Arun District Council 5-year Housing Land Supply 2024/25 - 2029/30
4.1 This Chapter sets out the council's assessment of Housing Land Supply (HLS) for the Arun Local Planning Authority Area (i.e. excluding areas of Arun District which fall within the SDNP). The 5YHLS looks forward for the period 2024/25 - 2029/30. The methodology for assessing the 5YHLS is in accordance with the provisions of the NPPF, and relevant Planning Practice Guidance (PPG). In accordance with the AMR reporting period, the completions and commitments monitoring baseline period is from 1 April 2023 - 31 March 2024.
National Planning Policy Framework
4.2 In July 2024, the Government consulted on proposed changes to the NPPF, with a revised NPPF published on 12 December 2024. The NPPF sets out a revised standard method and requires a 5YHLS to be demonstrated at all times. This should include a 5% buffer, or 20% where there has been significant under delivery of housing over the previous 3 years (para. 78a & b). Further policy consequences apply where delivery has fallen below housing requirement over the previous 3 years (para. 79). Local Housing Need (LHN) calculations generated by the new standard method were published with the revised NPPF; these increase the annual requirement for Arun from 1,342 to 1,476.
4.3 A key objective of the Government's policy set out in the NPPF is to significantly boost the supply of homes (para. 61). This includes a requirement that LPAs should identify and update annually a supply of specific deliverable sites to provide 5 years' worth of housing against their housing requirement.
4.4 The NPPF sets out how authorities measure their previous 3 years housing delivery performance against the housing policy requirement or local housing need; and looking forward, how to calculate a 5YHLS:
- The Government's revised 'standard method' (SM) is used to calculate a minimum annual local housing need and comprises two main steps:
- Setting the baseline using the value of existing housing stock for the area of the local authority[1], where the baseline is 0.8% of the existing housing stock for the area. The most recent data published at the time should be used.
- An adjustment to take account of affordability, using the median workplace-based affordability ratios published by the Office for National Statistics (ONS) at a local authority level[2]. The mean average affordability over the 5 most recent years for which data is available should be used.
- The Housing Delivery Test (HDT) measures performance over the previous 3 years and is expressed as a percentage of the Local Plan housing target (or housing requirement), divided by the number of housing completions.
- Where plans are more than 5 years old and housing polices have not been updated, then the SM local housing need figure must be used (para. 78).
- The HDT is the basis for calculating an authority's 'buffer' for calculating a 5YHLS (para. 78b).
- Calculating a 5YHLS places emphasis on clearly evidenced 'specific deliverable sites' that are available in the right locations now, that can be developed within 5 years (para. 78).
4.5 The NPPF states that LPAs may make an allowance for windfall sites as part of the anticipated supply, if they have compelling evidence that such sites will provide a reliable source of supply (para. 75). This should not include residential gardens.
4.6 The NPPF contains further guidance to assess the deliverability and developability status of sites (Annex 2). To be considered deliverable, sites for housing should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within 5 years. In particular:
a) Sites which do not involve major development and have planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within 5 years (for example because they are no longer viable, there is no longer a demand for the type of units or sites have long term phasing plans).
b) Where a site has outline planning permission for major development, has been allocated in a development plan, has a grant of permission in principle, or is identified on a brownfield register, it should only be considered deliverable where there is clear evidence that housing completions will begin on site within 5 years.
4.7 To be considered developable, sites should be in a suitable location for housing development, with a reasonable prospect that they will be available and could be viably developed at the point envisaged.
Planning Practice Guidance (PPG)
4.8 The Government's streamlined planning guidance was launched on 6 March 2014 and is continually updated. It includes guidance on issues such as the starting point for the HLS, deliverability, developability and dealing with past under- and over- supply.
Housing Delivery Test (HDT)
4.9 The Housing Delivery Test Measurement Rule Book, 12 December 2024 sets out the method for calculating housing delivery as follows:
4.10 The results of the HDT for Arun for 2018, 2019, 2020, 2021, 2022 and 2023 (published by the Government) follow:
- 91% November 2018;
- 68% November 2019;
- 61% November 2020 (Published 19 January 2021);
- 65% November 2021 (Published 14 January 2022);
- 61% November 2022 (Published 19 December 2023)[3];
- 70% 2023 (Published 12 December 2024)[4]
4.11 For areas without a recently adopted (or reviewed) Local Plan (i.e., more than 5 years old), unless the strategic policies have been reviewed and found not to require updating, the 'minimum annual local housing need' figure (based on the SM) will be used.
4.12 Policy H SP1 'The Housing Requirement' in the ALP sets out the 5-year annualised whole plan target. This includes an element of unmet need from neighbouring local authorities and is accordingly referred to as the 'stepped housing requirement.'
4.13 However, for the purposes of this AMR and in accordance with the NPPF (12 December 2024), the 5YHLS requirement is calculated based on the Government's new SM, using the 'local housing need' figure for Arun District.
4.14 The NPPF sets out consequences for not meeting the HDT and the 5YHLS; failure in either case will trigger application of the 'presumption in favour of sustainable development' (para. 11d). The NPPF (footnote 8 & para. 79) specifies percentage thresholds where the housing requirement assessed against the HDT would trigger para. 11d such that applications should be granted, unless such a decision would conflict with the policies, protected assets, and designations of the NPPF or that the adverse impacts of doing so would significantly and demonstrably outweigh the benefits weighed against the NPPF as a whole, "having particular regard to key policies for directing development to sustainable locations, making effective use of land, securing well-designed placed and providing affordable homes, individually or in combination."
4.15 Following annual publication of the HDT, the NPPF specifies that if delivery has been below a LPA's housing requirement over the previous 3 years, the following policy consequences should apply (para. 79):
- Where housing delivery falls below 95% of the requirement, an 'action plan' to assess the causes of under-delivery and identify actions to increase delivery in future years should be prepared.
- Where housing delivery falls below 85% of the requirement, the LPA should include a 20% buffer to their 5 YHLS, in addition to preparing an action plan.
- Where housing delivery falls below 75% of the requirement, the 'presumption in favour of sustainable development' applies, in addition to the requirements for an action plan and a 20% buffer.
4.16 The published HDT results for Arun District (see para. 4.10 above) required that an action plan be prepared; and in 2019, an action plan was published, and a 20% buffer was triggered in order to calculate the 5YHLS. It is anticipated that this requirement will not change until the Government's thresholds (set out above) are achieved.
Housing Requirement
4.17 The NPPF advises that strategic policies in Local Plans should, as a minimum, provide for objectively assessed needs for housing (para. 11b). These policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development, including planning for and allocating sufficient sites (para. 23).
4.18 Arun's housing requirement is set out in the adopted ALP. The whole plan requirement, set out in Policy H SP1 'The Housing Requirement', is 20,000 new homes over the Plan period (i.e. 1,000 per annum). This target of 1,000 dwellings per annum (dpa) comprises the objectively assessed need of 919 dpa, plus an additional 81 dpa to meet unmet housing need over the Plan period to 2031. This contributes toward unmet needs of the local Housing Market Area (HMA) around Arun, as well as that of the Coastal West Sussex HMA.
4.19 Due to the shortfall in delivery from the start of the ALP period and the lead times required to build-out strategic allocations, it was established at Examination that a 'stepped trajectory' would be justified. This means that a lower figure of 610 would apply for the first 5 years of the plan (2011 - 2015); rising to 1,120 for years 6 - 10 (2016 - 2020); 1,310 for years 11 - 15 (2021 - 2025); and dropping to 960 for years 16 - 20 (2026 - 2030).
4.20 The PPG[5] clarifies:
"Housing requirement figures identified in adopted strategic housing policies should be used for calculating the 5-year housing land supply figure where:
- the plan was adopted in the last 5 years, or
- the strategic housing policies have been reviewed within the last 5 years and found not to need updating.
In other circumstances the 5-year housing land supply will be measured against the area's local housing need calculated using the standard method."
4.21 The ALP is more than 5 years old, and the housing policies were reviewed and need updating. In accordance with the NPPF, this means that the housing requirements within the ALP should be superseded by local housing need figure using the SM (para. 78).
Shortfall/Treatment of past under-provision
4.22 Given that the ALP is more than 5 years old, the housing requirement is now superseded by the local housing need figure. Therefore, shortfalls against the ALP requirements are no longer taken into account, as the SM for calculating local housing need factors this in. This is in line with the PPG[6] which states:
"Step 2 of the standard method factors in past under-delivery as part of the affordability ratio, so there is no requirement to specifically address under-delivery separately when establishing the minimum annual local housing need figure."
4.25 A number of other councils have adopted this approach of not including previous shortfalls when addressing housing need requirements for their 5YHLS calculations, including the following:
- Basingstoke and Deane Borough Council[7]
- Fareham Borough Council[8]
- Gedling Borough Council[9]
- North Northamptonshire Council[10]
Five Year Period
4.26 In accordance with the PPG[11], for decision making, a 5YHLS calculation is therefore, based on the new standard method local housing need figure of 1,476 dwellings per annum for Arun (up from 1,342 under the previous method), and is set out in this AMR for the reporting year. The methodology for calculating local housing need is set out in the PPG[12]. Guidance on the 5YHLS calculation is also set out in the PPG[13].
Buffer
4.26 Para. 78 of the NPPF 2024 addresses the need to for LPAs to identify housing land supply where their adopted local plan is more than 5 years old. It states:
"Local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of 5 years' worth of housing against their housing requirement set out in adopted strategic policies, or against their local housing need where the strategic policies are more than 5 years old. The supply of specific deliverable sites should in addition include a buffer (moved forward from later in the plan period) of:
a) 5% to ensure choice and competition in the market for land; or
b) 20% where there has been significant under delivery of housing over the previous three years, to improve the prospect of achieving the planned supply; or
c) From 1 July 2026, for the purposes of decision-making only, 20% where a local planning authority has a housing requirement adopted in the last five years examined against a previous version of this Framework, and whose annual average housing requirement is 80% or less of the most up to date local housing need figure calculated using the standard method set out in national planning practice guidance."
4.28 Given the published Housing Delivery Test figure for Arun of 70% in 2023 is below 75% (although up from 61% in the 2022 measurement, 65% in 2021 and 61% in 2020), a 20% buffer must still be added to its housing requirement figure.
4.29 Arun's historic performance of delivering housing completions is set out in Appendix 1 - Table 1. It provides annualised net housing completions for Arun District from 2008/09 - 2023/24. Up until 2011/12, it included sites which now fall within the SDNP Planning Authority. From 2012/13 onwards, the completions in SDNP are excluded from this data. However, it should be noted that the HDT includes completions in the SDNP.
4.30 Appendix 1 - Table 2 shows that completions averaged 751 dpa in the last 5 years, which is an improvement on the 675 dpa in 2022/23. This performance, while higher than 2022, and the highest recorded for the current reporting period, is still below the Local Plan trajectory target of 1,075 dpa over the last 10 years (based on the stepped requirement). If performance in 2023/24 is maintained over the next few years, significant progress will have been made, particularly as there has been a consistently high and increasing level of planning permissions, averaging 7,000 dwellings over the last 5 years (of which 5,494 are 'Deliverable'), which have not yet been implemented or completed.
4.31 Appendix 2 details the actual completions recorded in the year 2023/24.
Housing Land Supply Data
4.32 The assessment of HLS draws on several sources of evidence to calculate projected completion rates. The 5YHLS for 2024/25 - 2029/30 has been prepared using the Residential Land Availability (RLA) data supplied by WSCC as at 31 March 2024 (the latest available data)[14]. Additionally, a Call for Sites process was undertaken in August/September 2024 which, along with other data sources, were used to estimate deliverable supply looking forward 5 years from 1 April 2024. The 5-year HLS has partly been informed by the Housing and Economic Land Availability Assessment (HELAA) 2024 work undertaken by the council, which included publication of the Call for Sites over the summer to identify new opportunities, together with an assessment of previously proposed development sites within the district for deliverability and developability, and positive and proactive engagement with landowners, site promoters, developers and housebuilders. This included direct contact via email/phone to request updated delivery trajectories for strategic sites and those larger sites benefitting from planning permission. Whilst such information was not forthcoming on all sites, there was some success, which has assisted in informing the current 5YHLS position.
Projected completions on large sites with planning permission
4.33 For the purposes of assessing the HLS, 'Large' sites are those capable of yielding 5 dwellings or more from the monitoring year 2023/24. This is in line with the most up to date guidance contained within the PPG[15].
4.34 WSCC annually surveys all large sites with planning permission for 5 dwellings or more in West Sussex and provides a consistent assessment of the status of available sites in terms of commencement, actual completion, and projected completion. They liaise with the developers of large sites with full planning permission to gain evidence of when completions are predicted to come forward. This, therefore, provides a reliable basis for such sites being included in the assessment, in the terms of the sites being considered 'Deliverable.'
4.35 As well as HELAA records and Call for Sites data, Arun uses planning application data, recent appeal decisions, national published data, and case officer knowledge to help calculate the 5-year deliverable supply (using a consistent methodology on lead in times and build out rates). The sites which form part of this assessment are listed in Appendix 3.
Projected completions on Strategic Allocation Sites without planning permission
4.36 The stepped trajectory (Appendix 4) shows the predicted build out rates of the strategic allocation sites. This updated build out rate has been informed by the evidence sources outlined in para. 4.32 above. The strategic allocations and the details of each site are included as Appendix 4.
Projected completions on Housing & Economic Land Availability Assessment (HELAA) sites
4.37 A general Call for Sites for housing and employment use was undertaken for the HELAA in June/July 2021. The council undertook a new Call for Sites exercise in June/July 2023. This allowed sites for a range of uses to be submitted including residential, employment, Biodiversity Net Gain, Blue / Green Infrastructure and Leisure & Tourism uses[16]. A further Call for Sites was undertaken in August/September 2024 and will be reported in 2025.
4.38 The HELAA is not to be used for Development Management decisions as the HELAA confers no planning permission status to any site categorised as 'Deliverable,' 'Developable' or 'Not Currently Developable.' Sites in the HELAA may move from one category to another depending on circumstances. The HELAA remains a high-level assessment by the council. The most recent HELAA document and interactive map for the period 2021 was produced in January 2022[17].
4.39 For the purpose of this assessment, sites of 5 or more dwellings identified within the HELAA as 'Deliverable' (i.e., suitable, available, and achievable) and within the current built up area, are included, once sufficient evidence of deliverability was provided by the promotors - see Appendix 5 for details of sites included.
Projected completions on Made Neighbourhood Plan sites
4.40 Sites allocated in Neighbourhood Plans that have either been 'made' or have passed examination (as at 31 March 2024) are included if they are considered likely to come forward within the next 5 years. All such sites have been assessed as 'Deliverable' as part of the Neighbourhood Plan process and where up to date evidence was provided - see Appendix 6 for details of sites included.
Projected completions & implementation rates on small sites
4.41 The WSCC RLA survey includes comprehensive information on all planning permissions for residential development of all site sizes and dwelling numbers. From this data, it is possible to determine the number of dwellings permitted on all 'small' sites, i.e. sites of less than 5 dwellings, as at 31 March 2024.
4.42 These small sites are then categorised either as under construction ('In Course of Erection' - ICE), or not commenced. It is assumed that sites under construction will be fully built out within the next 5 years, so these are included in the 5YHLS. Of the sites that are not yet commenced, a non-implementation rate is applied - see Appendix 7. A list of small site commitments data is set out at Appendix 8.
Small sites windfall calculation
4.43 The NPPF (para. 75) provides for LPAs to make an allowance for windfall sites as part of the anticipated supply, if there is compelling evidence that they will provide a reliable source of supply. Any allowance should be realistic, having regard to the strategic housing land availability assessment, historic windfall delivery rates and expected future trends.
4.44 Appendix 7 uses data from the WSCC RLA on dwelling completions on small sites from 2004/5 to 2023/24, specifically excluding development on residential gardens, in accordance with NPPF para. 75. This demonstrates that completions on such sites were never lower than 19 dpa, and were as high as 147 dpa, with an overall average of 70 dpa for the last 20 years.
4.45 On this basis, it is reasonable to provide a windfall allowance for small sites at a rate of 70 dpa (the average for the period 2004/5 - 2023/24) towards the 5YHLS period. A windfall figure is only included within a year's worth of housing supply when the supply from existing permissions on small sites is less than 70. This ensures that no one year exceeds 70 dwellings as a windfall allowance. This is demonstrated in the following table, as well as Appendix 7:
Small sites windfall
| |
2024/25 |
2025/26 |
2026/27 |
2027/28 |
2028/29 |
Total |
| Small site dwellings projected |
84 |
60 |
39 |
7 |
1 |
191 |
| Windfalls allowance |
0 |
10 |
31 |
63 |
69 |
173 |
Housing Land Supply assessment
4.46 Following adoption of the ALP, delivery rates have not come forward as forecast, despite there being a healthy overall level of permissions. The reasons for this are covered in more detail in the 'Arun District Council Housing Delivery Test Action Plan 2021'[18], which updated the first version published in June 2019, and can be summarised as follows:
- Applications on all strategic sites have not come forward as anticipated.
- The quality of some submissions for major applications has not been of sufficient quality to allow for timely approval.
- Some applications on strategic allocations which were recommended for approval were subsequently refused at Committee.
- The rate of completions is largely dependent on developers and consequently out of the control of the council.
- Developers have not delivered on previously promoted build out rates.
4.47 There has been improvement in 2023/24 with the grant of planning permission for some strategic allocations, and through receipt of deliverability evidence from site promoters e.g., site housing trajectories. Further progress on the strategic allocations is anticipated given that Masterplans are in place for most sites.
4.48 In August/September 2023, the council commissioned an external consultant to secure residential site delivery agreements with landowners and developers on 8 sites (1 additional site was put forward by the landowners). 4 sites had outline planning permission and 5 were strategic allocations without planning permission as at 31 March 2022[19]. The process resulted in signed delivery agreements which contained estimated projected housing trajectories to boost the requirement of delivery evidence to meet the Category b definition of a deliverable site in the NPPF Annex 2[20].
4.49 The latest update of the Local Plan Housing Trajectory is at Appendix 9. This shows the actual and predicted dwelling numbers that make up the HLS over the whole Plan period (2011 - 2031).
4.50 The following table summarizes how the 5YHLS assessment has been calculated using the land supply data sources outlined in para. 4.32 above, against the SM, in accordance with the PPG[21]. The new SM local housing need figure for Arun District is 1,476 dpa and includes an affordability uplift to address housing delivery performance. The Local Plan backlog/shortfall is, therefore, no longer applied, or appropriate.
4.51 There is evidence of significant progress in bringing forward planning approvals on strategic sites, including a framework of coordinating Masterplans. The Arun Housing Market Absorption Study (December 2022)[22] considers that this should be monitored over the period 2023/24 to assess a likely step increase in housing delivery as a result. Indeed, housing completions show a step increase in 2023/24. Arun has also prepared and published HDT Action Plans which have provided policy coordination to help tackle the shortfall, including preparing Masterplans for strategic allocations, publishing an Interim Housing Statement, and work to secure residential site delivery agreements to remove barriers (see para. 4.46 above).
4.52 Based on the new SM and updated guidance published on 12 December 2024, the 5YHLS calculation indicates that there is a 3.41-year land supply.
5-Year Housing Land Supply Table
5YHLS based on the new Standard Method - Large sites commitments, Neighbourhood Plan allocations and HELAA sites all include a 10% slippage reduction in accordance with best practice.
| A |
Standard Method annualised figure for Arun housing need 2024/25 - 2029/30 (1,476 x 5) |
7,380 |
| B |
Plus 20% Buffer (A x 0.2) |
1,476 |
| C |
Total need 2024/25 - 2029/30 (A+B) |
8,856 |
| D |
Large Site Commitments (as at 31 March 2024 from WSCC RLA data - Appendix 3) |
4,914 |
| E |
Small Site Commitments (as at 31 March 2024 from WSCC RLA data - Appendix 8) |
297 |
| F |
Windfall allowance (as at 31 March 2024 from WSCC RLA data - Appendix 7) |
173 |
| G |
Made Neighbourhood Plan Allocations without planning permission as at 31 March 2024 from HELAA - Appendix 6) |
87 |
| H |
Deliverable HELAA Sites within built up area - Appendix 5 |
145 |
| I |
Strategic Site Allocations (without PP as at 31 March 2024 or committed after 31 March 2024 - Appendix 4) |
419 |
| J |
Total Supply (D+E+F+G+H+I) |
6,035 |
| K |
5-Year Supply in years (J/C x 5) |
3.41 |
Table Caption
Note: The SM figure for Arun includes a nominal element of need for the SDNP.
[1] Table 125: dwelling stock estimate by local authority district
[2] Median workplace-based affordability ratios
[3] Housing Delivery Test: 2022 measurement
[4] Housing Delivery Test: 2023 measurement
[5] Housing supply and delivery, Para: 005 Reference ID: 68-005-20190722
[6] Housing supply and delivery, Para: 031 Reference ID: 68-031-20190722
[7] Basingstoke and Deane Authority Monitoring Report 2022/23
[8] Fareham Borough Council: Five Year Housing Land Supply Position
[9] Gedling Borough Council: Five Year Housing Land Supply Assessment 2023
[10] North Northamptonshire Council Assessment of housing land supply 2023-28
[11] Housing and economic needs assessment, Para: 016 Reference ID: 2a-016-20190220
[12] Housing and economic needs assessment, Para: 004 Reference ID: 2a-004-20241212
[13] Housing supply and delivery, Para: 022 Reference ID: 68-031-20190722
[14] West Sussex commercial and residential data
[15] Housing and economic land availability assessment, Para: 009 Reference ID: 3-009-20190722
[16] Arun Call for Sites process
[17] HELAA report 2021
[18] Arun District Council Housing Delivery Test - Action Plan
[19] Arun District Council Residential Site Delivery Agreements, October 2023
[20] NPPF, Annex 2, Deliverable site definition
[21] Housing supply and delivery
[22] Arun District Council Housing Market Absorption Study