This statement constitutes an update to the published Housing Land Position Statement (March 2019).
On 13 December 2019 the Planning Inspectorate issued its decision in relation to an outline planning application for up to 100no. dwellings at 'Land to the South of Chain House Lane, Whitestake, Preston' (Appeal Ref: APP/F2360/W/19/3234070) within the administrative area of South Ribble.can be downloaded here.
The Inspector dismissed the appeal, and, in doing so, undertook a comprehensive analysis of the housing land supply position in South Ribble.
Given the nature of the joint strategic plan-making arrangement within Central Lancashire, the Inspector undertook this analysis mindful of the fact that the conclusions drawn 'may have consequences for decision making by neighbouring authorities' (Paragraph 34 of the appeal decision).
Central Lancashire Core Strategy Policy 4 contains the housing requirement figure for Preston and the other Central Lancashire authorities.
This Policy was adopted in July 2012, and is therefore more than five years old.
The Inspector's analysis in Paragraphs 9 to 36 of the aforementioned appeal decision assesses the evolution of the housing land supply situation across Central Lancashire since that time, including the publication of a Strategic Housing Market Assessment in September 2017, and the subsequent 'Joint Memorandum of Understanding and Statement of Co-operation relating to the Provision of Housing Land' which followed in October 2017.
More recent developments, namely the publication of the Central Lancashire Housing Study, and the commencement of consultation on a revised Memorandum of Understanding and Statement of Co-operation, both in 2019, are referenced in the appeal decision, with the Inspector noting the 'direction of travel by all three authorities towards the standard method and a redistribution of the housing requirement based on a range of factors' (Paragraph 36 of the appeal decision).
The Inspector's conclusions on housing land supply in the appeal decision are clear. Paragraph 37 of the appeal decision states:
'37. Having regard to paragraphs 33, 73 (and footnote 37) and 212-213 of the NPPF, and the PPG paragraph 062, I conclude that the figure within Policy 4 of 417 dwellings per annum is out-of-date on several counts:
(i) the strategic policies are over 5 years old;
(ii) my conclusions that the 2017 MOU (and SHMA leading up to it) did not properly constitute a review; and
(iii) the 'significant change' resulting from the introduction of the standard method in the 2018 Framework and the Council's significantly lower figure arising from the standard method calculation.
Additionally, the MOU itself requires review by September 2020; indeed a new version is currently undergoing consultation.'
Whilst the Inspector does not attempt to specify what South Ribble's final annual housing requirement figure should currently be, Paragraph 39 of the appeal decision concludes 'that the standard method of calculating local housing need should be used for the purposes of this appeal'.
As a partner authority in plan-making, whereby Policy 4 of the Central Lancashire Core Strategy is equally relevant in Preston as it is in South Ribble, we must adhere to the principles which underpin the decision made by the Inspector in this regard.
The factors outlined in Paragraph 37 of the Inspector's appeal decision apply to Preston in exactly the same way as they do to South Ribble. We no longer consider the 2012 Central Lancashire Core Strategy figure of 507 dwellings per annum to be a true reflection of Preston's minimum housing requirement.
As such, with immediate effect, we will use the standard method to calculate our minimum annual housing need figure, from a base date of 2019, for the purposes of monitoring our housing land supply position.
Further, with immediate effect, the Council can demonstrate a five year supply of deliverable housing land.
The detailed calculations in this regard, as at April 2019, are shown in the table below.
|Requirement||Local Housing Need||Redistributed Local Housing Need (2019 MOU)|
|B||Total five year requirement (A x 5)|
|C||Requirement plus 5% buffer (B + 5%)|
|D||Annual requirement plus buffer (C / 5 years)|
|E||Five year supply 1 April 2019 to 31 March 2024|
|F||Years supply (E/D)|
A proposed revised Memorandum of Understanding and Statement of Co-operation is the subject of a consultation until 13 January 2020. Whereupon the three Councils will be asked to make a determination on whether or not to approve the same.
For ease of reference, the Council's five year supply position against both the local housing need figure and the redistributed housing need figure (in accordance with the distribution proposed in the revised 2019 Memorandum of Understanding and Statement of Co-operation) is shown in the table above.
The latest Housing Land Position Statement is available to view in a PDF document below.