with the benefit of planning permissions and/or allocations, whilst these sites have the greater certainty of delivery, they are only included in the 5 year land supply if it is considered that there is a realistic prospect that housing will be delivered within 5 years.
Sites without planning permission or allocation are less certain in their suitability, availability and achievability. Their suitability and achievability is appropriately considered through the planning application process, including the full extent of infrastructure provision required to make them acceptable. For this reason, the Council considers it robust to consider sites without planning permission in the 5 year land supply assessment, only where the Planning Committee has given a resolution to grant planning permission, subject to a Section 106 legal agreement for planning obligations.”
In accordance with Council Procedure Rule No. 11, Mr Tony Brigden had given Notice in accordance with the Council’s Constitution of his intention to ask a question of the Chairman at this meeting. As Mr Bridgen was unable to be present on the day, his question was read out by the Chairman, together with the answer.
“Babergh District Council's 2017 Annual Monitoring Report has a number of significant deficiencies, about which I have written to the CEO and other Officers. Amongst these are concerns with the accuracy of the 5 Year Housing Land Supply data assumptions and resultant calculations. Notable amongst which is the dwellings completion deficiency in the SHMA 5 Year HLS table, quoted as -510. This is at significant variance with the figure quoted in the Core Strategy calculation quoted as -101, because of differences in baseline data.
Examination of the 'Key Assumptions' shows the SHMA calculation utilises inflated historical annual targets of 355 as opposed to the CS Housing Targets of 220/325, thus misrepresenting the completions delivery performance.
Quite apart from questions of concern with the 355 calculation, the AMR is required to represent a realistic perspective of key matters within the remit of a Local Authority, and I ask the Council how its constituents can be asked to take seriously data that 'reverse engineers' performance metrics in what appears to be a deliberate attempt to misrepresent a key strategic measurement."
Answer
“The annualised housing targets in Core Strategy based 5 year supply methodology and the SHMA based 5 year supply methodology apply to different plan periods – 2011 to 2031 and 2014 to 2036 respectively. It is therefore appropriate to consider the relevant figures starting from 2014 which also matches the plan start year of the emerging Joint Local Plan.”