5 Year Land Supply Requirements As Of April 2011 - Public forum - Planning Advisory Service (PAS)
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5 Year Land Supply Requirements As Of April 2011
I'm hoping many readers have now had chance to read the Letter to Chief Planning Officers from Bob Neill dated 30th March 2011 (I'm afriad I can't find a link on the web to provide a copy). It's title is: "Letter to Local Authority Chief Planning Officers on preparation and monitoring of local plans" This announcement has left us in an even bigger quandry about how to produce a 5 Year Land Supply from April 2011. Firstly, you may have noted that in the government's 'Data Burdens' review, the intention was to remove the need to produce a separate 5 Year Land Supply as this would be covered under the COIs. The documentation is available here: http://www.communities.gov.uk/localgovernment/decentralisation/tacklingburdens/databurdens/ I'm unclear as to whether this review is complete (ditto full revocation of the NIs) but I'm under the impression both take effect as of tomorrow. I took this initial decision to mean that separate 5 Year Land Supply schedules no longer need to be prepared, but targets and performance would be calculated in the usual way under COI guidance. What are other thoughts on this? However, after yesterday's announcement by Bob Neill, the COIs have been revoked and so a Five Year Land Supply is now very difficult to report. I'm sure the initial Data Burdens review didn't see that coming. PPS3 remains in place, so the principle of a 5 Year Supply of deliverable land remains. By this I mean using Para. 33 to establish the requirement (be that following RSS or another calculation of need / achievability) and developing the trajectories etc. required, plus the implications for determining planning applications in paras. 68-74. It is notable that some of the priniples underpinning the delivery of a 5YLS (i.e. Plan Monitor Manage) have been part removed through the impact of guidance revoked yesterday! But, without the COIs is there an explicit need to report the 5 year supply against a given dwellings target with all the weight that can be given to this in planning decisions? If so, I can't see much option other than using the old COI method of calculation, making revocation inconsequential in this case. My suspicion is this is another example of trying to weaken the case for housing targets, but with PPS3 in place surely this fundamental requirement remains. How are people planning to proceed over this year.
Sadly, I think we will still be continuing to monitor the 5 year supply, whether there is monitoring guidance or national indicators to require it or not. Until it is removed from PPS3 I don't think this will make any difference.
As far as I can tell, the gist of the Government's approach on this is to reduce the burden of having to report certain statistics to central government, and not necessarily to stop producing those statistics in the first place. It still seems highly appropriate, to me, that all councils continue to monitor their housing supply, and that to achieve consistency and accountability the same periods and methodologies should be used, especially across housing market areas. I certainly hope that the need to keep an eye on supply is not dropped from PPS3. Eventually, all council statistical data of this sort needs to be available in an open source form, so that is it easy for third parties (eg. at appeal) to go over the raw figures.
I don't think that the inclusion of any specific 'burden' on the spreadsheet in the burdens review means that the government is intending to remove it. The spreadsheet simply lists a large number of existing requirements and is inviting comments. Previously the government has said it is committed to keeping the 5 year land supply requirement, so I think this particular aspect of PPS3 is here to stay either in its present form in the new NPF. FYI, there is a new government 'barrier busting' website which appears to be another attempt to invite suggestions to remove red tape etc
Thanks for the help so far. Good to see some agreement that PPS3 should be the overriding force in this case and hence a 5 Year Land Supply should still be displayed and demonstrated. For the record, Five Year Land Supply is now removed from the spreadsheet in my link in the original post, hence conspicuous by it's absence. It's removal can be charted on the 'changes' tab of that spreadsheet. Given that the COIs are now revoked too, this leaves a void in how the 5YLS must be demonstrated in my view. I'm happy that the fundamental PPS3 requirement remains but for me these announcements create a string of mixed-messages about how targets need to be demonstrated. I suspect the requirement for a 5YLS won't disappear from PPS3 and will be re-emphasised at some stage, especially given what some members of the coalition have said re: growth. However, the most recent announcements pander more to Localism and there may be some creative new ways of calculating 5YLS's in the near future. Such is the clash between the two agendas. I'd love to hear any more comments.
I know some authorities are continuing to express a 5 year land supply against annual RSS targets, as required by PPS3, in an annual monitoring report. However, others are expressing a five year land supply but not as annual figures against RSS targets, showing instead a total figure over the whole 5 year period. And not publishing an annual monitoring report, but instead publishing a five year land supply statement on the web. Harriet
Now really quite confused. The final version of the Single Data List (see: http://www.communities.gov.uk/localgovernment/decentralisation/tacklingburdens/singledatalist/) retains a requirement to report the COIs. Granted, they are under review but as I read it they still apply for 2011-12. This seems to run in contrast to the Bob Neill letter that formally revoked their guidance / requirements. Strikes me that CLG realise you can't revoke the COIs and Five Year Land Supply (as a separate collection) and still get any sense from demonstrating a 5 Year Land Supply as required by PPS3. Not sure everyone else in government does.
I think the guidance being withdrawn only means that you now have more of a choice of whether to use it as, you know, a "guide". I suspect this is going to happen all over the place (and we, for our part, will produce something on new-look local AMRs soon). That said, you still have duties under PPS3, and presumably more/less/the same duties under the NPPF and need to ensure that your monitoring reflects them. As the letter says "[...] we intend to proceed with a package of measures to free up local authorities by removing red tape and streamlining policy on local plans. It is therefore a matter for each council to decide what to include in their monitoring reports while ensuring that they are prepared in accordance with the relevant legislation. " The single data list is (as far as I can see) a similar-feeling but quite different issue.