What counts towards the housing supply? - Public forum - Planning Advisory Service (PAS)

My view would be that  if C2 uses count towards meeting housing needs - and it is now clear that they do - there is no reason to understate your housing delivery figure by excluding C2 completions from the beginning of  the plan period. What would be the logic for so doing?

There is further information from DCLG on definitions which may assist you at:

https://www.gov.uk/definitions-of-general-housing-terms

Information they supply as part of completing the Housing Flows Reconciliation Form would also assist.  My understanding from past conversations with CLG is that HMOs do count and should be recorded.  But you need to take full account of advice around self-containment and how these properties are taken into account by the Valuation Office.  So an HMO for 6 people is only 1 property.  This applies to the correct recording of student accomodation as well.  Does the VO regard these as separate self contained units, cluster flats or simply a hall of residence.  In the case of the first two of these, they can count, a hall of residence as with a nursing home does not.  Straight communal accommodation such as a nursing home or student hall is not included within your annual net completion figures and therefore not within your AMR figures in terms of general housing supply.

Of course this advice does not appear to be fully in line with NPPG and the guidance is silent on how to actually count numbers, so some ambiguity will remain...communal accommodation is not included in net completions but it can be included within the assessment of supply in local plans.  I would return to the CLG return for the more detailed view and that places weight on how the VO has listed a property be it a student hall or care home.  Clearly there is a planning argument that communal accommodation will have met needs for conventional housing.  I suspect the bottom line in this is you will not be able to defend a land supply position which has relied too much on "unconventional" housing such as care homes or student halls when challenged about delivery of "more normal" market housing. 

I've been thinking about this recently too.

If you read paras 37 and 38 there are subtle differences in the wording. I don't know whether this is deliberate or whether it's just bad consistency in the PPG.

Para 37 (C2) talks about counting C2/resi institutions AGAINST your REQUIREMENT. Then it says you could allocate sites. So this is really talking about NEED? It is certainly talkign about allocating sites.

On the other hand Para 38 (Stundents) uses a different wording saying that ALL student accommodation can be counted TOWARDS the housing REQUIREMENT.

This inconsistency makes it very confusing. Is the use of 'against' and 'towards' deliberate?

My only thoughts are that whatever you do you are measuring how many new homes/dwellings are provided against and objectively assessed need. So you need to count NET and include losses. Therefore if you have a C2 institution demolished/lost during the plan period then you count it as a loss. If you are goign to argue that every single bedroom in a C2 is equivalent to one dwelling as a gain to the stock, then you have to do the same for losses.

On student accommodation the PPG is a bit clearer and I'd say that you could look at student sharing rates in the private rental market. Say, for example the average student house has 3 students in it, then if you get new halls built you could count 1 dwelling for every 3 beds? That would sound logical. Student accommodation is also often provided as cluster flats now so you could count 1 cluster as 1 dwelling.

It's all a bit messy really and the PPG has not helped to clear up the detail other than to say you can count these types of development (I think)!!