2. Five-year housing land supply position

2.1. The following paragraphs and tables set out New Forest District's (outside the National Park) five-year housing land supply position for the period 2024/25-2028/29.

Baseline housing target

2.2. The New Forest District (outside the National Park) Local Plan 2016-2036 Part 1: Planning Strategy was formally adopted on 6 July 2020. The adopted Local Plan is less than five years old and is therefore used as the baseline for calculating the Council's housing land requirement for the five-year housing land supply assessment in this report.

2.3. The adopted Local Plan 2016-2036 Part 1: Planning Strategy seeks to deliver a new housing requirement of at least 10,420 (net) dwellings for the period 2016-2036. Policy STR5 sets out a stepped housing target as follows:

• 2016/17 to 2020/21 - 300 dwellings per annum
• 2021/22 to 2025/26 - 400 dwellings per annum
• 2026/27 to 2035/36 - 700 dwellings per annum

2.4. The annual housing target for the years 2024/25-2028/29 is as follows in Table 1.

Table 1: Housing Target 2024/25 to 2028/29

Dwelling completions 2016/17 - 2023/24

2.5. In the period 2016/17 to 2023/24 2,179 dwellings were completed (as set out in Table 2 overleaf). This is 521 dwellings below the housing requirement for that period as shown in the table below. The Planning Practice Guidance states that a deficit or shortfall in housing delivery will need to be calculated from the base date of the adopted Local Plan and should be added to the Local Plan requirements for the next five-year period (the Sedgefield approach), then the appropriate buffer should be applied. Accordingly, therefore, the shortfall of 521 dwellings will be added to the five-year housing target of 2,900 dwellings.

Table 2: Net completions 2016/17 to 2023/24

Buffer

2.6. The NPPF (paragraph 78) requires a buffer of 5% to be applied to the five year housing land requirement to allow for choice and competition in the market. The buffer should be increased to 20% where delivery of housing over the previous three years has fallen below 85% of the requirement, as set out in the last published Housing Delivery Test results.

2.7. The most recent Housing Delivery Test result released by the Government was the 2023 Housing Delivery Test covering the period 2020/21-2022/23. This was published by the Government on 12 December 2024. The published results show that the Council achieved a score of 75% in the Housing Delivery Test 2023 Measurement. This is below the threshold of 85% below which the buffer of 20% should be added to the five-year housing land supply requirement.

2.8. On that basis therefore, under the terms of the NPPF (Paragraph 78), the appropriate buffer to apply for the purposes of this five-year housing land supply assessment is the 20% buffer.

2.9. The Council prepared a Housing Delivery Action Plan in May 2024 to seek to positively respond to the challenge of improving housing delivery and supply in the Plan Area. The Housing Delivery Action Plan sets out the reasons for the challenges faced in terms of housing delivery and supply in the Plan Area and outlines the actions the Council intends to take to seek to encourage increased housing delivery in the Plan Area.

Housing supply

2.10. This section summarises the components that comprise the supply of deliverable housing land to meet the five-year housing land requirement. This is done in accordance with the requirement of the NPPF which states that to be considered deliverable, sites for housing should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years.

2.11. The components that have been included towards the five-year housing land supply within New Forest District (outside the National Park) are:

• Large sites (sites of 10 dwellings or more) including Local Plan 2016- 2036 Part 1 strategic sites and other allocations and permissions that are considered to meet the NPPF definition of deliverable
• Small sites with planning permission (sites of less than 10 Dwellings)
• Sites that have planning permission for C2 use
• An allowance for small site windfalls

Large sites (sites of 10 dwellings or more) including Local Plan 2016-2036 Part 1 strategic sites and other allocations and permissions that are considered to meet the NPPF definition of deliverable

2.12. Large sites are included in the assessment of five-year housing land supply where there is a realistic prospect of delivery in the period 2024/25 to 2028/2029. Large sites with detailed planning permission are, as set out by the NPPF, considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within five years. Housing completions from large sites without detailed planning permission have been included within the five-year housing land supply period where it is considered that there is clear evidence that housing completions will begin on site within five years. The justification for the phasing of each site is set out in the housing trajectory for the Plan Area (Table 7) at the end of this report.

2.13. Research/analysis undertaken by Hampshire County Council at a County level on past trends for average build-out rates and lead-in times for sites of 100 to 399 dwellings concludes that there is an average lead-in time of 1.6 years from grant of detailed planning permission to first completions and there is an average build-out rate of 52 dwellings per annum per site. This average lead-in time and build-out rate informs the housing trajectory.

2.14. For large sites that as of 1 April 2024 did not have either a planning permission or a resolution to grant planning permission, the adopted Local Plan allocation estimate of site capacity is used for the purposes of this housing trajectory.

Small sites with planning permissions (sites of less than 10 dwellings)

2.15. Existing unimplemented planning permissions for sites with a net gain of less than 10 dwellings (small sites) also contribute to the five-year housing land supply. Schemes with planning permission that fall below this threshold are considered collectively. Rather than site by site phasing for these schemes, a 10% discount has been applied to the outstanding net gain in dwellings to take account of the potential level of uncertainty regarding the exact number of permissions that will be implemented. This approach is considered to provide an appropriate level of confidence and degree of flexibility in the figures. The supply and phasing expected from permissioned small sites is set out in Table 3 below.

Table 3: Housing capacity from small site commitments

Permissioned sites for Use Class C2 care homes

2.16. The Planning Practice Guidance for specialist housing for older people was updated in 2019 and indicates that plan-making authorities may count provision for older people in Class C2 against their housing requirement. To establish the amount of accommodation released in the housing market, the guidance indicates that authorities should base calculations on the average number of adults living in households using the published Census data.

2.17. The published Census 2011 data indicates that that there is an average of 1.8 adults living in households in New Forest District. A ratio of 1.8 has therefore been applied to Class C2 care home accommodation. Comparable data to a local authority level has not yet been published as part of the 2021 Census, with the PPG still linking to the 2011 data. We will update the figures in accordance with the PPG once available.

2.18. The published Census 2011 data indicates that that there is an average of 1.8 adults living in households in New Forest District. A ratio of 1.8 has therefore been applied to Class C2 care home accommodation. Comparable data to a local authority level has not yet been published as part of the 2021 Census, with the PPG still linking to the 2011 data. We will update the figures in accordance with the PPG once available.

2.19. The table below sets out the sites within the Plan Area that have planning permission for care home accommodation. This totals 138 bedrooms. Applying the established ratio of 1.8 to this equates to 77 dwellings released on the housing market. In accordance with the Planning Practice Guidance, 77 dwellings are therefore included within the five-year housing land supply as both sites have full planning permission and meet the NPPF definition of deliverable.

Table 4: Sites with planning permission for care homes

Small site windfall allowance

2.20. The following paragraphs provide information on the estimated contribution to the Local Plan's five-year housing land supply arising from windfall development.

2.21. The NPPF defines windfall sites as those which have not been specifically identified as available in the Local Plan process. Paragraph 75 of the NPPF advises that local authorities may make an allowance for windfall sites in the five-year supply if they have compelling evidence that they will provide a reliable source of supply.

2.22. Table 5 below shows historic delivery on small site windfalls (sites delivering between 1 and 9 dwellings) over the last 10 years. This analysis of housing completions indicates that an average of 85 dwellings per annum was delivered through small site windfall development. This indicates the consistently strong contribution small site windfall development makes to housing delivery in New Forest District.

Table 5: Small site completions since 2014/15

2.23. In recent years, the Government has introduced a range of new permitted development rights that allow for greater flexibility of change of use. Permitted development rights now allow some commercial, office, light industrial, storage/distribution and agricultural premises to be converted to housing without the need for planning permission. Given this and past rates of delivery on small site windfalls, it is therefore clear that small site windfalls will continue to provide a reliable source of future supply.

2.24. The small site windfall allowance was tested during the last Local Plan examination and, in their Report on the Examination, the Inspectors examining the Local Plan concluded that the estimate of 77 completions per year on small windfall sites (less than ten dwellings) "is reasonable and realistic in light of past trends and given the potential for rural exceptions sites and schemes through permitted development rights".

2.25. Based on this analysis, the Council considers it justifiable to include an allowance for small site windfalls in the five-year housing land supply period of 44 dwellings in 2027/28 (reduced from 77 to avoid double counting with existing permissioned small sites that are projected to deliver 33 dwellings in 2027/28) and 77 dwellings in 2028/29.

Five-year housing land supply assessment for the period 2024/25 to 2028/29

2.26. This assessment set out in Table 6 below shows that the Council cannot demonstrate a five-year housing land supply for the period 2024/25 to 2028/29 with the supply being 2.39 years. Table 7 overleaf shows the housing trajectory and the specific sites that are included within the five-year housing land supply period and the justification for their inclusion.

Table 6: Five-Year Housing Land Supply Calculation for the period 2023/24- 2027/28