Five Year Housing Land Supply Statement 2024

1. Background
 

1.1. The National Planning Policy Framework (NPPF) states that local planning authorities must identify a deliverable five year supply of housing sites in March 2012, revised in July 2018, updated in February 2012, revised in July 2021, updated in September 2023. It was then revised in response to the Levelling-up and Regeneration Bill: reforms to national planning policy consultation on 19th December 2023 and most recently on 12 December 2024 in response to Proposed reforms to the National Planning Policy Framework and other changes to the Planning system consultation.

1.2. Guidance is contained in both the NPPF and the National Planning Practice Guidance (NPPG) for housing and economic land availability assessments last updated in July 2019. The preparation of a Strategic Housing Land Availability Assessment (SHLAA) is a requirement of the NPPF with guidance provided in the NPPG. The SHLAA is a technical study that assists in the monitoring of whether there is an adequate supply of deliverable housing land at any point in time.

1.3. The process of being able to demonstrate a five-year housing land supply in Leeds has been a historical challenge. The Core Strategy was originally adopted in 2014 and set a housing requirement of 70,000 (net) new dwellings in the period 2012 to 2028. The requirement led to the need for land allocations for 66,000 new homes, meaning the release of Green Belt sites was necessary at the time. In response, the Site Allocations Plan (SAP) proposed to release the largest level of land allocations for housing in the country. The SAP was subject to a legal challenge and the Green Belt housing allocations were subsequently removed through the SAP Remittal process and adopted by the Council on 17th January 2024.

1.4. Following the adoption of Core Strategy (2014) on 12th November 2014 and prior to the release of land allocations through SAP on 12 July 2019, a near five-year period was characterised by a succession of housing land supply challenges, initially to the presence of a five-year housing land supply and then to disputes over the extent of the shortfall at eleven public inquires. Throughout this period, the Council had worked hard to strengthen its land supply through both plan-making and decision taking activities.

1.5. The Council has reflected and updated this position to a base date of 1st April 2024. This statement reflects to up-to-date assessment of sites as part of the 2023 SHLAA. The 2024 SHLAA takes account of new planning permissions and construction activity to a base date of 1st April 2024.

1.6. The Council has granted more planning permissions for housing over the past five years than at any time. The number of homes approved are now well above the City’s housing requirement figures. Approvals have been granted for 53,094 new homes since 2017, well in excess of the target for the same period.

2. National Policy
 

National Planning Policy Framework

2.1. The NPPF states that the purpose of the planning system is to contribute to the achievement of sustainable development. For housing, this means providing the supply of housing required to meet the needs of present and future generations.

2.2. Local planning authorities are required to prepare a SHLAA in order to establish realistic assumptions about the availability, suitability and achievability of land to meet the identified need for housing over the plan period.
 

2.3. The NPPF states that local planning authorities must identify a deliverable five year supply of housing sites. The NPPF states that to be considered deliverable, sites 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 and in particular that development of the site is viable.

2.4. The NPPF identifies the need to consider:

• A supply buffer – dependent upon performance against the Housing Delivery Test, local planning authorities are required to include an additional allowance or 'buffer' of five percent (moved forward from later in the plan period) in terms of supply to ensure choice and competition in the market for land. Local planning authorities with a record of been significant under delivery of housing over the previous three years should apply a 20 percent buffer (Paragraph 78).
• Windfall sites - local planning authorities may make an allowance for windfall sites in their five year supply if they have compelling evidence such sites have consistently become available in the local area and will continue to provide a reliable source of supply (Paragraph 75).

2.5. Footnote 8 to Paragraph 11 of the NPPF states that relevant policies for the supply of housing should not be considered up to date if the local planning authority cannot demonstrate a five year supply of deliverable housing sites.

National Planning Practice Framework and Guidance

2.6. The National Planning Policy Framework was published on 27 March 2012 and sets out the government’s planning policies for England and how these are expected to be applied. A new version of the National Planning Policy Framework was published on 24 July 2018, updated on 19 February 2019, revised on 20 July 2021 and updated on 5 September 2023.

2.7. The NPPG provides clarity on what constitutes a deliverable site. Annex 2 (updated on 19 February 2019) of the NPPF defines a deliverable site in terms of an assessment of the timescale for delivery and the planning status of the site and adds further detail as to the evidential requirement needed on sites without a detailed planning permission…“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. In particular:

• a) sites which do not involve major development and have planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within five years for example because they are no longer viable, there is no longer a demand for the type of units or sites have long term phasing plans).
• b) where a site has outline planning permission for major development, has been allocated in a development plan, has a grant of permission in principle, or is identified on a brownfield register, it should only be considered deliverable where there is clear evidence that housing completions will begin on site within five years.”

2.8. Case law1 has determined how to interpret that definition and confirms that:

"The proper interpretation of the definition is that any site which can be shown to 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' will meet the definition; and that the examples given in [the NPPF] are not exhaustive of all the categories of site which are capable of meeting that definition. Whether a site does or does not meet the definition is a matter of planning judgment on the evidence available."

2.9. The Council has produced clear evidence across all sites as part of the SHLAA process, thereby satisfying the NPPF approach. It has always been important to confirm an accurate position of housing land supply by identifying any factors leading to either delay or acceleration of house building on sites. This includes confirmation of any availability or ownership issues that would impact on the delivery of a site.

2.10. The Council has contacted landowners, developers and agents involved in the delivery of sites in order to collate new evidence and establish a dialogue on delivery in order to make informed decisions as to how sites contribute to the future supply of housing in Leeds.

2.11. Paragraph 26 of the NPPG directs authorities to use evidence set out in the SHLAA to identify sites which may be suitable, available and achievable for housing development and also provide some evidence as to their deliverability. The 2024 SHLAA accords with both the revised NPPF and the NPPG.

1 East Northamptonshire Council and Secretary of State for Housing, Communities and Local Government and

Lourett Developments
 

3. The requirement
 

3.1. The starting point for establishing a five year supply requirement is the housing target identified in strategic policies for the first five years of the plan. Paragraph 78 of the NPPF states that “Local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of 5 years’ worth of housing”.

3.2. The Council recognises the local housing need figures as part of the standard methodology to which a 35% uplift for urban centres applies in Leeds. In line with NPPG, the housing requirement figures in adopted Local Plans should continue to be used for the purposes of calculating five-year housing land supply until such time as the plan is reviewed or the five-year review period has passed.

3.3. The requirement figure for housing was the adopted Core Strategy (2019) and in use for performance purposes until it is either replaced as part of a local plan update with a new requirement or upon the adopted target becoming 5 years old on 11 September 2024. It is now replaced by the Government’s methodology for Local Housing Need (LHN) with a 35% uplift for the 20 largest Cities and Urban Centres in England. Whilst the Core Strategy requirement was less than 5 years old at the base date of the 2024 SHLAA on 1 April 2024, the Council has decided to use the LHN requirement as it is in place within the first year of the SHLAA and at the time of publication.

3.4. On 30 July 2024, the Government’s proposed reforms to the NPPF included an update to the ‘standard method’ taking an approach to increase existing stock and incorporate an uplift based an increased affordability multiplier. The changes also propose to remove the requirement for an ‘urban uplift’, which applies to Leeds.

3.5. The proposed calculation generated a target of 4,159 per annum for Leeds, which was more than the Core Strategy target (3,247 per annum) or what the standard method previously generated (3,022 per annum). The urban uplift generated a figure of 3,987 using the latest ONS affordability ratio released in March 2024, which was the housing requirement between 11 September 2024 and 12 December 2024.

3.6. On 12th December 2024 the Government published the revised NPPF which sets a new Standard Method for assessing housing needs. The figure for Leeds is 3,811 new homes per annum. The current requirement in December 2024 is 3,811 per annum.

3.7. The delivery and associated undersupply for the first five years of the plan (1st April 2017 to 31st March 2024) are:

• Net Delivery: 1st April 2017 to 31st March 2024 = 22,682
• Requirement: 1st April 2017 to 31st March 2024 = 22,729
• Undersupply: 1st April 2017 to 31st March 2024 = 47

3.8. The mechanics of the Housing Delivery Test determine the buffer to be applied to the requirement figure and the transitional arrangements are set out in NPPG. The Council’s delivery in line with paragraph 78 of the NPPF means a 5% buffer has been applied to ensure choice and competition in the market (where there delivery of housing over the previous 3 years, has not fallen below 85% of the requirement). This buffer is applied to the housing requirement and the shortfall since the start of the plan.
 

3.9. For the five year period 1st April 2024 to 31st March 2029, the calculation is as follows:

• Baseline Requirement: 2024 to 2029 = 5 x 3,811 = 19,055
• Undersupply: 2017 to 2024 = 47
• Base Requirement + Undersupply = 19,102
• 5% Buffer = 955
• Base Requirement + Undersupply + 5% Buffer = 20,057

3.10. The total adjusted five year requirement for the period 1st April 2024 to 31st March 2029 stands at 20,057 dwellings, a requirement of 4,011 dwellings per annum.
 

4. The SHLAA 2024
 

4.1. The NPPG provides information to help local authorities fulfil their responsibilities under paragraph 72 of the NPPF. As well as establishing a five-year supply position to support the preparation and examination of Local Plans, the NPPG confirms that the supply position should be updated annually.

4.2. The preparation of the 2024 SHLAA reflects the most up to date guidance available, including the NPPG. In particular, the NPPG provides more detailed advice for carrying out a SHLAA, noting that it should:

• identify sites and broad locations with potential for development;
• assess their development potential; and
• assess their suitability for development and the likelihood of development coming forward (the availability and achievability).

4.3. The Council have finalised the 2024 SHLAA and have contacted agents, landowners, developers and promoters of sites to comment upon the availability and achievability of each site to update the SHLAA according to the most up-to-date information available on a site-by-site basis. The Council has obtained detailed site-specific information that informs assessments of deliverability as advocated by Inspectors and the Secretary of State.

4.4. The sites included in the five-year supply satisfy the requirements of paragraph 72 of the NPPF and NPPG. The Council uses the information it has on suitability, availability, achievability and constraints to assess the timescale within which each site is capable of development.

4.5. The Council has contacted landowners as part of considering the availability of sites adopted under the Aire Valley Area Action Plan, and allocated under the Site Allocation Plan and as part of informing overall ‘deliverability’, including the “realistic prospect that housing will be delivered within five years”.

4.6. The Council confirms that no site included within its supply discloses any legal or ownership constraint, militating against the realistic prospect of delivery or overall deliverability.

4.7. The Council has properly taken into current housing market conditions. The Council consulted with the Home Builders Federation, landowners, agents and developers recognising that the changes posed to the housing market by the pandemic has created both challenges and opportunities for different types of sites. It was important that landowners confirmed whether the assessment reflected an accurate picture of delivery. Updated construction programmes were received and accurately recorded in the update and observations were welcomed on the capacity of the industry to deliver in the short, medium and long term.

4.8. The housing market in Leeds has seen continued and marked improvement in the last few years. National and international developer interest is continuing to grow and that the planning pipeline is strong with numerous high-rise developments both under construction and in planning. The outstanding stock of planning permissions is at the greatest ever level and Leeds remains firmly in ‘growth mode’ and is committed to additionality, and to accelerating delivery of the housing requirement in line with the Core Strategy and growth strategies.

5. The Five Year Housing Land Supply

5.1. The 2024 SHLAA update shows 24,764 units in the short term across 173 sites. To strengthen the five year supply position to the greatest level of certainty in deliverability terms, all sites in the short-term are either currently under construction or have detailed planning permission.

5.2. Policy compliant deliverable supply of 24,764 is comprised of:
 

5.3. The SHLAA identified sites provide 6.2 years of supply. With the inclusion of windfall at 500 per annum (adopted Core Strategy), and the discount of demolitions the total overall supply is 6.6 years:
 

6. Conclusion
 

6.1. The Council has undertaken an NPPF compliant update to the SHLAA reflective of realistic build out rates, the capacity of the industry to run a maximum number of outlets, reflections on previously disputed sites and the discount of sites subject to expired planning permissions with no current planning activity. The update accurately reflects the submissions made through the HBF consultation and on-going dialogue with landowners, agents and developers.

6.2. The level of housing land supply in Leeds is 6.6 years.