Policy GESP16: Housing Target and Distribution
The Greater Exeter councils will target the delivery of 2,663 homes per year in the Greater Exeter area (53,260 total) between 2020 and 2040. From the date of adoption of the GESP, the Housing Delivery Test and five year housing land supply calculations will be assessed against this target on a Greater Exeter area wide basis.
- Delivery to meet this target is proposed from the following sources (which allow for a headroom of about 20% against the overall target):
- Approximately 33,390 homes from existing planning commitments
- Approximately 18,500 homes on GESP allocations [sites to be determined after this consultation and identified in the next version of the GESP]
- Approximately 12,000 homes to be identified in future local and neighbourhood development plans [distribution between local planning authorities to be determined after this consultation and identified in the next version of the GESP]
- Local plans should allocate additional housing sites to make up for any under-provision in planning commitments within a local planning authority against the assumptions contained in A above
- Local plans may vary housing supply from these figures when justified by overall planning and sustainability considerations provided that any reductions are made in the context of effective duty to cooperate agreements with other local planning authorities which do not reduce the overall GESP housing delivery
7.4 The government’s standard method set out in national policy gives the Greater Exeter area housing need as 2,663 homes per year. The calculation uses data from the Office for National Statistics (ONS) 2014-based household projections and Office for National Statistics (ONS) 2018 housing affordability statistics.
7.5 Draft policy GESP16 identifies three sources of housing supply between 2020 and 2040. Total potential supply amounts to 63,890 dwellings, allowing for a healthy headroom of about 20% above the target. This means that the GESP will be resilient against uncertainties such as delay in developing a particular site or changes in housing need or government policy. The high headroom figure reflects the risks associated with the number of brownfield sites considered in Section C of this consultation, which are acknowledged to be difficult to deliver. With further work on deliverability of potential GESP sites, this headroom should fall as the GESP progresses towards adoption.
Commitments
7.6 Existing planning consents (including permissions awaiting Section 106 agreements) and existing local plan allocations which do not yet have planning permission are referred to as ‘existing planning commitments’ in draft policy GESP16 criterion A. Forecast completions between 2019 and 2020 are excluded from these figures as their development will precede the GESP plan period. 33,380 homes are forecast from this supply, comprising approximately 11,540 homes in East Devon, 6,830 homes in Exeter, 8,240 homes in Mid Devon and 9,010 in Teignbridge.
GESP Allocations
7.7 Strategic sites will be identified for allocation in the draft GESP. Sites we are considering and want to hear your thoughts on are included in Section C of this consultation. We consider that delivering around 18,500 homes on strategic sites within the plan period is feasible and would provide a reasonable balance with smaller sites within existing and future local plans.
Future Local and Neighbourhood Development Plans
7.8 Finally, as the Greater Exeter councils review their local plans they will need to allocate additional sites to meet the requirements in draft policy GESP16 section C. The requirements may also be met through brownfield registers, local development orders and neighbourhood development plan allocations. From these types of proposals, a total of 12,000 dwellings are identified in draft policy GESP16, subject to the clarifications below, giving the potential for a range of site scales and locations, including national policy requirements for identification of small sites.
7.9 At this stage, the local plan targets for individual districts are not defined and this will need to be agreed for the next version of the GESP. Local plans may include targets for individual neighbourhood development plans. Evidence such as the Urban Capacity Study and further iterations of the Housing and Employment Land Availability Assessment will inform this process.
7.10 Draft policy GESP16 is designed to give a long term and robust housing strategy against which local plan reviews and allocations can be assessed, looking over the long term. However, in order to keep certain elements of housing targets up to date, a number of the elements of the policy will need to be reviewed during local plan preparation, and these are explained further below.
7.11 The overall target for the GESP area applies for 5 years from the plan’s adoption, in accordance with national policy. A review of the target which finds it still to be appropriate extends its currency by a further 5 years. Pending a full review of the GESP, and depending on the review timetable, this is likely to be undertaken during individual local plan reviews. It will involve comparing the GESP target against the most recent GESP-wide housing need calculation and setting out the results in the Statement of Common Ground required under the duty to cooperate. Where overall housing need has changed significantly, the Greater Exeter councils should consider whether a new overall GESP-wide target should be used for five year supply and Housing Delivery Test purposes and set out any agreed change within the Statement of Common Ground.
7.12 In order to ensure that the local plans will underpin the achievement of the overall target, the policy requires that the local plans should review the deliverability of the commitments which are assumed within draft policy GESP16 criterion A and use up to date information. If commitments are not going to provide as much housing as previously expected, this will need to be made up for by increasing the local plan housing provision.
7.13 Finally, it is likely to be necessary for the Greater Exeter councils to review the overall delivery trajectory, including in particular the progress and prospects of the GESP allocations. This review is not intended to provide a basis for reconsidering the principle of the GESP allocations, as these form a central plank of the agreed spatial development strategy over the long term.
7.14 Having undertaken this joint work, it may become necessary to amend the targets within draft policy GESP16 criterion C to take account of the various background changes set out above. Such amendments should be agreed between the Greater Exeter councils and confirmed within a Statement of Common Ground. This review process will ensure that the housing targets are kept up to date and can provide a basis for effective and stable strategic guidance. Where severe difficulties in achieving the contribution within a local planning authority become apparent during a local plan review, the duty to cooperate process will give an opportunity to adjust overall housing provision between the local planning authorities, to ensure that the overall GESP housing target is met.
7.15 Draft policy GESP16 commits to future five year supply and Housing Delivery Test calculations (both required by national planning policy) to be undertaken on a plan-wide basis, reflecting the housing market area. A detailed housing delivery trajectory will be included in the next version of the GESP. This will be used as the basis for monitoring progress against the annual target of 2,663 dwellings.
Purpose Built Student Accommodation
7.16 The housing need of students in the Greater Exeter area, whether in purpose-built student accommodation or shared conventional housing, is an element of the overall housing need for the Greater Exeter area. It is not in addition to this need. This is explained further in the GESP Local Housing Needs Assessment (2nd Edition). Therefore new student flats, houses or bedrooms in purpose-built student accommodation all contribute to meeting the Greater Exeter area’s housing need.
7.17 In accordance with Practice Guidance, every 2.5 bedspaces in purpose-built student accommodation equates to 1 home in the Greater Exeter housing requirement. Purpose-built student accommodation commitments and completions will be counted on this basis in both the 5 year housing land supply and Housing Delivery Test. The ratio derives from published census data, which will be updated after the 2021 census.