Tewkesbury Borough Council Housing Supply Update
On 15th September 2023, Tewkesbury Borough Council (TBC) pledged to “urgently review the council’s housing position following a new development being approved at appeal”. Yesterday (18th October 2023) TBC published their Five Year Housing Land Supply Statement (5YHLS Statement).
The 5YHLS Statement updates the Housing Land Supply Statement published by the Council in March 2023. According to TBC this statement takes into account housing monitoring data from 1st April 2022 – 31st March 2023.
In the 5YHLS Statement, TBC now formally accept that that there is a significant shortfall in their housing land supply as follows:
- Housing land supply in the borough stands at 3.24 years.
- The total deliverable supply of homes is 1,892 when a buffer of 5% is applied (as required by the National Planning Policy Framework (NPPF)). This is against a minimum housing need of 2924 dwellings.
- This means that TBC has a shortfall of 1032 dwellings.
Welcome news for Developers
This will all be welcome news to developers with sites in the borough. Having a lack of five year supply renders policies for the provision of housing out of date. Paragraph 11(d) of the NPPF states that where this is the case, planning permission should be granted for a proposed development unless;
- the application of policies in this Framework that protect areas or assets of particular importance provides a clear reason for refusing the development proposed; or
- any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.
This test is known among planners as the tilted balance. This is because the judgement which local authorities need to exercise when determining an application for planning permission is effectively ‘tilted’ in favour of granting planning permission, as opposed to starting from a neutral position. It is worth being aware that there are certain caveats and exceptions to this. We can advise on these as and when they relate to specific sites.
‘Interim Housing Position Statement’ to follow
TBC has confirmed that “to assist decision making on planning applications for housing and the consideration of relevant policies the council will be publishing Interim Housing Position Statement later in Autumn.” It is suggested, given the context, that this will focus on relevant policies for the provision of housing and how the tilted balance factors into those considerations.
The document contains detailed appendices setting out the delivery trajectory for five-year period 2022/23 to 2026/27 to support the calculations included in the 5HLS statement. The Council will need to keep the sites listed in the appendices under review. If any permissions expire or the developments authorised by those permissions are no longer viable, they may have to be discounted from the housing land supply in the future. Therefore, the position has the potential to change again relatively quickly. We aim to keep on top of any changes as they arise.
What about the Joint Core Strategy (JCS)?
Alongside this report, TBC, along with Cheltenham Borough and Gloucester City Councils are producing the next iteration of the Joint Core Strategy, now known as the Strategic and Local Plan (SLP). One aim of this will of course be to allocate sufficient housing sites to meet the needs of all three areas. However, the local development scheme setting out the timetable for preparation of the SLP identifies a target date of April 2026 for submission of the draft plan to the Secretary of State. It will take some time after that before the SLP can be adopted. As a result, we expect there to be potential housing land supply issues within all three local authority areas for some time.
Our team are keeping this under review so that we can update our clients as soon as possible after changes occur. Please get in touch if we can help you with a potential housing development in Tewkesbury borough, or if you would like longer term ongoing updates or advice about the housing land supply situation in the area.
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