Residential Requirement Report - Borough of Dartford

BOROUGH COUNCIL

1

DARTFORD LOCAL PLAN

Residential Requirement Report February 2021

Dartford Residential Requirement Report February 2021

Contents

1 INTRODUCTION AND CONTEXT .....................................................................................3 Purpose and Structure of Report .......................................................................................3 Existing Policy – Headline Review.....................................................................................3

2. HOUSING DELIVERY TRENDS & BACKGROUND.........................................................6

Housing Delivery in Kent ....................................................................................................6 Housing Delivery Trends in Dartford..................................................................................8 Dartford Population Growth..............................................................................................10

3. POLICY EVALUATION ....................................................................................................13

Local Housing Need Method............................................................................................13 Policy Principles to Fulfill Dartford’s Local Housing Need...............................................13 Wider Housing Requirement Considerations...................................................................15 4. KEY FINDINGS REVIEW.............................................................................................19

Summary Context.............................................................................................................19 Setting Dartford’s Residential Requirement.....................................................................20 Deliverable Supply............................................................................................................21

5. CONCLUSIONS AND WAY FORWARD.........................................................................22 APPENDICES..........................................................................................................................23

APPENDIX A: Local Housing Need Calculation..................................................................23 APPENDIX B: National Planning Practice Guidance ..........................................................24 APPENDIX C: Deliverable Housing Land Supply ...............................................................25

DBC Planning Policy Team 2


1. INTRODUCTION AND CONTEXT

1.1 This report draws from housing research in Dartford, and national policy/ guidance, to recommend how residential development levels should be confirmed and expressed in the 2021 Dartford Local Plan publication document.

1.2 This sections sets out the purpose and structure, and defining existing national and local policy context, in producing the report.

Purpose and Structure of Report

1.3 National policy sets clear expectations for Local Plans to deliver a sufficient amount of new sustainable development, particularly housing. Policy is set for the rate of delivery (for example deliverable sites), the type of housing land, and wider area residential needs. The national standard method level forms a clear starting point for Local Plans considering local housing need. However further evaluation of a range of further relevant factors is required before setting the local residential requirement policy.

1.4 Housing levels and national policy should be set in the context of Dartford and its past requirement levels and delivery, and in Kent as a whole.

1.5 The report looks at data on Borough development needs and other studies that consider how (where) the level of required development for certain uses should be accommodated, most notably the Strategic Housing Land Availability Assessment (SHLAA).

1.6 Firstly, section 2 reviews housing delivery and population change data. Section 3 looks in more detail at the standard method outputs and implications of national policy for Dartford in the wider context. Section 4 draws together findings, with final key conclusions reported in Section 5.

1.7 Appendices include Dartford’s standard method and five year deliverable supply calculations.

Existing Policy – Headline Review

1.8 Chapter 3 of the National Planning Policy Framework (NPPF) is on ‘Plan Making’. It opens (paragraphs 15-16b, emphasis added):

“The planning system should be genuinely plan-led. Succinct and up-to-date plans should provide a positive vision for the future of each area; a framework for addressing housing needs and other economic, social and environmental priorities; and a platform for local people to shape their surroundings. Plans should: a) be prepared with the objective of contributing to the achievement of sustainabledevelopment;b) be prepared positively, in a way that is aspirational but deliverable;…”

1.9 NPPF Chapter 5 (‘Delivering a sufficient supply of homes’) starts (paragraphs 59-60, emphasis added): “ To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward


Polic CS 10: Housin Provision 1. In order to meet housing needs and to provide an impetus for regeneration of

the Borough, land is allocated for housing in accordance with the spatial strategv set out in Policy CS 1. The capacity between 2006 and 2026 is as follows 1°7 :

Dartford Town Centre inc Northern Gateway Ebbsfleet to Stone

up to 3,070 up to 7,850108

up to 3,750

up to 2,400

200

Thames Waterfront Other sites north of A2

Sites south of A2, normally provided within villaQe boundaries

Housing delivery does not meet local needs

Forecasts indicate plan delivery fall ing below local housing need level of 11,700 homes195

Review of SHLAA/SHMA

Full or partial review of the plan to be undertaken


where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay….To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standardmethod in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.”

1.10 The Dartford Core Strategy, adopted 2011, sets the local housing development level by focusing on the capacity of residential sites. It states (policy CS10:1):

1.11 These capacity figures are aggregated to produce the headline Borough maximum housing level. The sites, making up the planned housing supply for the 20 years from 2026, total of ‘up to’ 17,270. This capacity led figure can be expressed as up to 865 dwellings per annum, when averaged over the 2006-2026 plan period.

1.12 The Core Strategy’s CS10 capacity figure was complemented by a 11,700 local housing need figure (equating to 585 dwellings per annum over the 2006-2026 plan period), which works as an effective minimum i.e. when intervention would be taken to change approach and push levels up towards 17,300. This is set out in Table 5 ‘Triggers and Management Action’ (Core Strategy Chapter 6):

1.13 The three columns present risks, responses and actions, respectively. (The footnote for the level of local housing need refers to the 2011 Housing Implementation Strategy).

1.14 The first three locations with up to capacities in CS10 above reflect the first policy of the Core Strategy (CS1: Spatial Pattern of Development) which sets out that they are



the plan’s the spatial focus: ‘priority areas for development’ policies, and include two strategic allocations and other brownfield land regeneration opportunities.

1.15 These three defined urban areas for regeneration have ‘up to’ development figures in CS1 aggregating to 14,670 dwellings (equating to an average of 734p.a.). These focal areas account for 85% of the 16,700 total level.

1.16 Additional national and local policy provisions are referred to throughout the document, but it is clear both national and local strategy seek ambitious housing development and regeneration outcomes.


local authority dwelling stock as at 31 st March 2019 B0,000

72,130

70,000 68,1 60 67,490

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2. HOUSING DELIVERY TRENDS & BACKGROUND

2.1 Housing delivery levels and rates at local authority scale should be seen in context.

2.2 This section explores housing delivery levels in Kent and Dartford, related targets/ and brownfield land use; and the resulting rates of population growth that have occurred in the Borough.

Housing Delivery in Kent

2.3 Housing land availability will reflect the size of local authorities, amongst other factors. Dartford is not a large Borough in area, whether seen in a county or more metropolitan context. In land area terms, Dartford is the smallest out of the 13 Kent Distircts, and is smaller than 6 London Boroughs.

2.4 Dartford’s recent population levels are outlined at the end of this section, along with national comparators.

2.5 Kent County Council1 analysis of central government data provides a snapshot of Dartford’s overall aggregate housing levels in the county context.

1 https://www.kent.gov.uk/__data/assets/pdf_file/0005/81662/Housing-stock.pdf DBC Planning Policy Team

6

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2.6 The County Council comment:

“As at 2019 Maidstone district has the largest dwelling stock in the county (72,130). Over recent years Dartford (+4,740, +11.1%), Maidstone (+4,680, +6.9%) and Tonbridge & Malling (+3,800, +7.4%) districts have seen the biggest growth in dwelling stock over the last five years. Thanet saw the smallest 5 year percentage growth (+2.5%) while Gravesham saw the smallest number increase (+1,160) in dwellings.”

2.7 The County Council show in the following chart that Dartford has had proportionately very high rates of growth in the housing stock, both over the year to 2019 and a 5 year period – the highest in Kent for both.

2.8 The chart also includes the average figures for England, and at a higher level, for Kent as a whole. Gravesham and Sevenoaks are below the national average, with the other local authorities below average being Medway and those in east Kent.

2.9 The KCC data additionally shows Dartford has the lowest number of long-term vacant dwellings in the county in 2019.



Housing Delivery Trends in Dartford

2.10 The context of previous housing delivery rates (and target levels) in the Borough is also highly relevant.

322

646 622 625

184

659 603 610

152

362 323

422

602 565

971

1162

1031 1013

540

0

200

400

600

800

1000

1200

1400

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Delivery Since 01/02

2.11 In the 19 years to 2019/2020, the Borough’s annual delivery has 10 times been within a 10% variance (+/-) of 600 homes. The overall mean average new dwellings to 2019/20 has been 601pa.

2.12 Delivery has fluctuated. The extremes are: • Lowest annual delivery of dwellings was 152 in 2009/10.• Peak annual delivery of dwellings was 1,162 in 20016/17

2.13 Average rates of delivery are generally slightly higher in more recent periods: • From 2006/07 (Core Strategy period) = 644 dwellings per annum mean, 603

dwellings per annum median• From 2010/11 (Last 10 years) = 699 dwellings per annum mean, 584 dwellings per

annum median.

2.14 A pictorial illustration of these delivery rates is set out below:



Annual delivery mean averages over time

Extremes of annual delivery

699pa(From 2010)

601pa(From 2001)

1,162 152

2.15 In terms of policy requirements, the delivery figures set out above compare with a headline Core Strategy target of up to 865pa dwellings in average, and a minimum need trigger of an average of 585pa dwellings. For information, it can be noted that previous to the 2011 Core Strategy, the 1995 Dartford Local Plan included a requirement equating to 287pa dwellings.

2.16 The Core Strategy sites have a strong brownfield land focus. The total proportion of new dwellings delivered on brownfield land in the period 2006-2020 is 80.4%.

2.17 The yearly proportion is set out in the Chart below. This shows the percentage of new dwellings on brownfield land has fluctuated, however the 80% level has only been missed annually on two occasions (2013 and 2019).


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2.18 There has been some notable sources of brownfield sites in Dartford, land recycled from specific past land uses such as quarrying, historic hospital sites. However these particular sources are not continuing to produce surplus land, which underscores the importance of supporting sustainable regeneration for the future through for instance:

• Appropriate urban intensification at locations well served by public transport• Introducing new neighbourhoods where regeneration is required e.g. to

transform town centres.

Dartford Population Growth

2.19 As well as experiencing growth of housing stock within the Borough, Dartford has seen significant increases in population.

2.20 ONS mid-year population estimates show that over the last five years, the borough of Dartford has witnessed the 7th highest population growth in the country (3rd

highest if excluding London Boroughs).


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6,751 10,596 9,221

36,503

31,418

40,149

34,007

3,582 10.3% 10.4% 10.7% 10.9% 13.7% 14.1% 14.4%

58.3%

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10.0%

20.0%

30.0%

40.0%

50.0%

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0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

Five-year Population Growth

Increase in No. of Persons Five-year Percentage change

Source: ONS

2.21 The above figure shows the English Local Authorities who have experienced a five-year population growth of 10% or higher. As can be seen, Dartford’s population has grown by more than 10,000 persons, equating to a 10.4% percentage increase. This is the greatest of any two-tier area in England.

2.22 The figures shows in terms the level of population change, the relative impact varies depending on existing population levels. Dartford has a smaller than average population base, meaning proportionate growth rates are high.

2.23 When looking at average population increases over the same time period, mid-2014 to mid-2019, it is confirmed in the figure below that Dartford’s population growth at over 10% was a significantly higher rate than county, regional and national growth levels.



0.0%

2.0%

4.0%

6.0%

8.0%

10.0%

12.0%

Dartford Kent South East England

Population Change mid-2014 to mid-2019

Source: ONS


. (.Local ,affordability ratio - 4). Adjustment factor = 1 4 x 0;2 5 + l


3. POLICY EVALUATION

3.1 This section is a central part of the report, as national guidance requires close consideration, particularly Dartford’s local housing need baseline and how a requirement can be implemented and take on board wider requirements .

Local Housing Need Method

3.2 The NPPF paragraph 60 on delivering a sufficient supply of homes states that policies should be informed by the standard method in national planning guidance, unless an appropriate alternative approach is justified.

3.3 The Dartford and Ebbsfleet Housing Needs Assessment (HDH, 20192) reviewed the Dartford standard method output in the context of evidence on local affordable housing needs. The research considered that the standard method provided a suitable general basis for meeting housing needs in Dartford (see for example Assessment paragraphs 7.6 and 7.14).

3.4 Dartford has therefore not applied its own methodology for local housing need. It is implementing the current national standard method.

3.5 The local housing need level from the standards has been calculated as set out in Guidance (see Appendix A). In short this uses household growth projections, adjusted for ‘affordability’ (house prices and earnings), with adjustment as detailed in this formula:

3.6 The cap (and the new cities/ urban centres uplift) stage is not triggered in this Borough.

3.7 This results in a current standard method Local Housing Need figure for Dartford of 776 dwellings per annum. This method reflects core demographic trends occurring in Dartford, plus also takes account of key economic factors for home purchase.

Policy Principles to Fulfill Dartford’s Local Housing Need

3.8 National policy seeks for the Local Plan to identify a housing land supply to ensure that delivery does not fall short of the standard method level, with specific sites identified and available to be brought forward. Further consideration should then be given to the Local Plan policy requirement level and guidance that be can be set locally.

2 https://www.dartford.gov.uk/__data/assets/pdf_file/0012/862878/Dartford-and-Ebbsfleet-Residential-Needs-Assessment-Oct-2019.pdf DBC Planning Policy Team

13


3.9 The Dartford SHLAA findings (DBC, 2021) demonstrate relatively good overall expected levels of housing delivery in the Borough i.e. totals over the long-term average exceed the standard method level. This forms a potential basis for forming the residential requirement in the Local Plan.

3.10 NPPF paragraph 67 seeks housing supply to be identified “where possible” over a period extending to year 15 of the Plan.

3.11 The base year of the Local Plan commenced 2017/18 with the adoption of the last Dartford plan, and coinciding with the proposed introduction by government of the standard method. On this basis, and considering the long-term nature of regeneration in the Borough, for example to transform Central Dartford, it is considered that if planned residential levels in Dartford are to be based directly on available supply -capacity - in the housing trajectory, this should be calculated on a period of 15years into the plan (2031/32) as per national policy.

3.12 In terms of how the residential requirement level is expressed and operates it should: • Adhere to NPPF requirements for a sufficient provision of developable and, in

particular, deliverable housing sites over the appropriate time period required; • Be flexible enough to not preclude additional development occurring where it is in

highlighted sustainable locations, i.e. in the identified urban regeneration areas at Central Dartford and Ebbsfleet Garden City; and

• Also provide sufficient certainty to inform infrastructure planning, and to manage development pressures for development in unsustainable locations. This is particularly important as one of the fastest growing Boroughs in the country, operating in a two-tier system of government, adding to the fragmentation of infrastructure service delivery.

3.13 There are many variations in how housing levels are expressed in Local Plans. A range - expressing upper and lower figures - is sometimes found, and could be locally feasible (and is, for instance, how the current Dartford Core Strategy works).

3.14 Or a single figure could be applied; and possibly also expressed as a minimum/ maximum. However close consideration is need as how this operates with requirements of national policy.

3.15 Local Plans sometimes include staggered figures that vary over time based on phasing. However in reality councils cannot ordinarily force developers in how they build out planning permissions, and it is usually very hard to achieve planning permissions that slow or stop delivery based on Local Plan phased delivery aspirations. Phased delivery on larger sites is however desirable, including for infrastrucutre reasons or to ensure build out in line with agreed masterplans.

3.16 The government preference for regular plan updating is likely to mean that long-term specific provisions in plans for phasing many years ahead are unncessary. Key local triggers for review should be indentified in the Plan from the outset.

3.17 The housing requirement will operate alongside Plan performance monitoring and provisions that will trigger actions, including potential formal review of housing policy.



This is allied with ongoing government housing supply management measures, such as the Housing Delivery Test.

Wider Housing Requirement Considerations

3.18 Much of the emphasis in national policy is for every authority to sustainably and positively plan sufficient residential development to meet their own needs. Dartford has strong applied this approach, however specific national policy on finalising a precise housing requirement in excess of housing needs is limited; which is likely in recognition of the range of local factors that will influence growth levels that are sustainable and achievable in a locality.

3.19 For practical advice, national guidance (Paragraph: 010 Reference ID: 2a-010-20190220) does however offer some points for consideration. This advises on the circumstances suggesting when an acceleration in delivery beyond local trends (and going higher then standard method level) is appropriate.

3.20 This guidance is repdroduced at Appendix B, and its key requirements form the basis of the factors (left hand column in the table below) considered:

Situations where increases in housing need are likely to exceed past trends

Dartford Evaluation

PAST DELIVERY: “previous levels of housing delivery in an area… are significantly greater than the outcome from the standard method”

• As shown above (paragraphs 2.11-2.13) Dartford’s past housing delivery has fluctiated but most typically has been in the order of 600 dwellings per annum since 2001/2, as a broad indication.

• In the last ten years, Borough delivery had an average of 699 dwellings per annum

• Dartford’s history of housing delivery has been under the level of the standard method (776 dwellings per annum on average), not significantly greater.

LOCAL NEED EVIDENCE: • The Core Strategy’s assessment of local housing “previous assessments of need need was 585 dwellings per annum (paragraph 1.9 (such as a recently-produced above). Strategic Housing Market • The recent Dartford & Ebbsfleet Housing Needs Assessment) are significantly Assessment for the new Local Plan found that the greater than the outcome from Borough’s affordable housing needs did not the standard method” necessitate aiming for a requirement beyond the

standard method. • All evidence indicates that the Borough’s housing

needs are not significantly greater than the standard method.

STRATEGIC INFRASTRUCTURE: “strategic infrastructure improvements that are likely to drive an increase in the homes needed locally”

• No infrastructure projects have been confirmed that will increase housing need in the Borough.

• Infrastructure deficiencies can limit the level of demand for homes locally and constrain development, with actual circumstances such as reliance on temporary school accommodation and high GP to patient ratios likely to deter prospective occupants and some developers. If left unchecked, Dartford’s




Dartford Evaluation

high profile congestion problems may drive away more economic and investment stimuli of residential growth.

• Recent experience has clearly indicated a lack of responsiveness of infrastructure provision to high population growth. For example healthcare, education and public transport improvements have had an extended lag in provision relative to the provision of new development, impacting on wellbeing and generating major additional journeys and further loading transport infrastructure as people require essential services further afield.

• There are two major transport schemes planned and with good certainty of delivery:

o The Fastrack route extension through South and West Ebbsfleet (Eastern Quarry)

o The A2 junction improvements at Bean and Ebbsfleet adjacent junctions.

o These both are conceived in relation to, and will be focused on serving, planned development at Ebbsfleet that is supported and accounted for in the Local Plan

• No other strategic infrastructure projects creating new capacity are confirmed in the Borough. However the implications of any commitment to significant new rail infrastructure and services, or the economic growth and facilities from the London Resort, would be reviewed should they be agreed and impact in this plan period.

• There are therefore no strategic infrastructure improvements that are likely to drive an increase in the homes needed locally, beyond the new homes already planned for.

GROWTH FUNDING • No deliverable growth strategy has been agreed for STRATEGIES: the wider area. “growth strategies for the area • No growth deal or infrastructure funding has been that are likely to be deliverable, agreed with government on the basis of planning for for example where funding is in further increased growth rates in the Borough. place to promote and facilitate additional growth (e.g. Housing Deals)” STATEMENTS OF COMMON GROUND: “agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground”

• Local Plans have not been adopted on the basis of additional growth occurring at Dartford.

• No neighbouring Boroughs have asked Dartford to help with their housing need since Gravesham’s 2015 request and it is unclear if/how Gravesham Borough are actively pursuing this further.

• The 2019 agreed Statement of Common Ground between Dartford Borough and Sevenoaks District does not set out that Dartford Borough will take housing need from Sevenoaks District. Section 4




Dartford Evaluation

covers this issue directly: “it is clear that SDC and DBC do not share the same housing market area and there is not a functional cross-boundary housing linkage”. The Sevenoaks Core Strategy was adopted in 2011, no new Plan has been adopted.

• The 2020 ‘first stage’ Statement of Common Ground between Dartford Borough and Bexley London Borough does not set out that Dartford Borough will take housing need from Bexley Borough. Bexley have yet to take a Local Plan to Regulation 19 stage, since their Core Strategy was adopted in 2012.

• In 2015, Gravesham Borough wrote to Dartford Borough to request it takes on some of Gravesham’s need. Dartford Borough requested further information and discussion. Gravesham has yet to take a Local Plan to Regulation 19 stage, since its Core Strategy adopted in 2014 and the necessary further information (including on scale of unmet need) has yet been confirmed.

• Thurrock Council, on the other side the River Thames, adopted its Core Strategy in 2011. Like Dartford Borough, it is aiming to meet or surpass its housing need.

• In summary, the position on statements of common ground is informed by respective Local Plan updates and evidence release. Reflecting an interface between the rate of plan progress in Dartford, Bexley, Greater London, Sevenoaks, Gravesham and Thurrock, the situation is dynamic and requires ongoing cooperation to be maintained, statements kept up to date and further consideration given.

3.21 Out of all the considerations in the government guidance (summarised in the left hand column) it is apparent that the only likely rationale for Local Plan housing development levels above the standard method is the latter aspect, i.e. if agreed through Statements of Common Ground.This has not specifically occurred at present, but the overall current Duty to Cooperate obligaton on Local Planning Authorities confirms that it warrants continued work and consideration. This is consistent with key NPPF policy to take into account unmet needs of neighbouring authorities, and as part of planning positively and effectively.

3.22 Dartford’s strategic context is that Borough and Kent’s boundaries form local, county and regional frontiers (with Bexley in Greater London and Thurrock in the East of England areas) freely traversed in the economic and housing movements. One implication is further complexity in aligning cross-boundary planning timings and arrangements. The Borough’s situation is consistent with the fact that after review of functional connections, the Housing Needs Assessment concluded (paragraph 1.70) that Dartford can be seen as its own housing market area.



3.23 Extensive cooperation between Dartford and its neighbouring Authorities has nevertheless occurred, and drafting of Statements of Common Ground has progressed. One expression of this activity is documented in the Duty to Cooperate Statement of Activities (DBC, 2021).

3.24 In relation setting the residential requirement, to directly quantify implications for Dartford’s final housing policy taking account of all neighbours, the magnitude of ‘area’ aggregate need would need to be known and confirmed.

3.25 This is not the case. This is partly as some adjoining authorities have not progressed plans far enough, and also because the full extent of the applicable ‘area’ is undefined (as noted, Dartford’s neighbouring authorities are located in two other regions/ strategic planning areas). In any event, there is no set expectation by government that one single authority should vary from sustainable development and national policy key principles, including Green Belt national policy, to accommodate all unmet needs in the wider area.

3.26 To facilitate further progress, it is clear from the above state of play of Local Plans that Dartford Borough confirming its proposed housing development levels will be directly beneficial to taking forward further co-operation and positive strategic planning. This will inform Statements of Common Ground updating/ completion and assist with quantifying the delivery of housing needs in the area.



4. KEY FINDINGS REVIEW

4.1 This section summarises the evaluation in this report, to inform final policy outputs.

4.2 The preceding important local context/ data and national policy requirements are brought together to outline findings on the potential Local Plan approach to total Borough housing levels. Deliverable housing land implications are also set out.

Summary Context

4.3 Dartford is a compact small Borough, and 57% Green Belt land, but has however hosted huge population growth, and has boosted home building levels.

4.4 Underlying this, residential delivery rates in particular have fluctuated but there is evidence of an upward trajectory over time. New homes have principally been from historic brownfield land sources.

4.5 Dartford’s main housing policy from 2011 currently sets out the maximum (up to) residential capacity in the twenty years to 2026. If account is also taken of the lower level included in the Plan for triggering actions to intervene to boost supply, the overall approach can be seen as a range.

4.6 Despite Core Strategy success in focusing regeneration and increasing housing supply, it is not considered appropriate under the NPPF to set out headline policy as a maximum/ or up to level. However if residential development occurs at a level substantially higher than expected, this can result in major adverse infrastructure and environmental outcomes.

4.7 The simplest approach is for the housing requirement to be expressed as a single figure. To refect Dartford’s regeneration (urban brownfield land) agenda area policies can provide support to bring forward further sustainable opportunities at identified urban locations, when land is available.

4.8 Under the government’s current standard method, Dartford’s local housing need level is 776 dwellings per annum. Dartford Borough is not proposing an alternative methodology for quantifying the residential need level as its starting point for setting the Borough residential requirement.

4.9 The standard method is appropriate in Dartford in terms of affordable housing needs, when accompanied by suitable development management policy. The national standard method factors in affordability of home buying.

4.10 A sustained level of new home construction of 776 dwellings per annum (the standard method level) in Dartford can be seen as a significant increase, which may equate to a 29% uplift from prevailing levels of the last two decades.

4.11 A housing requirement level somewhat in excess of 776 new homes a year would increase certainty of achievement, achieving an average in excess of 776 dwelling



completions a year over time. However in any event, national policy has requirements that introduce a buffer to manage delivery.

4.12 In terms of when/ why to set a requirement at a level above the standard method, government guidance on circumstances to accelerating housing delivery/ trends has been studied: • There is no evidence of current or future housing need data, or agreements

in relation to infrastructure secured on the basis of future additional growth, to indicate that a substantial uplift on the standard method is appropriate in the Borough.

• It has been shown the principal consideration from this guidance that applies in Dartford is in relation to the ongoing issue of Statements of Common Ground (reflecting Local Plan progress in the area).

Setting Dartford’s Residential Requirement

4.13 In summary, from the above and previous sections, these external (or internal) considerations do not define a specific residential requirement number for Dartford. However rather than defaulting to the standard method level, a positive approach that can meet residential and regeneration needs in sustainable locations is proposed in order to inform the final residential requirement level. Dartford’s SHLAA criteria allow for sustainable but sufficient residential development, and can be seen as representing some continuity of approach from the Core Strategy that has been successful in accelerating housing supply at identified urban locations.

4.14 Dartford’s identified housing supply has now been finalised with conclusion of the SHLAA showing suitable, available and achievable sites in excess of 776 dwellings p.a. The Borough’s housing land supply provides good certainty, partly because much of this residential pipeline already benefits from planning permission.

4.15 Full phasing of new housing site (SHLAA) capacity over the Plan period has been undertaken in line with guidance. Applying the 15 year horizon from the start of the Plan as identified at paragraph 3.9 and focusing on the identified sustainable regeneration capacity (cumulative delivery total in the SHLAA) at 2031/32, results in a total housing capacity of 11,900.

4.16 Annualised, this sets the Dartford housing requirement at 790 dwellings per annum on average (rounded).

4.17 Dartford’s housing requirement based on the Borough’s identified sustainable regeneration capacity reflects the established principles, and national policy, of brownfield land development near good public transport and a choice of local services/ facilities. This accords with the letter and spirit of government policy to boost housing supply whilst maintaining a focus for development in Dartford’s most sustainable urban locations and protecting the green belt.



Deliverable Supply

4.18 Close regard has been had to the NPPF, including specific housing requirements such as paragraph 67 on deliverable sites (and specific developable sites for years 6-10 and where possible years 11-15 of the plan). The requirement for a Five Year Suply, with an appropiate buffer on a requirement of 790pa new homes, is tested at Appendix C.

4.19 There is a 5.6 years deliverable housing land supply from the appropriate sites from the housing trajecory from the SHLAA, when applying the 790 home requirement.

4.20 Dartford will seek to confirm this presence of a five year deliverable supply of housing land through the new Local Plan.



5. CONCLUSIONS AND WAY FORWARD

5.1 This section brings together key conclusions from the study, particularly the previous section, and outlines the future approach for the Dartford Local Plan.

5.2 An updated core residential level can now be clearly set out, in the new Local Plan and to meet national policy and to aid local regeneraiton and infrastrucutre planning. This however should maintain the principle of a capacity/ urban brownfield based approach, as consistent with local housing need.

5.3 After analysis of the level of development needed, how national policy will be met in the area, and the specific findings on available and sustainable Dartford housing capacity (SHLAA), it is concluded a Local Plan strategic policy based on an average residential requirement of 790pa would be: positive (deliverable and realistic) planning for area housing needs, justified and effective.

5.4 This level is consistent with spatial strategy and new Local Plan aims, and boosting local/ area supply, above the standard method level.

5.5 In consideration of how it is expressed and operates with other policies, the level is not specified as an “up to” level or “minimum”. This recognises how national policy/guidance works, and environmental implications. A clear single figure provides clarity and confidence, for example for infrastructure service providers.

5.6 Additional issues raised in this report also suggest Dartford Local Plan strategic policy on residential development levels should also:

5.6.1 Recognise at target of 80% of new homes to be brownfield land.

5.6.2 Encourage phased large site delivery/ alignment with infrastructure.

5.6.3 Be related to guidance on non-residential development levels in Dartford.

5.6.4 Have supporting monitoring arrangements and review triggers.


(·. Local af f ordabl-Uty ratio - 4). Ad1ustment factor = , ----------- x 0.25 + 1 . 4


APPENDICES

APPENDIX A: Local Housing Need Calculation

National guidance on calculating the Local Housing Need has been followed and the calculations have been set out below. The process can be broke down into three steps;

1. Calculate the adjustment factor following the formula below

2. Apply the adjustment factor to the average annual projected household growth over a ten year period

3. Apply a cap – this step is not applicable for Dartford

Step 1

Local Affordability Ratio for 2020 is 9.23. Therefore the adjustment factor is 1.33, as shown below.

�9.23 − 4

� 𝑥𝑥 0.25 + 1 = 1.33 4

Step 2

The average annual projected household growth is calculated over the ten year period from 2020 to 2030 based on the 2014-based projections published by the ONS. The average across Dartford’s projected annual increase for this time period is 585.

Year 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 Average Projected

Growth 46,509 47,095 47,693 48,280 48,865 49,447 50,007 50,585 51,161 51,746

Annual Increase 613 586 598 587 585 582 560 578 576 585 585

Therefore, the Local Housing Need is 776, as shown below.

1.33𝑥𝑥 585 = 776


APPENDIX B: National Planning Practice Guidance

Applied in section 3:

When might it be appropriate to plan for a higher housing need figure than the standard method indicates?

The government is committed to ensuring that more homes are built and supports ambitious authorities who want to plan for growth. The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates.

This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan). Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:

• growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);

• strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or

• an authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground;

There may, occasionally, also be situations where previous levels of housing delivery in an area, or previous assessments of need (such as a recently-produced Strategic Housing Market Assessment) are significantly greater than the outcome from the standard method. Authorities will need to take this into account when considering whether it is appropriate to plan for a higher level of need than the standard model suggests.

Paragraph: 010 Reference ID: 2a-010-20190220

Revision date: 20 02 2019

24


APPENDIX C: Deliverable Housing Land Supply

A housing requirement for Dartford at 790 homes per annum, over the Plan period (20 years), this equates to a total need for 15,800 homes. 2,585 homes have already been delivered and the remaining 12,990 are projected for delivery within the remained of the Plan period – as set by the trajectory3.

The process and calculations for determining Dartford’s projected five year delivery, against the five year requirement, is set out here.

2,585 homes have already been delivered between 2017/18 and 2019/20. This means that Dartford has a surplus of 215 homes which can be applied to the five year supply as per the Sedgefield approach recommended in national policy guidance. After deducting this, the total five year requirement is 3,375.

A Annual Housing Requirement 790 B Homes already delivered 2017/18-2019/20 2,585 C Surplus (B- Three years of requirement – B) 215= 2,585- (790x3) D Five years of requirement, minus surplus ((Ax5) – C) 3,735= (790x5) – 215 E Requirement with 10% Buffer (D + 10%) 4,109= 3,375 x 1.1

The PPG requires that a 10% buffer be added to the five year housing requirement to account for potential fluctuations in the market over the year and ensure that the five year land supply is sufficiently flexible and robust.

After applying the 10% buffer, the five year requirement is 4,109

The five-year supply is based on how this covered by projected deliveries between 2020/21 and 2024/25.

The annual projected delivery is shown in the following table and is made up of all sites assessed as ‘deliverable’. In total, there are 4,605 homes projected within this five year period.

2020/21 2021/22 2022/23 2023/24 2024/25

ProjectedHousing Delivery

494 786 1121 1168 1036

3 SHLAA 2021 Findings Report DBC Planning Policy Team

25

�


494

786

1121 1168

1036

0

200

400

600

800

1000

1200

1400

Year 1 Year 2 Year 3 Year 4 Year 5

Annual Delivery within Five Year Supply

Projected Annual Delivery Average Annual Delivery

Dartford’s deliverable year supply meets, and exceeds, the new Local Plan requirement of 4,109 homes over the five year period and equates to a 5.6 year supply

0

1,000

2,000

3,000

4,000

5,000

Requirement Requirement with 10% Buffer Projected Delivery

Meeting the Five Year Requirement

Number of Homes

.


Documents

Residential Requirement Report - Borough of Dartford