Persimmon Homes (Wessex) Oxfordshire Growth Board Representations to the Housing Land Supply Consultation July 2018
2 Copyright 2018 Persimmon Homes Ltd. All rights reserved. The material contained in this document remains the property of Persimmon Homes. No part of this document may be reproduced, copied, photocopied, translated, stored in, or converted electronically into a retrieval system, or transmitted, in any form, or by any means without prior written permission of Persimmon, or as specifically detailed in any supplementary Licence Agreement issued by Persimmon Homes Ltd. Produced by Persimmon Homes Wessex. Verona House Tetbury Hill Malmesbury Wiltshire SN16 9JR Revision: 2 Document Status: Planning Release Date: 9 July 2018 Author: JP Checked by: CM, TW, LC
3 CONTENTS Introduction... 4 Q1... 5 Q2... 7
4 INTRODUCTION We write with reference to the above and welcome the opportunity to submit comments on the housing land supply consultation being undertaken by the Oxfordshire Growth Board. Please treat this as our formal representations, duly made within the consultation period. Building around 12,000 new homes a year in more than 400 locations nationwide, Persimmon is one of the UK s leading house builders, committed to the highest standards of planning, design and construction. Persimmon Homes is actively engaged with the delivery of various strategic and nonstrategic mixed-use and residential schemes in Oxfordshire so is well placed to comment on this consultation. The consultation proposal is as follows: A 3-year land supply, to apply in all of the districts in Oxfordshire for the duration of the development (from commencement of the Section 28 process to adoption) of the Joint Statutory Spatial Plan. The consultation poses the following two questions, which are considered in these representations. 1. Do you agree with the proposed temporary 3-year housing supply requirement for Oxfordshire, which will end on the adoption of the Joint Statutory Spatial Plan (planned by 31 March 2021, subject to examination)? 2. Do you have any other comments on this consultation?
5 Q1 Persimmon Homes applauds the work of the Oxfordshire Growth Board in working to coordinate the six Oxfordshire authorities to plan proactively for the county s current and future housing needs. However, whilst the ambition and progress made in Oxfordshire is commendable, Persimmon Homes objects to the proposal to temporarily lower the housing supply requirement from five to three years for the following reasons: The proposal is not justified because there is an existing shortage of housing in the area people need homes now. The five year supply threshold has been an effective tool in delivering much needed market and affordable housing in the short term. The tilted balance is currently triggered where five year housing land supply is not achieved via the plan-led system. This has enabled housing sites to come forward where adverse impacts do not outweigh the benefits. Such an approach has been critical in boosting housing supply since 2012 at a time when plan preparation continues to be sluggish. A move to dilute this means would be counterproductive to the objective to deliver new homes and would exacerbate existing supply issues. A number of the Districts do not have an adopted Local Plan in place to direct new housing development (the plans for Oxford City and South Oxfordshire have not yet even been submitted). Without these plans in place, it is unclear how further housing would be able to come forward in the short term without the opportunity that the five year supply threshold presents - and has delivered through recent planning application appeals. These emerging local development plans have not been tested at Examination and the proposal to attribute so much weight to them is unsound. The argument that a reduction in the housing supply requirement is needed to allow the Oxfordshire authorities to plan for the future is flawed. The land supply threshold does not prevent the authorities from planning ambitiously for the area s long term housing needs. If this reasoning is due to anxiety about pressure on local planning authority resources, then it should be noted that the Government is making efforts to reduce the sometimes prolonged land supply examination process. The draft revised NPPF introduced the standardised methodology for calculating Objectively Assessed Needs and an opportunity for Councils to agree Annual Position Statements on land supply. These measures are designed to provide further clarity on the land supply process, thus relieving pressure on LPA resources. The proposal is referred to as temporary but is tied to the examination and adoption of the Joint Spatial Strategy Plan. As evidenced by current Local Plan examinations in Oxfordshire, this process can take considerable time beyond typically anticipated in a LPAs Local Development Scheme, and it is therefore difficult to determine how long such a limitation on housing growth would last. Introducing a temporary restriction in this manner could result in longer term consequences beyond the March 2021 date identified in this consultation. Progress with the emerging Oxfordshire JSSP has been accelerated by the land supply situation and it is a concern that this progress may slow down if the housing supply requirement is relaxed and this impetus is lost. Furthermore, constraining housing supply for the short term will only serve to exacerbate need within the market area. If implemented, this will undermine the stated national objective of delivering 300,000 new homes per year. The need for housing is particularly acute in the South East region and
6 county of Oxfordshire, which is identified as one the areas of greatest need and demand in the country. The proposal has the potential to throttle the supply of new housing which is inconsistent with the themes of the NPPF and the Government s Housing White Paper ( Planning for the Right Homes in the Right Places ). The three year housing land supply threshold is currently used to support Neighbourhood Planning groups, however the application of this over an entire county could have major social, economic and environmental implications. The Cambridge-Milton Keynes-Oxford arc is identified as a major growth area for the UK and so the proposal to restrict housing development opportunities in Oxfordshire is particularly at odds with the Government s agenda to drive growth in this region. The National Infrastructure Commission s Partnering for Prosperity report (published November 2017) highlights the housing crisis in this area, stating that The success of towns and cities across the arc has fuelled demand for homes. But a sustained shortfall in housing supply has led to high house prices and low levels of affordability, for both home ownership and private rental, and an undersupply of affordable housing. This is placing a fundamental constraint on the continued growth of the arc s most successful economies. The Report goes on to discuss the potential for relaxation of the land supply requirement, however recommends that this be on the basis that In all cases, agreement must preserve the requirement for local authorities to maintain a supply of land sufficient to enable house building at the rate that would have been required in the absence of any deal to support additional housing growth. The Oxfordshire proposal does not meet this stipulation as the land supply will be assessed against existing objectively assessed needs. The uncertainty around housing delivery exacerbated by this three year proposal has the potential to create uncertainty for people doing business in the arc. Changing policy conditions abruptly in this manner can have knock on effects for businesses making investment decisions. In conclusion, there are a number of reasons why the proposal to reduce the housing land supply requirement in Oxfordshire is counterproductive to the drive to deliver much needed new homes across the country and particularly within this area. Persimmon Homes objects to the proposal and would encourage the Oxford Growth Board to review their justification before implementing this measure.
7 Q2 Persimmon Homes (Wessex) does not have any further comments on this consultation.