SHLAA Housing Implementation Strategy – Knowsley MBCMarch 2010
Planning Policy Statement 3: Housing (PPS3) advises that Local Development Documents should set out a Housing implementation strategy that describes the approach to managing delivery of the housing and previously-developed land targets and trajectories. This document sets out how Knowsley’s housing targets will be achieved through the emerging Core Strategy.
Scenario and contingency planning
Background
The table below shows that between 2002 and 2016 the Unitary Development Plan required 3,220 dwellings to be built. This was based on the requirement contained within the Regional Planning Guidance for the North West (RPG13). This has now been superseded by the North West of England Plan Regional Spatial Strategy (2008) which requires 8,100 dwellings to be built between 2003 and 2021.
Plan period and housing targetsStart of Plan period / End of Plan period / Total housing required / Source of Plan target
2002 / 2016 / 3220 / Unitary Development Plan (June, 2006)
2003 / 2021 / 8100 / Regional Spatial Strategy (2008)
Source: Knowsley Replacement Unitary Development Plan (2006) and North West of England Plan Regional Spatial Strategy to 2021
In order to comply with the 2003 RSS requirement of no more than 230 dwellings peryear, the Council applied a housing constraint policy from March 2005 to February 2008.When the new RSS was published in 2008, it almost doubled Knowsley’s housing requirement.It also backdated the requirement to 2003 that is during the time that the Council was applyinghousing constraint. During the same period, a large number of properties were demolishedin the North Huyton and Tower Hill Action Areas.
Regional Spatial Strategy (RSS)
The Regional Spatial Strategy (RSS) for the North West was published in 2008. It required that new housing completions should total an average of at least 450 dwelling completions per year from 2003 until 2021. This figure is net i.e. in addition to demolition replacements. To date (i.e. from 2003 up to 2009) there has been shortfall of 1,517 net dwelling completions compared to the RSS requirement for this period. This has been largely due to there having been a large number of demolitions in Action Areas (primarily North Huyton) and a downturn in the economy.
In order to meet the RSS requirement, an average of 592 dwellings will have to be built each year from 1st April 2009 to 31st March 2021. This includes the 450 requirement in the RSS, plus an allowance to make up the shortfall from 2003-2009, plus a further allowance for replacement of anticipated demolitions.
Evidence Base and Emerging Local Development Framework
The Council have undertaken a Strategic Housing Land Availability Assessment (SHLAA), which was published in March 2010. This Study has assessed how much land could potentially be available for housing over the next 15 years, and where this could be delivered. The Study has indicatedjust under a 6 years supply is considered to be “deliverable” on the context of PPS3 and that a total ‘risk assessed’ 8 years supply of housing land is available within the urban area at the Study base date, April 1st 2008. Work is currently underway to undertake an update of the Study with a base date of April 1st 2010. It is anticipated that the work will be finalised by September 2010 and inform the Core Strategy “Preferred Options” consultation in autumn 2010.
As part of its Local Development Framework, the Council has published a Core Strategy “Issues and Options” paper. This was subject to public consultation between November 2009 and January 2010.This identifies three strategic options which may address the shortfall of land for housing development in different ways.
- Option A – Urban Concentration would enable about 5,500 dwellings to be built in the Borough.
- Option B – Focussed Urban Regeneration would enable about 6,500 dwellings to be built in the Borough.
- Option C – Sustainable Urban extensions would enable all housing need to be built in the Borough but would result in the loss of some Green Belt land mostly after the next ten years.
Note:Under Options A and B the shortfall would have to be met in adjoining districts.
The Council’s Core Strategy is currently expected to be adopted in March 2012, and will need to demonstrate a 15-year supply of housing land from the date of adoption toward 2027. Using the SHLAA with a base date of April 2008 and assuming the continuation of the current RSS requirement of 450 dwellings per annum continues beyond 2021 to 2027, Knowsley will therefore face a theoretical shortfall of approximately 4,500 dwellings.
The findings of the SHLAA will be monitored on an annual basis through the AMR to assess their validity. However, given the extent of the shortfall, Knowsley is likely to face a housing land shortage in the medium to long term. This would still likely apply even if a significant number of unanticipated “windfall” sites were to come forward.
In line with government guidance we have also looked to assess the potential supply that could arise from other sources, such as employment land, surplus green spaces, re-use of vacant homes, and building at higher densities. The approach that has been taken to each of these potential sources is outlined below:
- EmploymentLand: the recently published a Employment Land & Premises Study has indicated that Knowsley does not have sufficient employment land to meet its needs over the forthcoming Core Strategy plan period. The study stated the Borough needs an additional 110.85ha of employment land, which if rolled forward to 2027 for the Core Strategy plan period equates to 126.13ha of which 36.79ha can be gained through regeneration and remodelling opportunities. Work in this area has already commenced, as the Council recently appointed consultants DTZ to undertake a review of Knowsley Industrial Park (KIP). The findings of this study will feed into the emerging LDF as they become available.
- Public Open Space: The Council recently consulted on, via the “Issues and Options” paper, the potential for reviewing the green space standards in the Unitary Development Plan (UDP). If the standards were to be reviewed further evidence would need to be gathered, therefore is it difficult to determine the quantum of land that may be suitable for residential development in the future.
- FormerSchool Sites: In response to the Government’s plan for increased investment in primary schools, Knowsley Council has submitted proposals for the rationalisation of primary schools within the Borough. The proposals within the document, entitled ‘Future Schooling in Knowsley: Strategy for Change 2008- 2010’ building on the success of the ‘Building Schools for the Future’ programme. Although the programme is still in an embryonic phase, it is evident that a number a primary schools may become surplus to educational requirements over the 15 years of the strategy’s existence. Given the nature of the sites, at least some of them could be potentially suitable for residential development. These sites may feed into future reviews of the SHLAA as the become available, subject to other policy constraints.
- Vacant Homes: one potential source of housing is to bring long-term vacant properties back into use. This issue was addressed in Knowsley’s SHLAA, which commented that “it is evident that Knowsley is subject to a significantly lower incidence of long term empty homes than its neighbour Liverpool and that its vacancy rates are consistently lower than those across the Merseyside sub-region as a whole. Accordingly, it is considered highly unlikely that vacant properties will make a significant contribution to the supply of housing in Knowsley in coming years. Accordingly, no provision is made in the supply identified by this SHLAA for any additional dwellings to be provided through the re-occupation of empty homes”.
- Building at Higher Densities: Whilst building at higher densities is theoretically an option, we are aware that the apartment market has been hardest hit by the recent downturn, and a number of house-builders have told us they will not build any apartments for 10 years. The demand is now predominantly for family homes which will inevitably produce lower densities
In addition, the Council has also looked to explore whether neighbouring authorities could meet any of its housing needs. the recent consultation for the “Issues and Options” paper opened the debate on this matter. It is apparent from the consultation and review of relevant evidence base studies that many authorities within Merseyside are in a similar position, or are at best only able to cater for their own development needs. The exception in this context is Liverpool MBC as their SHLAA indicates an oversupply of approximately 3,000 dwellings, which in terms of numbers would be insufficient to meet the outstanding needs of all neighbouring districts. In order to explore this issue matter further, an ‘Overview Study’ has been jointly commissioned by the Merseyside authorities. This will look to examine whether the needs of any one Merseyside authority can be met within the boundaries of another. The findings from this study will feed into our emerging Core Strategy within the sub-region.
Given the scale of the shortfall, and likelihood that all Knowsley’s development requirements will not be met by other means, the Council in partnership with Sefton MBC has jointly commissioned a Green Belt Study, with West Lancashire Borough Council adopting a similar methodology in a shadowing role. The purpose of this Study is to identify broad locations that might be suitable for meeting our future housing and employment needs. It should be noted however that this study does not represent a review of the Green Belt at this stage, nor does it necessarily mean that land will be released from the Green Belt following its completion. This could only occur following a sub-regional review of the Merseyside Green Belt, and a future review of the Regional Strategy. However, it may identify some sites which could be released as ‘non-strategic’ Green Belt via the Local Development Framework process.
In addition, Knowsley is committed to delivering affordable housing and meeting specific housing needs within the Borough. As a result, in February 2010, Knowsley Council commissioned David Couttie Associates to complete a Strategic Housing Market Assessment (SHMA) for Knowsley. This document a key piece of evidence for Knowsley’s Local Development Framework as well as for the Council’s housing strategies. It is also envisaged that the document will be of use to the Council’s partners, such as Registered Social Landlords, in progressing their policies and programmes.
The SHMA involves a detailed assessment of the current housing market in Knowsley, including consideration of influences such as demographics and population change, household formation and trends, housing supply and demand, employment and commuting as well as market statistics about house prices and affordability. Using this data, the SHMA makes recommendations about the type, size and amount of housing which is required in Knowsley, and also includes policy recommendations to address existing imbalances, improve the housing offer across all sectors and deliver affordable housing.
The production of the Knowsley SHMA has been overseen by a Strategic Housing Market Partnership Board and wider stakeholder group. Subsequent to a period of stakeholder and public consultation, it is anticipated that the Knowsley SHMA will be finalised by mid-2010. Hence, along with other evidence base documents such as the SHLAA and Housing Needs Assessment help to form a comprehensive understanding of the current and likely future housing market in Knowsley.
Risk assessment of obstacles and constraints to housing delivery
In assessing Knowsley’s potential housing land supply, it is recognised that unforeseen circumstances or obstacles may arise that may prevent sites from coming forward for development. Accordingly, Knowsley’s SHLAA carried out by consultants White Young Green (WYG) consider that it is appropriate and robust for a ‘risk assessment’ to reduce the housing supply provided by sites with planning permission and those identified by the SHLAA by a factor of 20%. Put simply, this assumes that (on average) one in five of the sites assessed will not be delivered as anticipated and that 20 out of every 100 dwellings currently permitted will not be completed.
The headline obstacle and to housing delivery in Knowsley are considered to be the current economic climate. Developers are generally reluctant to invest resources in new development in the current financial uncertainly. The Council is committed to facilitating development where this is feasible, however the wider economic conditions are generally beyond the Council’s control. The Council and its partners have employed the following measures to increase housing delivery:
- Knowsley Housing Trust (KHT) continues to invest in its core stock and will invest a further £236M over the life of its current business plan in keeping its customers homes decent. The 2010/11 investment programme will invest £22M delivering new homes, improved central heating systems, improved and new fencing, the continuation of improvements to previously declared surplus maisonettes and flats now being refurbished and converted to family homes.
- Effective performance of the planning system, including the encouragement of pre-application discussions to iron out potential issues before an application is submitted and the promotion of land available for development. Alerting developers to the availability of land for development through the Borough’s published SHLAA.
- Continuous engagement with the Homes and Communities Agency (HCA) to increase the supply of affordable homes in Knowsley.Since 2008, and running until 2011, the Homes and Communities Agency will have invested £8.4bn nationally in affordable housing through the National Affordable Housing Programme (NAHP). The programme’s development partners will deliver 155,000 new homes and each year. Knowsley aims to work alongside Registered Social Landlords and developer partners to further encourage development in the borough to ensure a sustainable mixed community.
Engagement with House Builders and Key Stakeholders
The Council has engaged key stakeholders and the community from the outset of production of the Core Strategy and associated evidence base. The Local Development Framework team maintains a database of interested parties and stakeholders and they are regularly invited to comment on Local Development Framework documents. The Council has also involved stakeholders through Core Strategy workshops, public meetings, regular updates on the Council’s website
A SHLAA steering group was set up at the outset of the study to engage key stakeholders such as housebuilders, RSLs, neighbouring local authorities and representatives from GONW and 4NW. The steering group met during the formulation of the study methodology, and also during the public consultation to discuss the interim findings. A significant number of the group also made formal representations to the consultation exercise. Correspondence has also been sent to the members of the steering group now that the study has concluded asking members to collectively ‘sign off’ the study. Any disagreements with the methodology or findings will be formally recorded.
In addition, the SHLAA included two ‘Call for Sites’ exercises where landowners and developers were encouraged to submit sites for consideration through the study, in total just over 60 sites were submitted. Respondents to this exercise were asked to fill in a proforma, which identified theowner’s intensions, outstanding constraints, and the overall deliverability of the site. This process will be repeated periodically as the SHLAA is reviewed.
The Council also encourages the use of pre-applications discussions with developers for all major or potentially contentious schemes.
Monitoring and review of actual housing delivery performance
The Council has utilised a development (residential and industrial) monitoring system which provides comprehensive and detailed data development in the Borough. It is used to capture information on housing permissions and completions, on new build and conversion sites, dwelling demolitions and lapsed permissions. The information is reported each December in the Annual Monitoring Report (AMR).
An updated 5 year supply position and housing trajectory is included in the AMR each year, showing gross and net housing completions and an estimate of future housing delivery in relation to the RSS housing requirement. The AMR also presents an update on the SHLAA process.
Management Actions
As outlined earlier, the Borough is likely to have a housing land shortage in the medium to long term. As a result, the Council has sought to open the debate on this matter via the Core Strategy “Issues and Options” consultation and begun work investigating other sources of supply such as surplus public open space and potential “broad locations” for longer term development requirements.