SHP2016 - PSA Housing Need

STONE HILL
PARK
LIVE WORK PLAY
SHP1-4.3
Planning Statement
Addendum:
Housing Need
A brighter future for

Thanet and East Kent
Stone Hill Park
Contents
Contents
1.
Introduction................................................................................................................................................... 1
2.
Assessment of Housing Delivery ................................................................................................................ 4
3.
Published Housing Need Evidence .......................................................................................................... 6
4.
GVA Calculation of Objectively Assessed Housing Need ................................................................. 23
5.
Assessment of Land Supply ...................................................................................................................... 44
6.
Alignment Between Need and Supply.................................................................................................. 55
7.
Appropriateness of the Former Manston Airport Site.......................................................................... 58
8.
Conclusion .................................................................................................................................................. 59
Appendices
Appendix I
Housing Evidence Surrounding Districts (March 2015)
For and on behalf of GVA Grimley Limited
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Housing Evidence
1.
Introduction
1.1
GVA have been commissioned to prepare an evidence base to guide the preparation of a
masterplan for the redevelopment of the former Manston Airport site. The purpose of this
report is to provide the necessary land use evidence to justify housing, as part of the
masterplan proposals.
1.2
This report initially comprises a critique of the Councils housing evidence base, which focuses
on housing need and supply matters. Certain aspects of this evidence are then updated,
specifically the objectively assessed housing need, in order to calculate a more up-to-date
housing need figure and a more robust understanding of the alignment between housing
need and identified potential supply.
1.3
The outcome of this is an up to date evidence base position that identifies a higher level of
housing need (than identified in the Councils existing evidence base) plus a need to identify
a greater supply of deliverable housing land (than currently proposed in the 2015 consultation
draft Local Plan) in order to satisfy the updated objectively assessed need figures and to
tackle delivery risks associated with existing identified land supply.
Housing Evidence Base Context

1.4
The following evidence base documents have been reviewed. These documents address
housing delivery, housing need and housing land supply:
Housing Delivery:
Thanet Local Plan Monitoring Report (2014).
Housing Need:
Strategic Housing Market Assessment (SHMA) for the East Kent Sub-region (2009);
Thanet Strategic Housing Market Assessment (SHMA) 2016;
Kent County Council Economic and Demographic Forecasts (2013);
Thanet District Council Housing Topic Paper (2013);
Thanets New Local Plan Options Consultation (2014);
Draft Thanet Local Plan: Preferred Options (2015); and
As an extension to the consideration of housing need, a brief review of the key evidence
bases for the neighbouring local authorities, defined as making up the East Kent Housing
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Housing Evidence
Market Area in the East Kent SHMA (Thanet, Canterbury, Dover, Shepway, Swale), is
provided In Appendix of this report.
Housing Land Supply:
1.5
Strategic Housing Land Availability Assessment 2013 Update; and
Thanet Local Plan Monitoring Report (2014).
Many of the above documents were prepared in the assumed context of the site continuing
to operate as an airport which is no longer the case. Changes to the use of the site will have
subsequent impacts on the population growth forecast scenarios, housing need and land
availability assessment. In several cases, documents were also produced within a pre-NPPF
context, so their continuing validity is an area for consideration.
Report Structure
1.6
The report is structured as follows:
Section 2: Assessment of Housing Delivery This section reviews recent housing delivery
within Thanet, based on the Thanet Local Plan Monitoring Report (2014);
Section 3: Housing Need Evidence This section provides a detailed review and critique of
the existing housing need evidence (including the Thanet SHMA (2016));
Section 4: GVA Objective Assessment of Housing Need provides a re-calculated

objectively assessed housing requirement for Thanet District that establishes an up-to-date
and robust need position, which is NPPF and NPPG compliant and draws on the latest
published data available;
Section 5: Assessment of Land Supply This section reviews the SHLAA 2013 Update and
where relevant the Local Plan Monitoring Report, to provide an assessment of the
identified land supply position. This considers the assessed potential delivery from different
site sources, the identified 5 year housing land supply, the role of windfall sites, and the
methodological compliance of the site assessment with the tests set out in the NPPG
(suitability, availability and achievability).
Of key importance here is establishing an
understanding of the likelihood of identified potential sites coming forward, particularly in

relation to strategic sites within the 5 year deliverable period;
Section 6: Alignment Between Need and Supply This section draws on Sections 2-5 to
understand how the identified need aligns with recent past housing delivery levels and
assessed supply potential (SHLAA, AMR);
Section 7: Appropriateness of the Former Manston Airport Site This section considers the
suitability of the site to support housing (as part of a mixed use development); and
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Housing Evidence
Section 7: Conclusion The concluding section brings together the critique and
calculations produced throughout the report, to conclude that there is a well evidenced
case to justify residential development on the former Manston Airport site, as part of wider
mixed use development.
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Housing Evidence
2.
Assessment of Housing Delivery
2.1
This section reviews the latest Thanet Local Plan
Monitoring Report (2014) in order to
understand the level of recent housing delivery within Thanet District. This provides important
context to housing provision in the District, and will identify trends in housing delivery which
could be likely to continue into the future.
Dwelling Completions
2.2
From 2006/07 - 2013/14 there were 4,227 net additional dwelling completions, which equates
to an annual average net completions rate of 528 over the 8 year period. This is shown below
in the dwellings completions chart taken from Monitoring Report, see Figure 1.
Figure 1 AMR Chart showing Dwelling Completions in Thanet, 2006/07 2013/14
Source: Thanet Local Plan Monitoring Report 2013
2.3
We note that the dwelling requirement identified in the above figure against which new
completions are benchmarked (7,500 over the period from 2006-26, which equates to 375
new dwellings per annum), is based on the South East Plan (2009), which was revoked in 2010.
As such, it is out-of-date.
2.4
Despite the out-dated nature of this South East Plan based benchmark, it is evident from
Figure 1 that there has been a declining trend in dwelling completions when comparing pre2010/11 and post 2010/11, with figures dropping to below the South East Plan requirement to
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Housing Evidence
just above 300 dwellings in 2011/12, and falling further to approximately 200 dwellings in
2012/13. The 2013 AMR predicted the delivery of 588 dwellings for the period 2013/14, however
the 2014 AMR reports that just 321 were completed (while recognising that this was an
increase on the 2012/13 low point).
Previously Developed Land Targets

2.5
The AMR also reports that 68.5% of homes in the reporting year (13-14) were completed on
previously developed land (below the stated target of 70%).
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Housing Evidence
3.
Published Housing Need Evidence
3.1
The purpose of this section is to set out a review of existing housing need evidence and
related publications, which comprises the following:
3.2
Strategic Housing Market Assessment (SHMA) for the East Kent sub-region (2009);
KCC (Thanet) Economic and Demographic Forecasts (2013);
Thanet District Council Housing Topic Paper (2013);
Thanet Local Plan Options Consultation (2014);
Thanet Local Plan Preferred Options Consultation (2015); and
Thanet Strategic Housing Market Assessment (SHMA) (2016).
It is worth noting that it is unclear what evidence underpins the level of housing provision
identified within Policy SP11 of the preferred option draft Thanet Local Plan (2015). This level
(12,000 additional homes) broadly aligns with scenarios within both the 2009 SHMA and the
2013 KCC Economic and Demographic Projections. Both of which were prepared prior to the
publication of the NPPF and/or NPPG and therefore do not align with strategic guidance on
preparing Local Plan evidence or use the most up to date (and therefore reliable) data.
(i) East Kent SHMA, 2009

3.3
A historic assessment of need is found within the East Kent Strategic Housing Market
Assessment (SHMA) (2009) (which informed the draft Local Plan).
This was prepared by
consultants ECOTEC in compliance with the CLG (2007) Strategic Housing Market Assessments
Practice Guidance, and in line with Planning Policy Statement 3 (PPS3) (both of which have
been superseded/are out-of-date).
3.4
The assessment included the Canterbury, Dover, Shepway, Swale and Thanet districts, in their
entirety, and produced conclusions at a range of geographic levels from the East Kent subregion down to the local housing market areas identified within the defined strategic housing
market area.
Findings & Recommendations

3.5
When assessing need, the SHMA initially calculates housing need figures based on the period
from 2006 10. For Thanet this determines gross backlog need of 6,004 dwellings, and annual
newly arising need over the five year period of 825 dwellings.
Incorporating the 5 year
backlog reduction Thanets net annual housing need is calculated at 1,544 dwellings.
Incorporating 10 year backlog reduction Thanets net annual housing need is calculated at
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690 dwellings.
Housing Evidence
These housing need figures are shown below in Table 1 and Table 2,
contextualised against those for the other four East Kent authorities which make up the
defined housing market area (a brief review of housing need in these four authorities is
detailed in Appendix 1).
Table 1 SHMA Table showing Housing Need Calculation
Canterbu
Dover
Shepway
Swale
Thanet
Total
3,248
5,968
5,671
5,739
6,004
26,630
650
1,194
1,134
1,148
1,201
5,326
1,276
578
585
884
825
4,149
452
283
402
315
482
1,934
1,473
1,489
1,318
1,717
1,544
7,541
ry
Backlog need
Annual quota of
backlog reduction
over 5 years
(Backlog need/5)
Total newly arising
housing need
Annual supply of
social sector re-lets
Net annual housing
need
Source: East Kent SHMA, 2009 (Table 12.7 Bringing the evidence together)
Table 2 SHMA Table showing Housing Need Calculation (re-calculated with 10 year backlog
reduction in line with South East Plan)
Canter
Dover
Shepway
Swale
Thanet
Total
3,248
5,968
5,671
5,739
6,004
26,630
325
597
567
574
600
2,663
1,276
578
585
884
825
4,149
497
394
481
601
735
2,708
1,104
781
671
857
690
4,103
bury
Backlog need
Annual quota of
backlog reduction
over 10 years
(Backlog need/10)
Total newly arising
housing need
Annual supply of
social sector re-lets
(current +10%)
Net annual housing
need
Source: East Kent SHMA, 2009 (Table 12.9 Housing need calculation re-calculated with a 10 year
backlog reduction in line with the South East plan)
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3.6
Housing Evidence
The SHMA projects forward these 2006-10 based need figures to cover the period from 2011-25
in three phases; 2011-15, 2016-20 and 2021-25. This is shown below in
3.7
Table 3. The main drawback of this forward projection is that it appears only to cover the
wider East Kent sub-region, without detailing the Local Authority specific housing need figures
as provided for the 2006-11 period.
Table 3 - Future Scenarios - Annual Need and Supply
Households in Housing Need
2011-15
2016-20
2021-25
Assuming no growth in affordable supply
High price scenario
Mid price scenario
Low price scenario
Need
15,900
15,600
15,200
Re-let supply
10,500
10,500
10,500
Balance
-5,400
-5,100
-4,700
Need
14,300
14,600
14,800
Re-let supply
10,500
10,500
10,500
Balance
-3,800
-4,100
-4,300
Need
11,100
13,100
14,500
Re-let supply
10,500
10,500
10,500
Balance
-600
-2,600
-4,000
Assuming high growth in affordable supply
High price scenario
Mid price scenario
Low price scenario
Need
12,700
12,300
11,900
Re-let supply
12,300
12,300
12,300
Balance
-400
400
Need
11,100
11,400
11,600
Re-let supply
12,300
12,300
12,300
Balance
1,200
900
700
Need
7,800
9,900
11,300
Re-let supply
12,300
12,300
12,300
Balance
4,500
2,400
1,000
Source: East Kent SHMA, 2009 (Table 12.5 Future Scenarios annual need and supply)
3.8
Table 4 shows the size specific balance between supply and need calculated within the
SHMA, identifying a shortfall in supply across all size categories in Thanet.
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Housing Evidence
Table 4 - Need and Affordable Supply by Dwelling Size

Canterbu
Dover
Shepway
Swale
Thanet
East Kent
616
399
530
531
876
2,951
176
124
145
91
294
831
-439
-274
-385
-439
-582
-2,120
29%
31%
27%
17%
34%
28%
280
176
307
381
209
1,353
199
51
80
47
39
416
-81
-125
-226
-334
-171
-937
71%
29%
26%
12%
18%
31%
234
245
279
325
333
1,417
79
121
95
87
381
-234
-166
-159
-230
-247
-1,036
0%
32%
43%
29%
26%
27%
656
788
489
648
487
3,068
68
28
56
79
63
294
-588
-759
-433
-569
-425
-2,775
10%
4%
12%
12%
13%
10%
140
164
115
147
120
686
ry
Total
need
1 bed
flat or
house
Available
supply
Supply
need
Supply /
need
Total
need
2 bed
flat or
house
Available
supply
Shortfall /
surplus
Supply /
need
Total
need
Available
2 bed
supply
house
Supply
need
Supply /
need
Total
need
Available
3 bed
supply
house
Supply
need
Supply /
need
4+bed
Total
house
need
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Housing Evidence
Available
12
-131
-164
-115
-144
-120
-673
6%
0%
0%
2%
0%
2%
1,926
1,772
1,720
2,032
2,026
9,475
452
283
402
315
482
1,934
-1,473
-1,489
-1,318
-1,717
-1,544
7,541
23%
16%
23%
16%
24%
20%
supply
Shortfall /
surplus
Supply /
need
Total
need
All
dwelling
types
Available
supply
Supply
need
Supply /
need
Source: East Kent SHMA, 2009
Critique of Need Assessment

3.9
This critique focuses on the SHMAs recommendations and analysis with regard to housing
need. .
3.10
The length of time that has passed since the publication of the East Kent SHMA in 2009 has a
number of implications for guidance compliance, methodology and data sources.
Guidance Compliance
3.11
The SHMA report was published in June 2009 prior to the publication of the NPPF and
subsequent NPPG. This has implications for the compliance of the SHMA methodology with
the latest policy and accompanying guidance, particularly the requirement for authorities to
calculate their own objectively assessed housing need and resulting market (and affordable)
housing requirements.
3.12
The SHMA was also undertaken at a time when the South East Plan 2009 (Regional Spatial
Strategy) identified a dwelling requirement target informing Local Plans, which was identified
as 6,500 dwellings for Thanet from 2006-2026. This level of regional policy has since been
abolished, with the South East Plan being revoked in March 2013. Aspects of the SHMAs
recommendations and findings were based on the South East Plan, so now require revision in
light of the changed policy context. The 6,500 dwelling target is also likely to understate
housing need considering that it was adopted 6 years ago, therefore it does not take into
account more recent trends in population growth and household formation rates and as such
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Housing Evidence
does not represent an appropriate benchmark for newly calculated housing need or housing
supply.
Data Limitations
3.13
The 2009 SHMA is based on the 2006 ONS population and household estimates, 2007 Kent
County Council forecasts, and a range of data from the 2001 Census, including travel to work
data and certain starting point migration figures. This data is now out of date and reliance on
it reduces the validity and relevance of the SHMAs need figures. Use of the latest mid-year
population and household estimates and sub-national population and household projections
is required to robustly calculate objectively assessed housing need and identify the most upto-date level of housing need possible.
3.14
Considering travel to work flows in particular, updated travel to work flow data from the 2011
Census is available, facilitating substantially more accurate assessments of housing market
areas. Whilst a full review of the SHMAs housing market area definition is not undertaken here,
it is suggested that the existing definition which does not incorporate 2011 Census travel to
work flows data, and is also contributed to by out-dated migration and house price levels
data, has reduced validity and robustness.
3.15
Considering the time that has passed since the existing SHMA was produced, a review of the
housing market area would be beneficial, particularly considering the importance which is
currently being placed on their accurate definition by Inspectors. Accurate housing market
areas are crucial in considering wider influences on housing need even when need is only
being calculated for a single district.
3.16
The East Kent SHMAs assumptions relating to household formation patterns are a key issue for
the robustness of the results and significantly undermine the continued relevance of the SHMA
projections and assessment of housing need and potentially its use in supporting the Local
Plan. Evidence suggests that household formation rates may have changed significantly since
the study was prepared as a result of intensifying affordability issues and recent levels of
under-supply of stock.
3.17
Results from the 2011 Census indicate that, contrary to expectation, average household size
remained constant between 2001 and 2011. Census 2011 showed that there was a greater
population level and lesser number of households than expected. The 2011 Census results,
and therefore the DCLG household projections, in this regard were impacted by long term
issues of affordability and the economic downturn, which could mean they can lead to
recommendations which could underprovide housing in certain areas.
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3.18
Housing Evidence
Consideration of the latest projections within the context of longer term pre-recession trends is
crucial in light of the impact the recession has had on household formation rates (as
demonstrated by Census data).
3.19
Alan Holmans TCPA paper New estimates of housing demand and need in England, 2011 to
2031 (Tomorrow Series Paper 16) provides an analysis of the potential impacts and influences
of the recession on household formation. It compares pre and post recession data to identify
the impact and consider whether an economic recovery will reverse recent trends. Overall it
considers how these impact both the affordability of housing and the ability to forecast future
housing need.
3.20
The 2014 RTPI Research Report Planning for housing in England: Understanding recent
changes in household formation rates and their implications for planning for housing in
England (Research Report no.1 Jan 2014) also considers the planning implications of these
observed changes in household formation rates.
3.21
Both reports suggest that using the 2011 Census data alone is likely to result in an underestimate of projections of future household need.
Therefore other data is required to
supplement analysis and arrive at an appropriate level of future need.

3.22
The detailed methodological aspects of household formation trends are considered later in
this section as part of the re-calculation of objectively assessed need. It is fair to assume here
that considering the influence of market and wider economic factors on household formation,
the SHMAs adopted household formation assumptions were set in a different context which is
no longer an accurate reflection of current and future household formation trends, which
reduces the robustness of the SHMAs projections and need outputs.
3.23
At a more general level, the SHMA projection period from 2006-10 is set within the context of
the credit crunch and economic downturn, yet we are now experiencing the transition
towards economic recovery.
This will significantly affect the population and household
projections upon which the SHMA was based (2006 based household estimates), the
presence/level of any uplift applied to demographic driven need figures, and therefore the
objectively assessed requirement for the District.
3.24
The relevance of the SHMA calculated figures is also reduced by the out-dated nature of the
Thanet specific need scenarios from 2006-10, and because the scenarios which go beyond
the current date to 2025 are only at the sub-regional East Kent level and do not provide district
level specific need figures.
Conclusions
3.25
The 2009 SHMA is out of date. The most specific issues with its outputs are as follows:
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Pre NPPF and NPPG publication;
Benchmarking of need against now abolished South East Plan requirement;
Reliance on out dated 2001 Census travel to work flows affecting HMA definition;
Out dated household formation rate assumptions; and
No indication of Thanet specific need beyond the 2006-10 period.
(ii) Economic and Demographic Forecasts (2013)

3.26
An updated assessment of need is found in the Economic and Demographic Forecasts

document for Thanet District Council, which was undertaken in February 2013 by Kent County
Councils Business Intelligence, Research & Evaluation Team.
3.27
In relation to housing, the forecast outputs from this document provide more up to date
population and household growth scenarios for Thanet District than the 2009 SHMA, with
various scenarios for Thanet Districts need for housing and jobs based on future projections.
Forecasting Outputs
3.28
The document demonstrates a range of forecast dwelling growth figures over the plan period
from 2011-31, with dwelling figures for 2031 ranging from 66,800 dwellings (in the zero net
migration scenario) to 75,000 dwellings (in the policy on scenario), having increased from the
2011 figure of 63,100 dwellings, see Table 5.
3.29
This range of dwelling growth figures translates to an additional dwelling requirement over the
plan period ranging from 3,700 new dwellings (zero net migration scenario) to 11,800 new
dwellings (policy on scenario), which is equated here to an annual requirement range from
185 to 5590 dwellings per annum.
3.30
However, the range of forecasting outputs from this document are not intended to provide a
single likely future housing need figure, as would result from an objectively assessed need
calculation in a SHMA, but instead to present estimated growth ranges from which Thanet
District Council can interpret need.
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Housing Evidence
Table 5 - Table Showing Forecast of Dwelling Growth for Thanet District, 2011-31
Scenario 1
Scenario 2
Scenario 3
Scenario 4
Scenario 5
Experian
Risk Based
Policy-on
Zero Net
Short Term
Baseline
Scenario
Scenario
Migration
Migration Trend
2011
63,100
63,100
63,100
63,100
63,100
2012
64,400
63,600
64,500
63,300
63,600
2013
64,700
63,200
65,000
63,500
64,100
2014
65,100
63,200
65,400
63,700
64,600
2015
65,500
63,400
65,800
63,900
65,200
2016
65,900
63,900
66,400
64,200
65,800
2017
66,600
64,600
67,200
64,500
66,500
2018
67,100
65,100
67,800
64,700
67,100
2019
67,700
65,700
68,500
64,900
67,700
2020
68,200
66,200
69,100
65,100
68,300
2021
68,700
66,700
69,800
65,300
68,900
2022
69,200
67,200
70,400
65,500
69,500
2023
69,700
67,600
71,000
65,600
70,100
2024
70,100
68,000
71,500
65,800
70,700
2025
70,600
68,500
72,100
66,000
71,300
2026
71,100
69,000
72,700
66,200
71,900
2027
71,600
69,500
73,300
66,300
72,600
2028
72,000
69,900
73,900
66,500
73,100
2029
72,400
70,300
74,400
66,600
73,700
2030
72,800
70,700
74,800
66,700
74,200
2031
72,800
70,800
75,000
66,800
74,800
9,700
7,600
11,800
3,700
11,600
15.3
12.1
18.7
5.9
18.4
Change
2011-31
% Change
Source: Economic and Demographic Forecasts (2013) Table 10.
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Forecasting Critique
3.31
This document provides an update to the forecasting undertaken in the East Kent SHMA
(2009). It forecasts the population and dwelling requirements for Thanet District from 2011-31,
incorporating demographic population led-scenarios based on future population trends and
economic job-led scenarios based on future levels of job growth. It considers five scenarios;
three Experian job led and two demographic led, reviewing the Thanet Economic and
Employment Assessment in November 2012 to understand the housing and labour supply
needed to meet/support the growth options from the scenarios within this assessment.
3.32
The POPGROUP and Delivered Forecast model is adopted, using 2011 base year and 2011
mid-year population estimates as the base variables (significantly more recent than the base
data in the East Kent SHMA). A cohort survival methodology is adopted and standard data
sets are used including ONS, CLG, Experian, Nomis, Kent County Council and Thanet District
Council sources.
3.33
Whilst much of the data used in the forecasting scenarios is more up to date than in the 2009
East Kent SHMA, there are a number of data elements which reduce the continued relevance
and robustness of the forecasting and its outputs.
3.34
Economic activity rates are based on 2001 Census rates, rolled forward using ONS labour force
projections, now superseded by the availability of 2011 Census data.
The 2008 based
household projections and the 2010 based sub national population projections are now out of
date and the 2011 based interim household projections and 2012 base sub national
population projections replace them as the latest household and population data.
3.35
The commuting ratio (residence to workplace) is calculated as part of the forecasting

process, yet as for the existing SHMA when examining commuting patterns, this is based on
2001 Census results because the 2011 Census was released after the forecasts publication.
Experian evidence is also incorporated, however there is still significant uncertainty
surrounding the calculated commuting ratio which would be addressed by incorporating
2011 Census based commuting data.
3.36
The other key issue to note is that the forecasts used represent low employment growth
scenarios which are not the most appropriate for Thanet. Scenario 1 Experian Baseline only
adopts 0.5% growth in the first decade and 0.2% in the second decade, equating to 3,100 net
additional jobs over the 2011-31 period. Scenario 2 Risk based only adopts 0.1% growth in
the first decade and 0.2% in the second decade. Scenario 3 Policy on adopts the highest
level of employment growth in these forecasts, with 5,100 net additional jobs over the 2011-31
period, and Scenarios 4 and 5 are migration based so do not incorporate employment growth
into their scenarios.
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(iii) Thanet District Council Housing Topic Paper (2013)

3.37
The Thanet Housing Topic Paper was produced in May 2013, acting as a background
document to the preparation of the draft Thanet Local Plan. The document is set within the
context of the NPPF, considering the need for a housing update to the Local Plan. It makes
reference to the Kent and Medway Housing Strategy (2012-2015), the East Kent Sustainable
Community Strategy (2009) and Thanet District Councils 2012-16 Corporate Plan, and the
Thanet specific findings of the existing East Kent SHMA.
3.38
The Paper does not update the need assessment for Thanet in terms of providing outputs, but
it does support the case for an updated assessment of need. Its reference to the existing
assessment of need in the East Kent SHMA emphasises how the preparation of the SHMA in a
very different policy and guidance context renders it now out-dated, and considering the
current context suggests it is likely to underestimate the housing need identified for Thanet
District.
3.39
The Paper makes reference to the review of the SHMA and its findings. It supports one of the
SHMAs conclusions, as shown below, which aligns with the notion of Thanets under-delivery
of the required level of housing, resulting in unmet need.
3.40
The 2009 SHMA indicated that existing and arising need for affordable housing in the sub
region is so high that it is inconceivable that it could be met. The validity of the conclusions
and recommendations of the SHMA are currently being reviewed, but it is anticipated that this
conclusion will be re-affirmed (page 9.)
(iv) Thanet Local Plan Options Consultation (2014)

3.41
The Issues and Options Consultation on Thanets new Local Plan was undertaken from 3rd
June to 14th August 2013. The key Options paper relevant for review here is Issue 8 How
many homes do we need to provide?
3.42
The Issue 8 paper details the abolition of the South East Plan and therefore, the need to move
beyond the housing targets which it contained, and base Local Plan housing targets on NPPF
compliant objectively assessed need. As for the Housing Topic Paper, this document does not
update Thanets need assessment in terms of providing outputs, but again emphasises the
requirement for updated assessment.
3.43
In relation to considering the future number of households and resultant housing need the
paper refers to the existing East Kent SHMA (2009), supplemented by the updated
demographic and economic modelling (Economic and Demographic Forecasts 2013). In
reference to these forecasts it aligns with the understanding that although the basis of the
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updated forecasting brings the projected future households figures much more up to date
than those within the existing SHMA and provides a better indication of the range of future
household need in Thanet, in order to reach the most robust housing need figure within
Thanets new Local Plan further re-calculation of housing need using the newly released 2011
Census data is required.
(v) Thanet Local Plan Preferred Options Consultation (2015)

3.44
The Draft Thanet Local Plan to 2031 (DTLP) (Preferred Option) was consulted on in early 2015.
Housing Strategy
3.45
The Housing Strategy section of the DTLP sets out how the Local Plan seeks to meet the
housing needs of Thanet alongside other partners, including the Councils housing
regeneration, empty property and strategy functions (page 53).
3.46
In relation to the housing quantum to be provided over the plan period, the DTLP reflects
forecasts based on recent migration trend based population projections and the labour
requirements supporting the Councils aspirations for economic and employment growth
(page 53). These forecasts are contained within the Economic and Demographic Forecasts
(2013) document. As discussed earlier, this document undertakes forecasting using a NPPF
and NPPG compliant methodology to consider three Experian job led and two demographic
led scenarios.
3.47
Although it represents a substantial update to the forecasting inputs to the housing need
figure identified in the existing East Kent SHMA (2009), it relies on 2008 based household
projections and 2010 based sub national population projections, both of which are now out of
date 1. Economic activity rates and commuting data were sourced from the 2001 Census, and
both of these factors now have been updated by data published from the 2011 Census. The
forecasting also uses forecasts which show low employment growth which are also
significantly out of date.
3.48
As shown in Table 6, Policy SP11 of the Housing Strategy in the DTLP identifies a target provision
of 12,000 new dwellings over the plan period from 2011-3, split evenly into the delivery of 3,000
new dwellings over each 5 year period. It is unclear which evidence document is used to
justify this level as it does not directly align with either the 2009 SHMA or 2013 Demographic
forecast scenarios.
A total of 12,000 homes equates to delivery of 600 new dwellings per
annum.
A detailed critique of these population and household projections is undertaken the following sub-section; Recalculation of Objectively Assessed Housing Need
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Table 6 Draft Policy SP11 - Housing Provision
Additional
2011-16
2016-21
2021-26
2026-31
Total
3,000
3,000
3,000
3,000
12,000
S homes
S
o
Source: Draft Thanet Local Plan: Housing Strategy section (page 53)
3.49
Reference is made to the land availability identified in the Strategic Housing Land Availability
Assessment, to demonstrate that the 12,000 housing target is deliverable in sites within the
District over the plan period.
3.50
The DTLP also relies substantially on the existing East Kent SHMA (2009), particularly in relation to
the type and size of dwellings (for market and affordable homes), Policy SP18 Type and Size
of Dwellings, and the provision of affordable homes, Policy SP19 Affordable Housing.
(vi) Thanet Strategic Housing Market Assessment (2016)

3.51
In January 2016, Thanet District Council published a Strategic Housing Market Assessment
(SHMA) providing its latest position on the future need for housing in the district. The SHMA, the
first such update to the Councils evidence base since 2009, provides an assessment of the
quantum and type of housing needed in Thanet over the period 2011 to 2031.
3.52
The document is prepared in line with the stages set out in thePPG) and provides a stepped
approach to understanding full objectively assessed housing need (OAN) starting with the
DCLG Household Projections and making a number of adjustments to take account of
variations in demographic trends, future economic growth and the effect of improvements to
affordability and housing supply on household formation. Whilst the SHMA largely follows the
correct approach, there are a number of concerns about the specific assumptions employed
in the SHMAs demographic and economic model which means it will not meet the likely
future change in employment growth across the projection period.
3.53
The SHMA starts with an assessment of the latest housing projections; the DCLG 2012
Household Projections (HP). Over the period 2011 to 2031, the 2012 HP project a need for 749
dwellings per annum. The 2012 HP contain both population and household formation
projections which use trend-based data. The population projections use short term trends
(from the last 5 to 6 years) whereas the household formation projection utilise longer term
trend data, dating back to the 1971 Census. The SHMA assesses past population data to
understand if the last 5 to 6 years represents an appropriate basis for future population growth.
It identified that net migration from London fell following the recession and that this was likely
to be a short-term effect which would reverse over time as the wider economy of Kent
improved (relative to London). Furthermore, the Greater London Authority, in the recently
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adopted Further Alternations London Plan, assumed that out migration from London would
increase as the economy improves. With this in mind, the SHMA alters the 2012 HP to assume
an increase in migration from London takes place over the plan period, in line with the GLAs
assumptions. This results in a 1% increase in population growth over the projection period and
a requirement to delivery 777 dwellings per annum (a 4% increase in housing need). Whilst an
adjustment to migration rates to understand increased net migration from London is
appropriate, it would be instructive to understand the implications of long term migration
trends more widely as well as the impact of un-attributable population change (see below).
This is a shortcoming of the SHMA as currently drafted.
3.54
The SHMA then assesses the likely change in job growth over the projection period which is
takes from the East of England Forecasting Model (Autumn 2014). This model forecasts that
4,800 jobs would be created over the projection period (2011 to 2031), which equates to
employment growth of around 0.5% per annum. The SHMA notes that this level of employment
growth is notably below the 0.8% per annum achieved historically (1993 to 2010) however
this growth was supported by relatively a high level of public sector employment growth.
3.55
GVAs Employment Land Use Evidence Base report which is submitted with the application
and explores economic trends in Thanet shows that future employment growth is likely to be in
excess of 7,000 across the plan period (2011 to 2031) i.e. 47% higher than the East of England
Forecasting Model. The Future Employment Role report provides the justification for this level of
employment growth however this report will consider the housing need implications of
delivering 7,000 jobs in Thanet up to 2031.
3.56
Translating employment growth into population growth is not straightforward and involves
making assumptions about unemployment, commuting, economic activity and double
jobbing and how these change over time. The SHMA makes a number of assumptions around
these issues which seem largely sensible however with regard to double jobbing it uses the
Annual Population Survey. The Annual Population Survey is not a survey of workers (as the
SHMA suggests) but a survey of residents. The double jobbing figure of 5.1% is therefore for a
different population. The East of England Forecasting Model provides some indication of
double jobbing levels for workers in Thanet and concludes that it lies around 1.2% (average of
2011 to 2031). This would seem an appropriate starting point for the analysis.
3.57
Section 6 of the SHMA looks at market signals which are designed to assess whether the
housing market is demonstrating market undersupply relative to demand. It looks at house
prices, rents, affordability, housing supply and overcrowding. It concludes that the whilst some
market signals show a housing market which is relatively affordable and accessible, a number
of indicators show pressure in the housing market including increased levels of overcrowding
and concealed households. Another issue which is identified in the SHMA is the fall in
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household formation amongst young adults (25 to 34 year olds). Overall the SHMA concludes
that an adjustment to past demographic trends is appropriate to understand the effect of
improvements to the housing market on household formation and to therefore ensure the
FOAN plans for it. The adjustment the SHMA makes is to increase household formation in 25 to
34 year olds so that they return to 2001 levels by 2025 where after projected rates are linked to
the trend within the 2012 HP. The justification for this is to project an improvement in
affordability and supply to that exhibited at the late 1990s / early 2000s.
3.58
Figure 2 shows recorded household formation over time (1991 to 2011) with projected
household formation up to 2033. There are many things that have affected household
formation in this country over time including changes in family make-up, inter-generational
households, ethnicity and housing behaviour linked to constrained housing supply and
accessibility. The main age group affected by the lack of supply are 25 to 34 year olds, as this
age group is statistically the most likely to remain in the family home or live in larger shared
houses and this reduces their household representative rate (the chance of them being the
head of a household, HRR). It can be seen by Figure 2 that between 1991 and 2001 HRRs in 25
to 34 year olds increased, however between 2001 and 2011/12 they fell again. Between 2011
and 2031 (the SHMAs projection period) the 2012 HP project that household formation will
increase and fall again. This is the trend that the SHMA follows when it tracks the 2012 HP rate
after 2025.
3.59
Figure 2 shows the 2008 HP HRR projection alongside the 2012 HP projection. This projection
shows an overtly more positive trajectory for HRRs in this age group, which would be the
response to a significant increase in housing supply. The SHMA should therefore follow the 2008
HP projection following its HRR adjustment up to 2025.
Figure 2 - Household Representative Rates from 2012, 2011-interim and 2008 HP (DCLG)
15-24
25-34
0.2
0.6
0.15
0.55
0.1
0.5
0.05
0.45
2012 HP
2008 HP
2012 HP
35-44
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2008 HP
1991
1993
1995
1997
1999
2001
2003
2005
2007
2009
2011
2013
2015
2017
2019
2021
2023
2025
2027
2029
2031
2033
0.4
1991
1993
1995
1997
1999
2001
2003
2005
2007
2009
2011
2013
2015
2017
2019
2021
2023
2025
2027
2029
2031
2033
45-54
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0.65
0.7
0.6
0.65
0.55
0.6
0.5
0.55
2012 HP
2008 HP
2012 HP
55-59
60-64
0.7
0.7
0.65
0.65
0.6
0.6
0.55
0.55
2008 HP
75-84
0.7
0.83
0.65
0.78
0.6
0.73
0.55
0.68
2012 HP
2008 HP
1991
1993
1995
1997
1999
2001
2003
2005
2007
2009
2011
2013
2015
2017
2019
2021
2023
2025
2027
2029
2031
2033
0.5
3.60
2008 HP
2012 HP
0.63
2008 HP
1991
1993
1995
1997
1999
2001
2003
2005
2007
2009
2011
2013
2015
2017
2019
2021
2023
2025
2027
2029
2031
2033
65-74
2012 HP
0.5
1991
1993
1995
1997
1999
2001
2003
2005
2007
2009
2011
2013
2015
2017
2019
2021
2023
2025
2027
2029
2031
2033
0.5
1991
1993
1995
1997
1999
2001
2003
2005
2007
2009
2011
2013
2015
2017
2019
2021
2023
2025
2027
2029
2031
2033
2012 HP
2008 HP
1991
1993
1995
1997
1999
2001
2003
2005
2007
2009
2011
2013
2015
2017
2019
2021
2023
2025
2027
2029
2031
2033
0.5
1991
1993
1995
1997
1999
2001
2003
2005
2007
2009
2011
2013
2015
2017
2019
2021
2023
2025
2027
2029
2031
2033
0.45
In conclusion, the 2016 SHMAs approach broadly follows the correct stages within national
planning guidance:
It starts with the DCLG Household Projections (749 dpa).
It then makes adjustments to the demographic assumptions (increase to 777 dpa).
It assesses projected labour supply against the likely change in job numbers and
concludes that no increase is justified. However, GVA considers that employment growth is
likely to be around 47% higher than the SHMA has concluded which suggests that an
increase would be justified.
An assessment of market signals has concluded that there are indicators of pressure in the
housing market including overcrowding, concealed households and falls in HRRs in
younger demographics. An adjustment is made to HRRs to model an improvement in
market signals (increase to 783 dpa), albeit GVA does not consider this goes far enough as
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the 2012 HP HRRs which the SHMA tracks, shows a fall in HRRs in the end of the projection
period.
3.61
It concludes with the identification of OAN for 785 homes per annum, equivalent to 15,700
homes over the 2011-31 period (the above figures are rounded to the nearest 5
dwellings/annum).
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4.
Housing Evidence
GVA Calculation of Objectively Assessed Housing

Need
4.1
Overall this report concludes that the existing evidence base, including the 2016 Thanet
SHMA, does not fully and objectively assess housing needs in Thanet.
4.2
In the absence of this, this section provides an objective assessment of housing needs for the
District. The NPPF and PPG requires housing needs to be met at the housing market area
(HMA) level, however this re-calculation focuses solely on the need for Thanet District Council.
It does however consider the housing stock and active market context of the East Kent
housing market area, acknowledging the Manston site as a potential sub-regional housing site
which could meet the needs of the wider HMA as well as those solely for Thanet.
4.3
This assessment uses a fully PPG compliant methodology with GVAs bespoke demographic
and economic model. It uses the latest population and household projections and the latest
data which takes account of demographic, housing and economic trends. The methodology
will apply the staged approach espoused by the NPPG which is explained in more detail
below but which commences with an assessment of DCLG household projections, and tests
these projections against the extent to which they support labour force growth, improve or
maintain affordability and meet the needs of households unable to access market housing.
The staged process results in an objectively assessed housing need for the district which
provides a policy-off interpretation of housing needs.
4.4
As set out above, the NPPF and NPPG sets out a detailed methodology for undertaking an
assessment of housing need in an area. GVA has summarised some of the key requirements
and statements from the NPPG which provide some context as to the required approach.
National Guidance
The primacy of the up to date SHMA
Local planning authorities should [] assess their full housing needs, working with
neighbouring authorities where housing market areas cross administrative boundaries. The []
Assessment should identify the scale of housing that the local population is likely to need
over the plan period which:
meets household and population projections, taking account of migration and

demographic change;
addresses the need for all types of housing, including affordable housing ; and
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caters for housing demand and the scale of housing supply necessary to meet this
demand. (Paragraph 159 NPPF)
The assessment of housing and economic development needs includes the Strategic
Housing Market Assessment requirement as set out in the National Planning Policy Framework
(NPPG Ref. ID 2a-001-20140306)
What is housing need?
The primary objective of an assessment of housing needs is to identify the future quantity of
housing needed (NPPG Ref. ID 2a-002-20140306).
Need for housing in the context of the guidance refers to the scale and mix of housing that
is likely to be needed in the housing market area over the plan period and should cater for
the housing demand of the area and identify the scale of housing supply necessary to meet
that demand. (NPPG Ref. ID 2a-003-20140306)
The assessment of development needs is an objective assessment of need based on facts
and unbiased evidence. Plan makers should not apply constraints to the overall assessment of
need, such as limitations imposed by the supply of land for new development, historic under
performance, viability, infrastructure, or environmental constraints (NPPG Ref. ID 2a-00420140306)
What should the assessment include?
4.5
The starting point for an assessment of housing need should be the Household Projections
(NPPG Ref. ID 2a-015-20140306). Adjustments should then be made to understand the impact
of future changes to demographic and migration trends (NPPG Ref. ID 2a-017-20140306)
employment growth (NPPG Ref. ID 2a-018-20140306) and market signals (NPPG Ref. ID 2a-01920140306). The assessment should also consider the implications for affordable housing (NPPG
Ref ID 2a-029-20140306) however, as this is focussed on overall need and does not constitute a
full strategic housing market assessment, affordable requirement calculations are not
undertaken.
How should historic undersupply be dealt with?
4.6
4.7
The NPPG cautions that past trends including undersupply and worsening
affordability - may have artificially suppressed household formation rates and therefore could
affect future projections. The guidance states:
The household projection-based estimate of housing need may require adjustment to reflect
factors affecting local demography and household formation rates which are not captured in
past trends. For example, formation rates may have been suppressed historically by undersupply and worsening affordability of housing. The assessment will therefore need to reflect the
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consequences of past under delivery of housing. As household projections do not reflect

unmet housing need, local planning authorities should take a view based on available
evidence of the extent to which household formation rates are or have been constrained by
supply. (NPPG Ref. ID 2a-015-20140306)
4.7
To conclude, an assessment of housing needs must be objective and must identify demand
and therefore housing need in full. It should not seek to include metrics or measures which
apply restraint. It should be realistic that is to say identified supply should meet demand and
be based on realistic assumptions about future population and housing change.
4.8
The methodology has the following steps:
Assess the latest household projections and their assumptions to understand if they could
be an appropriate measure of future population and household growth in the subject
area. This includes an assessment of issues which may have affected past trends such as
economic recession, affordability and past housing supply / policies.
Review past economic performance and employment forecasts to understand if

projected working age population can support economic growth in the subject area. If
there is projected to be a shortfall, this could provide a justification for increasing housing
delivery.
Assess housing market signals to understand the balance between housing demand and
supply. If indicators such as house prices, rents, affordability and overcrowding show that
demand for housing is outstripping supply relative to the surrounding area and nationally
this could provide a justification for increasing housing delivery.
ONS/DCLG Projections
4.9
The latest full population projections available from the Office of National Statistics (ONS) are
the 2010-based Sub-national Population Projections (SNPP) and the 2012-based SNPP. Both
projections use different assumptions of fertility, mortality and migration based on trends from
the previous five/six years and start from a different base population. The 2012 SNPP was
published in May 2014 and takes into account 2011 Census data making it a much more
reliable basis for projections notwithstanding local factors which may have affected past
trends and therefore future projections.
4.10
The SNPPs are not forecasts and do not take any account of future government policies,
changing economic circumstances or the capacity of an area to accommodate the change
in population. They provide an indication of the future size and structure of the population if
recent demographic trends continue. Projections become increasingly uncertain the further
they are carried forward, and particularly so for smaller geographic areas such as districts.
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4.11
Housing Evidence
Population projections provide a basis through which to understand future population

change. As discussed above, household projections provide a basis through which to
understand how that population change affects household formation. This is because as a
population changes (both in terms of size and structure) the number of dwellings needed to
house that population also changes. For example, a population with a high proportion of
people in their late teens is likely to need less housing than a population with a high proportion
of 70 year olds. This is because the former demographic often lives with parents and/or in
shared houses, whereas the latter is more likely to live as a couple or alone. These probabilities
shift over time as a result of cultural changes in the population. For example, divorce amongst
30 and 40 year olds has been increasing over time which has increased the need for housing
in this demographic, as when a family or couple splits up you have two households to
accommodate rather than one.
4.12
The household projections contain assumptions by age and sex about how household
formation will change over time. These assumptions are built up through analysis of the Census
and Labour Force Survey. As discussed above, there are three household projections
published by DCLG to consider: the 2008-based household projections, 2011-based interim
household projections and 2012-based household projections. Further information on each of
the projections is outlined in Table 7 with the results for each illustrated in Figures 1-4 and Table
8.
4.13
The published 2011-based household projections were interim reflecting known quality issues
and hence they only project to 2021. The House of Common Library (Social Policy Section)
states that:
4.14
Interim household projections for 2011 to 2021 (based on the 2011 Census) indicate that the
number of households grew more slowly than anticipated by the 2008 projections this is likely
to be a reflection of the severity and extent of the post-2008 economic downturn. The 2008based projections are still regarded as a solid indicator of potential levels of housing demand
over coming years. (Standard Note SN06416)
4.15
The 2012-based Household Projections provide an update to the 2011-based interim

projections and project over a longer term period (2012 to 2037). As can be seen from Figure
2, they provide a different interpretation of household formation to the 2011-based
projections.
4.16
Table 7 provides an introduction to the different projections and the assumptions they use to
project population and household change.
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Table 7 - National Population and Household Projections

Projection
Features
Household
2008 Used the 2008-based population projections as a base

based
Household formation rates trended from 1971, 1981, 1991 and 2001
household
Censuses and Labour Force Survey data.
projections
Long-term projection from 2008 to 2033
Average annual household growth between 2011 and 2031 = 680 for
Thanet
2011 Used the interim 2011-based population projections as a base
based
Household formation rates trended from 1971, 1981, 1991, 2001 and 2011
interim
Censuses and Labour Force Survey data which resulted in lower household
household
projections
formation rates than the 2008-based household projections.
Short-term projection from 2011 to 2021
Thanet
2012 Used the 2012-based population projections as a base
based
Household formation rates trended from 1971, 1981, 1991, 2001 and 2011
household
Censuses and Labour Force Survey data which resulted in lower household
projections
formation rates than the 2008-based household projections.
Thanet
2010based
SNPP
Population
Used demographic trends from 2005 to 2010
Included improved migration assumptions making use of administrative
data sources to better assign student populations and international
migrants to local authorities.
Average annual population growth between 2011 and 2031 = 926 for
Thanet
2012based
SNPP
Used demographic trends from 2007 to 2012

Included improved migration and natural change assumptions taken from
the 2011 Census.
Average annual population growth between 2011 and 2031 = 1,205 for
Thanet
Source: DCLG Live Tables and ONS SNPP
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Population Projections
4.17
The latest official projections come from the ONS 2012-based SNPP. Figure 3 provides a
comparison between the 2010-based and 2012-based SNPP showing clearly that the 2010based projection (based on estimates about population growth built up from the 2001
Census) significantly underestimates both the base population in 2012 (which has been
updated by the 2011 Census) and then projects that forward with a more depressed growth
trajectory over the years to 2035. The 2012-based SNPP (based on estimates about population
change built up from the more recent 2011 Census) shows that the population of Thanet is
projected to grow at a much faster rate than previously assumed - this is confirmed by Table 7
which shows annual growth rates increasing 28% from the 2010 SNPP to the 2012 SNPP.
Figure 3 - Comparison of the 2010-based and 2012-based SNPP for Thanet
Source: ONS SNPP 2010 & 2012
4.18
Population projections are made up of two principal components, natural change (births
minus deaths) and migration. Natural change is accurately recorded and more easily
projected given the relative predictability of fertility and mortality rates in a given population.
Migration however is significantly more difficult to estimate (particularly at the subregional/district level) and therefore to project. Table 8 provides a comparison between the
SNPP population projections and trends in migration estimates from the ONS mid-year
population estimates (MYE) which actually estimate the first year of the 2012 SNPP.
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4.19
Housing Evidence
It is clear from the mid-year estimates in Table 8 that the 2010 SNPP is likely to underestimate
migration and therefore population change going forward (as the population grows and
migration grows with it). The 2012 SNPP appears to be a much better reflection of past net
migration particularly once UPC 2 is factored in. Figure 4 sets out the mid-year estimates in
more detail and shows in combination with the migration data in Table 8 that due to
significant fluctuations in net migration (particularly pre/post-recession) the 2012 SNPP, on the
balance of evidence, provides a reasonable set of assumptions about future trends.
See previous footnote
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Table 8 - Comparison of Net Migration between revised Mid-Year Estimates (observed

migration), 2010-based and 2012-based SNPP (projected migration) for Thanet
2001 -
2007 -
2011
2016 -
2021 -
2026 -
2031 -
2014
2014
20 15
2020
2025
2030
2035
Mid-Year Estimates
1,073
1,120
MYE (plus Un-attributable

change (UPC) 3)
1,114
1,153
2010 SNPP
800
840
980
1000
1000
2012 SNPP
1,000
1,080
1,100
1,140
1,120
Source ONS Mid-Year Population Estimates 2002 to 2013 and SNPP
Figure 4 - Components of Change 2001 to 2013

2000
1500
1000
500
-500
-1000
UPC
International migration
Natural change
Population change
Domestic migration
Source: ONS Mid-Year Estimates
Household Projections
4.20
The DCLG 2012-based household projections provide quantitative assumptions about how the
population of Thanet will form households over the 25 years from 2012. They are based on
Census data from 1971 onwards and include the slow-down in household formation observed
between 2001 and 2011. Figure 5 provides a comparison between the 2008, 2011 and 2012
household projections.
Un-attributable population change is population change that occurred between the 2001 and 2011 Censuses but which ONS
cannot attribute to either migration or natural change. When looking at past trends this throws up a problem as clearly this
change occurred and so to not account for it in any way is to potentially misinterpret past population change. This scenario
seeks to include UPC (but only 50% of it) as net migration as ONS has concluded that due to the difficulties in recording
international migration at least part of UPC is likely to due to be this component of population change.
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4.21
Housing Evidence
It should be noted that the underlying population projections that fed into the household
projection are different, with the 2008 household projections having greater levels of
household formation but lower levels of population growth. Despite this, and as shown in
Figure 5 , the 2008 HP show lower levels of overall household growth. This shows that when all
other factors are the same, the 2008 HP provide more buoyant assumptions about household
formation. Notwithstanding, the 2008 HP are still a useful basis on which to understand longer
terms household formation rates given the constrained nature of recent household formation
which have been overly influenced by the recession and associated economic constraints in
the housing market.
Figure 5 - Comparison between the 2008 and 2011 Household Projections from 2012 2033
76,000
74,000
72,000
70,000
68,000
66,000
64,000
62,000
60,000
2008
2011
2012
Source: DCLG Household Projections
4.22
The published 2012 HP project annual growth of 689 households (equating to a dwelling
requirement of around 735 per annum) between 2011 and 2031 however since the
publication of the 2012 SNPP in 2014, two further sets of mid-year population estimates have
been published (2013 and 2014). The demographic model can be constrained so that it tracks
for the first 3 years of the projection (2011 to 2014) the mid-year population estimates. When
the model is re-ran, it produces an annual requirement of 749 dwellings per annum.
Alternative Migration Trends

4.23
As part of this assessment GVA has reviewed past migration trends on the basis of all data
since 2001/2. This is because the 2012 SNPP uses local migration data from principally the last
5/6 years. Some caution has to be observed when challenging the migration assumptions
within the SNPP. This is because the SNPP is multi-regional and considers not only past trends
but how those trends have and will be influenced by the changing demography in
surrounding areas. Notwithstanding this, it is useful to consider the implications of household
growth if past trends are to continue. Furthermore, GVAs model takes into account the
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changes demography and age structure of the UK and its relationship to migration into
Thanet. GVA model projects forward alternative migration trends using age specific migration
rates (i.e. the number of people of a given age and sex migrating in or out of an area per
1000 of the population at risk 4).). This method ensures that as the demographic make-up of
Thanet and the UK changes, so does its migration flows. The scenarios both include and
exclude UPC which as discussed above, has positively contributed towards past population
growth.
Table 9 - Annual Housing Needs, Long Term Migration Trends, 2011-31 (2012 HP HRRs)
Annual Dwelling Needs 2011 to 2031
Without UPC
With UPC
Mid-Point
776
791
784
Long term (2001 to 2014)

Source: GVA / ONS MYE
4.24
Table 9 shows that on the whole, long term migration (including recent migration trends post
2012) has exceeded the 2012 SNPP and even more so when UPC is included. The long term
scenario covers a period which includes both recession and growth and therefore provides a
longer term view of demographic trends through the economic cycle. This is important given
the Districts proximity to and relationship with Greater London whose migration flows are
heavily affected by the economic cycle, as shown in Figure 6. Given the uncertainty around
how much of UPC is due to migration error and how much is due to the Census, it is
considered that it should be factored into future projections but that a mid-point between the
scenarios which include and exclude the UPC (i.e. between 776 and 791 dwellings per
annum). This would produce a demographic requirement of 784 dwellings per annum using
the 2012 Household Projections HRRs.
The Population at Risk is either the population of Thanet when considering out-migration or the UK when
considering domestic in-migration. International migration is calculated by assuming a constant level of
migration with the profile of migrants taken from average migration between 2001 and 2014.
4
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Figure 6 - Net Internal Migration, London Since 1975

.
-20000
-40000
-60000
-80000
-100000
-120000
-140000
1975/76
1980/81
1985/86
1990/91
1995/96
2000/01
2005/06
2010/11
Source: Calculated from NHSCR data for London as defined as GLA area: Tony Champion Newcastle
University 2014
4.25
The NPPG states that the DCLG household projections should form the starting point for any
assessment of housing need. The published 2012 HP project a need for 712 dpa between 2011
and 2031. When these projections are updated with the latest mid-year population estimates
for Thanet they increase the annual dwellings need to 749 dpa over the projection period.
Taking account of longer term migration trends increases the annual housing need to
between 776 and 791 dpa depending on whether UPC is accounted for. A long term
migration scenarios is appropriate as it covers a full economic cycle and given the
uncertainty around UPC, it is considered that a mid-point should be assumed between UPC
included and excluded. Overall this results in demographic need for 784 dpa between 2011
and 2031. The next stage of this assessment will look at economic growth and whether there is
a case for increases to this figure further to achieve economic growth.
Economic Growth
4.26
Economic growth and household growth are inextricably linked. This is because as an
economy grows so does the requirement for labour force, and this requirement drives
migration and population growth. Furthermore, the PPG states that OAN should take into
account the likely change in employment and ensure that the projected labour force is
sufficient to meet this employment growth.
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4.27
Housing Evidence
GVAs The Future Employment Role of the Former Manston Airport report provides a detailed
assessment of future employment growth in Thanet and estimates past job growth and
forecast how many jobs might be created in the future.
4.28
Future job growth is considered in Table 10. This sets out the anticipated level of job growth
that is forecast to occur in Thanet.
Table 10 Thanet Forecasted Employment Growth 2013 to 2031 Experian Job Forecasts
Total job growth
7,032
Total
percentage
change
Annual job
growth
Average annual
percentage
growth
15.2%
352
0.72%
Source. GVA Employment Forecasts
4.29
To understand the relationship between jobs, labour force and population growth, a number
of assumptions need to be made, for example, the level of unemployment and economic
activity in the local population, and the extent to which the working population is employed
locally (commuting rates).
Unemployment
4.30
The level of unemployment over time is important for understanding the link between
population growth and job growth. For example, if 100 jobs were created in an area, and
unemployment rates were historically high, it is likely that a significant proportion of those jobs
would be taken by unemployed residents who are seeking employment. If on the other hand
unemployment were at a historic low, more of the 100 jobs would need to be filled by new
economically active people moving/commuting into the area to work. If people move to an
area for work, this creates a need for more housing.
4.31
The unemployment rate in 2011 was 9.9% according to the 2011 Census. The Annual
Population Survey recorded a figure of 22.2% and there is therefore doubt about the
accuracy of this figure. Unemployment is assumed to fall over the period to 2020 to 7.5% (prerecession average) where it remains static.
Economic Activity
4.32
The same principle applies to economically active persons (which are the total number of
people in work or looking for work) as unemployment. As the economically active population
increases (due to a rising number of older persons supplementing their pension for example, or
an increasing number of women working instead of raising families full time) the pool of local
labour increases, reducing the need for in-migration to support increases in the number of jobs
in a local area. Reduced in-migration means fewer migrants to house.
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4.33
Housing Evidence
Economic activity by age and sex is taken from the 2011 Census. This is projected forward
using trends from the 1981 Census, as well as assumptions from the 2012 European Union
Ageing Report and 2006 Labour Force Projections. The results show continuing increases in
economic activity amongst older males (+55 year olds) and females (+20 year olds). The
largest increases are observed in those at the current Statutory Pension Age, as this is due to
increase in both males and females over the period to 2028. This being the case it is likely that
increasing number of males and females will work or seek to work for longer.
4.34
Figure 7 provides economic activity rates by age and sex for Thanet from the Census going
back to 1981 (the earliest point at which accurate data is available). As is apparent from the
data, economic activity in males under 50 has changed little over the past 30 years with the
exception of slight fall since 1981. In males over-50 economic activity has increased with the
most significant increases in 60 to 74 year olds. These trends in older men are continued in the
projection whereas under-50s remain static.
4.35
In females economic activity has changed significantly since 1981, principally showing two
phenomena. The first is the increasing number of females choosing to work during their most
fertile years (20 to 40) and the increasing age at which the family career break takes place.
The second is the significant increase in economic activity for older women. This is likely to
continue given the changes to the SPA for women and the fact that women on the whole are
living longer with potentially fewer pension securities in the future. The purple line shows the
projection up to 2031.
Figure 7 - Economic Activity by Age and Sex Over Time (Males on left, females on right)
SSource: 1981, 1991, 2001 and 2011 Census.
Commuting
4.36
A commuting rate is the ratio of employed persons to employment in a given area. If an area
has a high commuting rate (i.e. a ratio of more than 1 employed person for every job) this
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means that the area is accommodating workers from the surrounding area. The converse if
true is the ratio is less than 1. If an area has a high and stable commuting rate (because it lies
adjacent to a large employment centre for example) then as the economy grows the area
will have to accommodate not only indigenous job growth but also the growing number of
commuters from the adjacent centre. This increases the level of housing growth needed to
accommodate a given level of indigenous job growth.
4.37
In 2011 there were 55,589 employed persons living in the District and 47,878 people working in
the District. This equates to a commuting ratio of 1.16 working persons per unit of employment.
Commuting is dictated by where people can and want to work and where they can and
want to live. Economic opportunity drives commuting destinations whereas quality of life
(good quality housing or environment/affordability etc) drives commuting origins.
Double jobbing
4.38
There are no official (i.e. ONS / DCLG) workforce statistics for double jobbing. The Annual
Population Survey provides such statistics for residents but not those who are actually
employed in the area. The East of England Forecasting Mode does however provide an
estimate of double jobbing amongst Thanets workforce. It concludes that around 1.2% of
workers have two jobs. The employment forecast will therefore be reduced to by that amount
to take account of this.
Jobs Growth
4.39
The NPPG (Ref ID: 2a-018-20140306) states that employment forecasts should be included in
an assessment of housing needs to define the quantum and location of new housing. Table 11
shows that employment growth forecasted by Experian (15.3%) (see Table 10) demonstrates a
need for around 716 dwellings per annum up to 2031. Given this, there is no evidence to
demonstrate that an uplift to demographic needs is required to accommodate economic
growth in Thanet District.
Table 11 - Annual Dwellings Needs for High and Low Growth Scenario
Annual Dwelling Needs 2011 to 2031
GVA Forecast
716
Source: Popgroup / GVA
Market Signals
4.40
The NPPF mandates the integration of different strategies and land uses including, requiring
planning authorities to ensure that their assessments of and strategies for housing,
employment and other uses are integrated and that they take full account of relevant market
and economic signals (paragraph 158).
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4.41
Housing Evidence
Paragraph 17, which sets out the Core Principles of the planning system states Plans should
take account of market signals, such as land prices and housing affordability, and set out a
clear strategy for allocating sufficient land which is suitable for development in their area,
taking account of the needs of the residential and business communities.
4.42
The NPPG provides further advice on what the NPPF means specifically by relevant market
and economic signals with regard to the housing market. The guidance (Ref 019-20140306)
explicitly sets out six market signals (although it is recognised that these are non-exhaustive):
4.43
land prices;
house prices;
rents;
affordability;
rate of development; and
overcrowding.
The NPPG also sets out broadly how these market signals should be interpreted:
The housing need number suggested by household projections (the starting point) should be
adjusted to reflect appropriate market signals, as well as other market indicators of the
balance between the demand for and supply of dwellings. Prices or rents rising faster than
the national/local average may well indicate particular market undersupply relative to
demand. (019-20140306)
Appropriate comparisons of indicators should be made. This includes comparison with longer
term trends (both in absolute levels and rates of change) in the: housing market area; similar
demographic and economic areas; and nationally. A worsening trend in any of these
indicators will require upward adjustment to planned housing numbers compared to ones
based solely on household projections. Volatility in some indicators requires care to be taken:
in these cases rolling average comparisons may be helpful to identify persistent changes and
trends. (020-20140306)
In areas where an upward adjustment is required, plan makers should set this adjustment at a
level that is reasonable. (020-20140306)
Prices
4.44
Median house prices in Thanet are 159,500 (2013 Q2), which is lower than the average of
172,050 for the HMA (Thanet, Canterbury, Dover, Shepway and Swale). As shown in Figure 8,
median house price in Thanet increased by 230% between 1996 and 2012, against an
increase of 219% in England, 225% in Kent and 222% in the HMA.
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Figure 8 - Mean House Prices Over Time Compared to the HMA, Region and England
Source: Live Table 581
Rents
4.45
Median rental prices in Thanet were 500 per calendar month in 2011 and had increased by
10% over the period to September 2015. This is lower than in Kent (12% increase), the South
East (14%) and but comparable to England (10%). This would not indicate a significant relative
pressure in the rental market.
Affordability
4.46
With median house prices 7.27 times median earnings in the District, housing is unaffordable to
the average household. Thanet is less affordable than Swale (6.58), Shepway (7.25), Dover
(6.25) and England as a whole (6.27) but more affordable than Canterbury (8.17). The
affordability ratio has also worsened in Thanet (112%) by a more significant degree than is
seen in the HMA (102%), Kent (98%) and England (90%). Thanet is therefore, unaffordable
relative to the surrounding area and is also becoming relatively less affordable.
Rates of development
4.47
Rates of development in relation to planned targets are set out in Figure 9. Whilst completions
in Thanet have been above planned targets, housing delivery since 2011 has fallen
significantly short of what is required. Taken as a whole, the Council has delivered around 20%
above its planned target, showing high demand for housing in the district.
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Figure 9 AMR Chart showing Net Housing Completions in Relation to Housing Target
Source: Annual Monitoring Report
Overcrowding
4.48
Occupancy ratings provide a measure of whether a household's accommodation is

overcrowded or under occupied. There are two measures of occupancy rating, one based
on the number of rooms in a household's accommodation, and one based on the number of
bedrooms. The ages of the household members and their relationships to each other are
used to derive the number of rooms/bedrooms they require, based on a standard formula.
The number of rooms/bedrooms required is subtracted from the number of rooms/bedrooms
in the household's accommodation to obtain the occupancy rating. An occupancy rating of 1 implies that a household has one fewer room/bedroom than required, whereas +1 implies
that they have one more room/bedroom than the standard requirement.
4.49
Figure 10 provides a comparison between the average number of bedrooms and average
number of people per household in Thanet, and comparator areas. There is significant
comparability across all areas in both variables, with the average number of bedrooms being
greater than the average household size. Thanet has the lowest number of bedrooms per
household (2.6), but this is only marginally lower than the level for the HMA (2.7), the South East
region (2.8) and England (2.7).
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Figure 10 - Average Household Size and Number of Bedrooms (2011)
Source: Census, 2011
4.50
Occupancy rating data based on the number of rooms and bedrooms is shown in Table 12,
alongside average household size and number of rooms and bedrooms.
To specifically
consider overcrowding, Figure 11 then demonstrates the occupancy rating (bedrooms) of -1

or less between 2001 and 2011.
This identifies where there are at least one too fewer
bedrooms than required for a household based on its size.
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Table 12 - Occupancy Ratings and Average Household Size (2011)

Occupancy
Occupancy
Average
Average
Average
rating
rating
household
number of
number of
(rooms) of -
(bedrooms)
size
rooms per
bedrooms
1 or less
of -1 or less
household
per
household
Households
Households
Persons per
Rooms per
Bedrooms
(%)
(%)
household
household
per
(No.)
(No.)
household
(No.)
England
8.7
4.6
2.4
5.4
2.7
South East
7.5
3.6
2.4
5.6
2.8
HMA
7.2
3.4
2.3
5.4
2.7
Thanet
8.1
3.6
2.2
5.2
2.6
Thanet
8.1
3.6
2.2
5.2
2.6
Canterbury
7.6
3.5
2.3
5.5
2.8
Dover
6.0
3.0
2.3
5.4
2.7
Shepway
8.0
3.4
2.2
5.4
2.7
Swale
6.1
3.3
2.4
5.5
2.8
HMA
Source: Census, 2011
Figure 11 - Occupancy Rating (bedrooms) of -1 or Less
Source: Census, 2001, 2011, 2016 SHMA
4.51
The occupancy rating for Thanet is approximately 8.1%, meaning that 8.1% of households in
the District are at least one room short and therefore considered to be overcrowded. Figure
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11 shows that this has increased significantly since 2001. Notwithstanding, it is important to
note that this figure does not make allowance for concealed households.
Houses in Multiple Occupation (HMO)
4.52
An HMO is a dwelling which has more than 3 unrelated people living in it. Data on dwellings,
household spaces and accommodation type from the 2011 Census indicates that 9% (5,890)
of Thanet households live in a flat/masionette/apartment which is part of a converted or
shared house (including bedsits). This is a significant increase from the 1% (361) of shared
dwellings that was observed in the 2001 Census.
4.53
This figure does not solely capture multiple household occupancy, but also includes flats that
may not be in multiple occupation. However, this is the only information available which gives
some indication of the total amount of HMO stock in the District.
4.54
The Councils HMO Register does not provide an accurate indication of the level of houses in
multiple occupation, as not all HMO properties are required to be licensed. A license must
only be obtained if the building has two or more households sharing basic amenities, is a
building or flat, or is converted with one or more non self-contained units, and fits the following
criteria:
Has a height of 3 or more storeys;
Has 5 or more people living there; and
Has occupants that make up more than one household (family unit).
Conclusions
4.55
The NPPG states that a worsening trend in any of these indicators will require upward
adjustment to planned housing numbers compared to ones based solely on household
projections. It is clear from the evidence set out in this re-calculation that the housing market
is experiencing a level of stress. This is apparent from levels of affordability. The presence of
overcrowding and its rate of increase in Thanet (with 8.1% of households having at least one
too few rooms) also demonstrate an element of housing demand.
4.56
In line with the provisions of the NPPG the evidence does warrant an increase in OAN based
purely on household projections. The 2016 SHMA advocates a return to levels of household for
younger age groups (25 to 34 year olds) observed in 2001, which in the SHMAs model takes
place over the period 2015 to 2025. Following 2025, the HRRs of this age group follow the trend
exhibited by the 2012 HP which shows a gradual decline in household formation. Whilst the
principle of returning HRRs to 2001 levels is a sound one, returning to the downward trend of
the 2012 HP is not an appropriate response. The 2008 HP trend, which has an upward
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trajectory from 2025 to 2031 is a more appropriate basis for projecting HRRs as it mirrors the
likely behaviour affected by a significant boost to housing supply. The adjustment made by
the 2016 SHMA to HRRs leads to an increase of 0.7% above the demographic base. If we
assume the 2008 HP trend following 2025 it results in an increase of 2.6%; increasing the midpoint demographic scenario from 784 dwellings per annum to 804 dwellings per annum.
4.57
The use of the economic scenario (716 dwellings per annum) decreases this by 11% and there
is therefore no justification for an increase in the demographic-led scenario to accommodate
employment growth. 5.
4.58
The key findings of this re-calculation of objectively assessed need, following the steps set out
in the NPPG, are as follows:
Assess
the
latest
household
projections.
The
latest
household
projections
and
demographic indicate a need for 749 dwellings per annum over the period 2011 to 2031.
Further analysis of household migration rates indicates that this should be increased to 784
dwellings per annum to take account of a full economic cycle and UPC.
Review employment forecasts and whether they could provide a justification for
increasing housing delivery. Growth in employment of around 15% has been forecast in
the district which can be delivered by projected demographic growth.
Assess housing market signals to understand if this could provide a justification for
increasing housing delivery. Housing market signals indicate affordability problems which
could justify an increase to objectively assessed needs in excess of household projections.
An increase in household formation in younger age groups results in an adjusted
demographic scenario of 804 dwellings per annum.
4.59
It is therefore concluded from this re-calculation that 804 dwellings per annum represents the
most robust OAN figure for Thanet, which equates to 16,080 homes over the period 2011-31.
4.60
This compares to 785 dwellings per annum/15,700 homes over the period 2011-31 identified in
the Councils 2016 SHMA (+2.4%).
Obviously house prices/affordability is as much as a factor of sub-regional / regional factors as it is about

specific supply in one area and therefore a wider significant boost in supply should take place to fully address
affordability.
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5.
Assessment of Land Supply
5.1
This section identifies Thanets land supply position based on review of the Strategic Housing
Land Availability Update 2013 (which is the current land supply assessment and informs the
Draft Thanet Local Plan (DTLP)), and the most recent Local Monitoring Report and Housing
Information Audit which set out Thanets current five year land supply.
5.2
Another key aspect of focus in relation to the Districts identified land supply in the DTLP
(based on the SHLAA 2013 Update) is the methodological compliance of the land supply
assessment and more importantly, how realistic it is for the identified sites to come forward in
their designated timeframe (particularly for sites at the strategic level). This considers the
strength of the evidence for sites coming forward and the robustness of the scoring criteria for
sites in accordance with the NPPG tests of suitability, availability and achievability. Overall, it
establishes an understanding of the appropriateness and deliverability of the assessed
potential land supply in the District and its ability to meet housing needs.
Assessed Potential
Thanet SHLAA 2013 Update Overview
5.3
The Thanet SHLAA Update was published in 2013 in order to review and update the findings of
the 2010 SHLAA in light of the NPPF and NPPG guidance, and to more robustly consider the
Districts potential housing land in the longer term to 2031 using a fully guidance compliant
methodology.
Methodology
5.4
The Thanet SHLAA 2013 Update adopts a base date of 31st March 2013 and draws on sites
with planning permission from the 2012 Housing Information Audit, so does not capture
planning permissions post 31st March 2012. The methodological approach involves the review
and re-assessment of all sites identified within the 2010 SHLAA as well as assessing new sites
that were not considered. High level sustainability screening is undertaken first to identify
those sites which should only sit within the reserve list (referred to only if there is insufficient
capacity), with screening criteria updated from the 2010 approach to achieve compliance
within the new guidance. This means that many sites not considered within the 2010 SHLAA
have been assessed in this update.
5.5
When considering the deliverability and developability of sites, methodological guidance was
taken from the Strategic Housing Land Availability Assessment Protocol for Kent & Medway. In
a guidance compliant approach. Sites were assessed in relation to their suitability, availability
and achievability and scored on these criteria from 1 to 4.
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5.6
5.7
5.8
Housing Evidence
For Suitability the scoring criteria was as follows:
4 = no material constraints/or impact mitigation required;
3 = constraints/impacts easily overcome/mitigated;
2 = overcoming constraints/impact mitigation more difficult to achieve; and
1 = constraints unlikely to be removed/impacts mitigated before 2031.
For Availability the scoring criteria was as follows:
4 = development commenced;
3 = no known constraints to availability;
2 = any constraints can be overcome within relevant timescale; and
1 = constraints cannot be overcome by 2031.
For Achievability consideration is made to the market, cost and delivery factors that affect
how achievable delivery of development on the site will be, with the scoring criteria as follows:
4 = The development is well in progress;
3 = Factors above are unlikely to impact availability;
2 = Factors above may cause a delay but site could be available by 2031; and
1 = no development seems achievable before 2031.
Key Findings & Critique

5.9
As shown in Table 13, the SHLAA Update identifies an overall potential supply that could
accommodate 20,456 dwellings to the end of the plan period (2031), and a further 1,813
dwellings post 2031. This is based on a range of sources which can be grouped into those sites
assessed from the SHLAA methodology, the forecast potential from windfall sites, and the
completed dwellings between April 2011 and March 2012.
This constitutes unconstrained
potential. Potential supply that could accommodate 4,542 dwellings is identified within the
first five years of the plan period (2011-16), considered deliverable, and the remainder of the
potential supply to 2031, 15,914 dwellings, considered developable (in line with NPPG
guidance).
5.10
As shown in Table 14, when compared with the notional requirement of 12,000 dwellings over
the plan period (as defined in the draft Thanet Local Plan, 2015), the identified potential
indicates the ability to deliver a surplus over each five year period (1,539 in 2011-16, 7,688 in
2016-21 and 262 in 2021-16) with the exception of 2026-31 (under-delivery of 1,043).
This
identifies overall over-delivery 10,259 dwellings over the plan period.
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Table 13 - SHLAA Table showing Potential Identified Capacity

Source of Housing
2011-16
2016-21
2021-26
2026-31
Post 2031
Potential
Grand
Total
Completed between
2011 and 2012 (study
320
320
base date)
Urban Capacity Audit
2006 Local Plan
allocations
Sites with planning
permission (residual)
Sites with planning
permission (new)
106
12
124
97
88
427
339
307
280
280
1,212
606
451
185
11
1,260
564
10
574
24
86
33
20
163
16
12
80
59
167
348
2,960
1,398
509
1,116
6,331
91
47
45
213
396
970
14
18
1,002
1,558
1,558
945
320
250
1,515
135
110
245
321
321
630
630
44
3,452
122
42
3,668
Council owned sites

with development
potential
Potential regeneration
sites
Landowner/developer
submissions (call 1)
Owner/developed
Owner/developer
Owner/developer
submissions
supplemental
Green Wedge (early
calls)
Green Wedge (2013
call)
Employment land
(from 2010 EL review)
Employment land
(from 2013 EL review)
Rural Area sites (all
calls)
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Small sites
Small windfall sites
200
200
240
240
Broad area windfall

contribution
680
680
680
Grand Total
4,542
10,688
3,269
1,957
Grand Total to 2031
4,542
10,688
3,269
1,957
2,040
1,813
22,269
20,456
Source: Thanet SHLAA 2013 Update (Potential Housing Capacity Summary Table)
Table 14 - SHLAA Table showing Indicative Trajectory compared with Notional Requirement (as
stated in 2015 draft Local Plan)
Grand
2011-16
2016-21
2021-26
2026-31
Post 2031
Potential capacity
4,542
10,688
3,269
1,957
1,8183
22,259
Notional requirement
3,000
3,000
3,000
3,000
n/a
12,000
+1,539
+7,688
+262
-1,043
Potential v.
requirement
Total
Source: Thanet SHLAA 2013 Update (Indicative Trajectory Table)
5.11
There are several points to consider in relation to this assertion of surplus identification of sites
compared to the notional requirement.
Firstly, the 12,000 figure adopted as the notional
housing requirement in this SHLAA Update is based on an indication within the Draft Thanet
Local Plan, which draws on the Economic and Demographic Forecasting 2013 updating the
East Kent SHMA figures. As already discussed in the earlier section, this figure is considered to
be an out-dated understatement of the Districts housing need, demonstrated by GVAs recalculation of objectively assessed need and the Councils 2016 SHMA.
5.12
Secondly, it is important to understand the proportion of windfalls that contribute to the

identified supply figure, as shown below in Table 15. For the first five year period (2011-16)
small windfall sites contribute 240 units to the identified potential capacity, which equates to
5.3% of the 4,542 units total capacity in that period. When considering the role of broad area
windfall contribution for supply from 6 years onwards, the contribution proportion increases to
6.4% from 2016-21, 20.8% from 2021-26 and 34.7% from 2026-31. Over the entire plan period
windfall contribution total capacity (from small sites and broad areas) equates to 11.2% of the
total potential capacity identified.
Assumes 88 per annum but deducting extant small site capacity to avoid duplication
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Table 15 - Table showing Windfall Contribution Capacity as Proportion of Total Potential

Capacity
2011-16
2016-21
2021-26
2026-31
Grand Total
Potential capacity
4,542
10,688
3,269
1,957
20,456
Small windfall sites
240
Broad area windfall

contribution
Windfall contribution
total capacity (%)
5.3%
240
680
680
680
2,040
6.4%
20.8%
34.7%
11.2%
Source: GVA adapted from Thanet SHLAA 2013 Update (Indicative Trajectory Table and Total
Completions and Component of Windfall Sites Not on Residential Gardens Table)
5.13
Whilst there has been historically significant levels of windfall contributions to total dwelling
delivery in Thanet, with small windfall sites delivering an average of 120 units per annum
between 2003/04 2007/08, this provides no guarantee that windfalls will continue to deliver
at the same level into the future. This uncertainty raises some question as to how realistic the
delivery of these forecast windfall units will be over the plan period, particularly in the second
half of the period from 2021 onwards. It is also relevant to note that the 2010 SHLAA identified
supply potential without the inclusion of windfall sites. This SHLAA Updates reliance on them
reduces the certainty of the potential of more than 2,000 units worth of capacity over the plan
period.
5.14
As outlined in the NPPG, a deliverable site in the context of housing policy is one that must be
able to be delivered in the first five years. Such sites could include those with development
plan housing allocations and planning permissions, unless there are identified constraints to
their five year delivery (NPPG ID 3-031-2014 03 06).
5.15
Based on this definition there is a total supply potential of 1,935 deliverable site units from 201116 evident in Table 13 (including completed sites, Urban Capacity Audit sites, 2006 Local Plan
Allocations sites and sites with planning permission), which equates to 42.6% of the total
potential of 4,542 units for this five year phase. This means that 58.4% of the total potential
(2,607 units) are not necessarily deliverable sites in housing policy terms.
5.16
It also suggests significant under-delivery when compared against the 2011-16 housing
provision target of 3,000 units in DTLP Policy SP11. Although the housing policy definition does
not automatically make sites any more or less deliverable, it does raise the question as to
whether some of this potential will realistically come forward in the first five years of the plan
period, such as potential from the Green Wedge 2013 Call (135 units), employment land from
the 2013 EL Review (630 units) and small windfall sites (240 units).
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Draft Thanet Local Plan Preferred Options Consultation (2015)

Housing Strategy
5.17
The DTLP puts in place draft policies to deliver a notional target of 12,000 new homes over the
plan period. This comprises the following:
Identified site allocations with capacity for 9,954 units, of which 4,150 units are within 4
strategic sites;
5.18
A windfall allowance of 2,480 units; and
(An allowance of 320 units for completions in 2011-12).
The Strategic Housing Allocations sub-section of the Housing Strategy section details the four
key strategic sites within DTLP Policy SP12 Strategic Housing Allocations, which are identified
to contribute approximately 35% of the total 12,000 housing provision figure aimed to be
achieved over the plan period. These four key strategic sites are Westwood, Birchington on
Sea, Westgate on Sea and Manston Green. Key details of the individual sites that make up
each strategic site are shown in Table 16.
Table 16 - Table showing Site Assessment Results for Key Strategic Sites Identified in Housing
Strategy
Strategic Site
Site
Site Source
2011-16
2016 31
Deliverability
potential
potential
Scores 7
(units)
units
Av
Identified Constraints
Ac
Potential
S511 Land
at
Court
Westwood
100
Nash
1,200
west of Red
House Farm
of site and potential

landscape impacts
Landowner/dev
S553 Land
contamination of part
eloper
Potential
submission tranche 1
S447 Red
House Farm
281
49
landscape
impacts
N/a
Possible
S515 Land
contamination,
0
at Gore End
Farm
Birchington
560
Landowner/dev
at
Street
submission tranche 1
and
potential
landscape
impacts
eloper
S498 Land
listed
buildings
N/a
0
456
100
700
Farm
S499 Land
at
S = Suitability
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Av = Availability
N/a
Ac = Achievability
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Mount
N/a
ST1 Land
south
of
Canterbury
Westgate on
Sea
Road
Landowner/dev
1,040
eloper
ST2 Land
south
of
submission
tranche 4
Linksfield
N/a
0
386
Road
Manston
SS33 Land
Green
at
Haine
Road
Manston
Green
Developments
Landowner/dev
eloper
submission
location
800
tranche 3
magnitude
and
may
be
affected by significant
archaeology
Source: Draft Thanet Local Plan Housing Strategy & SHLAA 2013 Update Appendix 2
5.19
The potential unit totals in this table are above the figures identified in Table 2 Total Housing
Provision of the DTLP which total 4,150 unit potential for the four strategic sites (Westwood:
1,450, Birchington: 1,000, Westgate-on-Sea: 1,000 and Manston Green: 700). This suggests that
the DTLP is not relying on the full unit potential identified in the SHLAA site assessment, possibly
due to full delivery being less realistic in light of the identified constraints, however this
approach is not clearly explained 8.
5.20
It is important to understand how realistic delivery of the 35% of total housing provision
contributed by these four strategic sites is, as full or partial non-delivery would pose a risk to
total housing provision.
5.21
Referring to the SHLAA, with the exception of the availability of the S511 Westwood site
(ranked 2) all sites receive a score of 3 for suitability, availability and achievability. This reveals
no obvious issues relating to availability and achievability, however in terms of suitability three
of the sites (S511, S499 and SS33) have identified constraints including landscape impact,
potential contamination, listed buildings and significant archaeology.
5.22
Whilst the SHLAA suitability score of 3 applies to sites where constraints/impacts are easily
overcome/mitigated, there is no clear justification that this is the case for these sites, so there
is perceived to be some risk of non-delivery of their total delivery quantum (1,000 deliverable
units from 2011-16 and 2,041developable units between 2016-31). This is a particular risk for the
development of the deliverable units within the first five year period from 2011-16 (100
potential units on S511, 100 potential units on S499 and 800 potential units on SS33).
It is stated in the Thanet SHLAA 2013 Update that the DTLP bases its potential supply on the SHLAA,
but determines the most appropriate sites of the SHLAA identified potential after making
considerations relating to competing uses, higher level policy, strategy and plan targets.
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5.23
Housing Evidence
The NPPG indicates that where there are identified constraints that impact on a sites
suitability, availability and achievability, there should be consideration of the action to remove
these constraints, how this could be achieved, and whether this will affect the likelihood of
delivery (NPPG ID 3-022-20140306). This information is not clear from the site assessments in the
SHLAA 2013 Update, despite the score of 3 for suitability, and without appropriate approaches
to overcoming these constraints there is some likelihood that delivery may not prove to be fully
achievable on these sites.
5.24
Within each of the DTLP Policies SP13 SP16 addressing Strategic Housing Sites at Manston
Green, Birchington, Westgate-on-Sea and Westwood, identification is made to the identified
constraints, however this is in the context of what should inform and be addressed in the
masterplanning process, suggesting that overcoming the constraints has not yet been given
detailed consideration.
For all four strategic sites the DTLP indicates that there is not a
completed masterplan or development/design brief nor have they been identified as sites
that benefit from existing planning consents. As such it is questionable whether they should be
included (in whole or in part) within the five year housing supply to 2016 (totalling 1,000 units in
the SHLAA Assessment). We note that since the preparation of the SHLAA, the planning
position of some of these sites (such as Manston Green) has moved forwards nonetheless
delivery constraints do still remain.
5.25
This brief review gives some initial consideration to achieving the housing delivery set out in
both the SHLAA 2013 Update and the DTLP. Whilst it does not look into how realistic the
housing delivery of other proposed allocation sites in the District is, this strategic site
consideration exemplifies the level of uncertainty associated with the sites delivering the
target number of units within the allotted five year phases. More detailed investigation into
the suitability of potential housing provision sites and their approach to overcoming constraint
would be required to formulate more concrete conclusions about delivery prospects.
5.26
In addition to the delivery risks associated with the allocated sites, we note that around 20% of
supply comprises windfall sites. We consider there to be a particular risk associated with the
dependence on this source of supply.
Thanet Local Plan Monitoring Report (2014) Overview
5.27
The Thanet Local Plan Monitoring Report (AMR) addresses local authority reporting
requirements dictated by the Localism Act and the Local Planning Regulations 2012. This
includes consideration of the level of achievement of Local Plan and Development Plan
Document policies, which is relevant here in relation to the monitoring of the achievement of
the Local Plan Housing policies, and particularly the provision of a five year supply of
deliverable land for housing.
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Five Year Housing Land Supply

5.28
Local authority identification of its 5 year supply of deliverable housing sites is a requirement of
the NPPF (as stated in paragraph 47), which should be benchmarked against housing
requirement;
..identify and update annually a supply of specific deliverable sites sufficient to provide five
years worth of housing against their housing requirements with an additional buffer of 5%
(moved forward from later in the plan period) to ensure choice and competition in the market
for land. Where there has been a record of persistent under delivery of housing, local planning
authorities should increase the buffer to 20% (moved forward from later in the plan period) to
provide a realistic prospect of achieving the planned supply and to ensure choice and
competition in the market for land (NPPF, paragraph 47).
5.29
The procedure for estimating the five year supply as part of the AMR involved three main
steps; listing all sites from the annual housing land study within the Housing Information Audit
(uncompleted sites with extant planning permission and sites allocated in the adopted local
plan), estimating deliverability of sites (within the period to March 2020) and the capacity of
deliverability, and scoring sites for suitability, availability and achievability (in line with the
requirement of the planning practice guidance (NPPG ID 3-018-20140306) from 14.
5.30
The AMR identifies the five year land supply for Thanet District from 1st April 2015 to 31st March
2020 to be 1,524 units on deliverable housing sites. This varies from the total five year sites
identified in the SHLAA 2013 Update (4,542 units) because the SHLAA does not remove from its
total those sites which are not considered deliverable in the context of housing policy. It also
differs from the calculated deliverable five year potential (1,935 units) because it is a
significantly more up to date assessment.
Conclusion
5.31
This section has considered Thanets land supply position based on review of the most recent
SHLAA (SHLAA Update 2013), the Draft Thanet Local Plan (DTLP) and the most recent Local
Monitoring Report (2013-14). The likelihood of delivery, particularly of the deliverable five
year housing phase, is a key focus. Attention is turned to the contribution of windfall sites to
identified housing potential and the methodology of the land supply assessment, specifically
the suitability, availability and achievability scoring criteria. The strategic sites identified in the
DTLP have also been considered to develop a basic understanding of how realistic delivery of
identified housing potential might be.
5.32
The Thanet SHLAA 2013 Update is the current NPPF and NPPG compliant assessment of
housing land supply potential for Thanet, which informs the housing supply aspect of the Draft
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Thanet Local Plan (DTLP). It identifies unconstrained supply for housing potential of 20,456 units
over the plan period (2011-31), with potential supply for 4,542 deliverable units from 2011-16
and 15,914 developable units from 2016-2031.
This assessed potential is benchmarked
against the 12,000 dwellings notional requirement over the plan period (based on the draft
Local Plan figure). This identifies total over-delivery potential of 10,259 dwellings over the plan
period; 1,539 from 2011-16 and 8,720 from 2016-31.
5.33
However, as already demonstrated through the re-calculation of objectively assessed need in

the previous section, the 12,000 dwelling requirement is out dated and does not represent the
true extent of need in the District, so constraining potential supply against this does not
constitute adequately addressing Thanets housing need.
5.34
In terms of the likelihood of delivery 11.2% (2,040 dwellings) of the potential 20,456 dwellings
over the plan period are windfall sites (small and broad area), carrying risk that despite historic
contributions this proportion is not delivered. This is a particular concern for the potential 5.2%
(240 dwellings) due to be delivered within the first five years of the plan period.
5.35
Based on the NPPG definition of delivery in the housing policy context 58.4% (2,607 dwellings)
of the total potential for 4,542 dwellings from 2011-16 are not necessarily deliverable sites
based on their sources, leaving the remaining potential figure of 1,935 units from deliverable
sites.
5.36
The Housing Strategy in the Draft Thanet Local Plan (DTLP) identifies four strategic sites which
support potential housing delivery of 4,150 units over the plan period, 35% of the total 12,000
requirement (Westwood, Birchington, Westgate-on-Sea and Manston Green). This 4,150 units
figure is a reviewed and reduced version of the total potential housing supply associated with
these sites in the SHLAA Update 2013 assessments, which suggests a likelihood of delivery
judgement may have already been made to reduce these figures.
5.37
However, even this reduced figure is not certain to be delivered. The SHLAA identifies that
three of the individual sites which make up the strategic sites have identified constraints
affecting their suitability for housing delivery (including possible contamination, potential
landscape impacts, listed buildings and significant archaeology). Whilst they are all scored as
having constraints/impacts are easily overcome/mitigated, there is no clear evidence to
justify the assessment.
5.38
Given that not all of these sites appear to benefit from an existing permission or even an
adopted or identifiable masterplan/development brief the ability of these sites to deliver
(particularly in the first five years) is questionable.
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5.39
Housing Evidence
The latest five year land supply for Thanet, identified in the Thanet Local Plan Monitoring
Report 2014, is for 1,524 dwellings (from 1st April 2015 31st March 2020). Although this does not
align with the 2011-16 or 2016-21 time periods, it can still be compared to the DTLP five year
delivery target of 3,000 units, to which it contributes just over 50%. This suggests that adequate
land supply potential is not being identified to address housing need identified within the DTLP.
This situation is exacerbated when the updated OANs for Thanet prepared by the Council
and GVA are taken into account, which suggest that the identified 5-year supply is capable
of meeting just 38% of need.
5.40
Having reviewed Thanets land supply position and undertaken initial consideration into the
adequacy of identified land supply potential, the next section takes this a step further by
understanding the specific alignment between housing need and identified housing land
supply, as well as understanding delivery potential when comparing previous delivery levels
with housing need figures.
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6.
Alignment Between Need and Supply
6.1
This section builds on the analysis from the previous sections to assess the most recent
assessments of housing need with the assessed potential land supply identified in the SHLAA
Update 2013 and the latest Monitoring Report (2014) five year housing land supply.
The
alignment between need iterations and recent housing delivery is also considered to add
depth to the understanding of how well Thanet has been addressing its housing need in
recent years.
Alignment of Need with Land Supply Potential

6.2
Table 17 brings together the figures identified throughout the previous stages of this document
to align the assessed housing need figures against the range of assessed housing land
potential. This comparison provides a rough indication of whether the SHLAA, AMR, and draft
Thanet Local Plan identify sites with sufficient capacity to address the Districts identified
housing need.
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Table 17 Annualised Table Showing How Delivery Levels Based on SHLAA Assessed Potential
Meeting Range of Housing Need Figures
SHLAA
2013
Update
Figures
Objective Assessed
Objective Assessed
Housing Need
Housing Need
(Thanet SHMA,2016)
(GVA, 2016)
785 dwellings per
804 dwellings per
annum
annum
15,700 dwellings in
16,080 dwellings in
period 2011-31
period 2011-31
20,456
+4,756
+4,376
1,524
-2,401
-2,496
2,366
-7,054
-7,282
12,718
-2,982
-3,362
Total Potential
Unconstrained Supply
(2011-2031)
5 Year Supply of
Deliverable Housing
Land (April 2015-
AMR
(2014)
March 2020)
Housing Trajectory
total planning
permissions and site
allocations for 12 year
period (2015-26)
Draft
Total Capacity to 2031
Thanet
(allocated sites,
Local
windfalls, and 2011-12
Plan
completions)
Source: Thanet SHLAA 2013 Update, Thanet Local Plan Monitoring Report 2012-13, East Kent SHMA 2009 &
Draft Thanet Local Plan Preferred Options Consultation 2015
6.3
This analysis shows that the deliverable 5-year and longer term developable supply of land
identified in the AMR and DTLP fall well short of up to date assessed needs (and this is in the
context of our aforementioned concerns over the genuine deliverability of some of this
supply). It is only the unconstrained supply identified in the SHLAA that is sufficient to meet
needs in full, which is clearly subject to deliverability constraints. This suggests that Thanet has
an insufficient supply of suitable deliverable housing land to meet assessed needs.
Alignment of Need with Recent Housing Delivery

6.4
Table 18 brings together housing delivery and need figures to consider whether recent housing
delivery in the District demonstrates capability to adequately meet housing need going
forwards.
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Table 18 - Table Showing Remaining Housing Need when Taking Account of Housing Delivery
at Three Key Levels
Objective Assessed
Objective Assessed Housing
Housing Need
Need
(Thanet SHMA,2016)
(GVA, 2016)
785 dwellings per

annum
2013/14 delivery
2006/7-2013/14 net
annual average delivery
804 dwellings per annum
321
-464
-483
528
-257
-271
Source: Thanet Local Plan Monitoring Report 2012-13, East Kent SHMA 2009 & Draft Thanet Local Plan
Preferred Options Consultation 2015
6.5
As is clear from the above table, historic delivery trends fall well short of identified need going
forwards.
6.6
This analysis reinforces the assertion that Thanet are not identifying clear ability to meet up to
date needs on the basis of recent delivery levels (on top of the concerns regarding land
supply previously discussed). The findings from this alignment analysis strengthen the case that
Thanet is not adequately identifying or making provision for its full, up to date, objectively
assessed housing need.
Conclusion
6.7
This section has considered the alignment of housing need and potential housing supply levels
identified for Thanet in previous sections to strengthen the case that Thanet is not adequately
identifying or clearly making provision for its full objectively assessed housing need.
The
additional alignment of housing need figures with recent delivery levels demonstrates that
even if the District were adequately identifying housing need, recent delivery levels challenge
the ability to achieve the level of housing delivery required to fully meet need.
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7.
Appropriateness of the Former Manston Airport Site
7.1
The previous sections confirm that there is a need to identify additional deliverable housing
land in Thanet.
7.2
This report forms part of a suite of documentation that is submitted in support of a planning
application for the redevelopment of the former Manston Airport site for mixed use
development, which includes 2,500 homes. The application documentation confirms that the
site is suitable for residential development, is available for development now, and has a robust
delivery strategy with completions commencing within 2 years. Moreover, the planning
application proposals represent a genuinely sustainable development proposition. As a
consequence the site should be treated as a deliverable housing site and therefore is
capable of forming part of the districts housing land supply.
7.3
It is our view that had the site been assessed as part of the 2013 SHLAA update, that it would
have scored highly and therefore should be treated as a preferable site when considered
alongside the total unconstrained supply identified in the SHLAA.
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8.
Conclusion
8.1
This document has reviewed Thanet District Councils key housing need and housing supply
evidence papers and the proposed housing policy within the Draft Thanet Local Plan, which
they inform. Furthermore, it presents our own objective assessment of housing need in the
district and considers the role that the former Manston Airport site could play in meeting that
need. We summarise the findings below:
1. Historic Housing Delivery Trends
There were 321 net housing completions in Thanet in 2013/14 (the most recent year
reported in the AMR).
Average net housing completions in the 5-year period 2009/10 to 2013/14 were 449
dwellings per annum (dpa). This is set against a benchmark target of 375 dpa (drawn from
the withdrawn South East Plan) which falls well short of the up to date OAN.
Delivery rates are projected to increase to 608 in 2014/15 (almost double the rate
achieved 2013/14), however no rationale is provided to justify this.
2. Housing Need Evidence
The most up to date objective assessment of housing need (OAN) produced by the
Council is the 2016 SHMA. This identifies a need of 785 dpa for the period 2011-31 (total of
15,700).
GVA considers the 2016 SHMA to have under-assumed likely employment growth and new
household formation rates and that therefore it slightly under-estimates likely need.
Accordingly, GVA has undertaken its own OAN which concludes that there is a need to
deliver 804 dpa (total of 16,080 in the period 2011-31).
Clearly, the above need figures are well in excess of the medium-term average historic
delivery trends referred to above (and more than double the average delivery rate for the
past 3-years).
3. Housing Land Supply
The housing policies set out in the adopted Thanet Local Plan are not based on an
NPPF/NPPG compliant objective assessment of housing need (they are based figures set
out in the now withdrawn South East Plan), and therefore the Council is not capable of
having a NPPF compliant demonstrable 5-year supply of deliverable housing land.
Notwithstanding this, the Councils 2014 AMR identifies a 5 year supply of deliverable
housing land with capacity to deliver 1,524 dwellings, and a total longer term housing
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trajectory (site allocations and commitments) of 2,366 dwellings for the 12-year period
2015-26.
The most relevant evidence base on land supply is the Thanet SHLAA Update (2013). This
identifies an unconstrained capacity for 20,456 dwellings for the period 2011-31. This
includes a windfall allowance of 2,280 units (11.1%). We note that many of the identified
sites are subject to deliverability constraints which is reflected in a genuinely deliverable
unconstrained supply of just 1,936 dwellings for the first 5-years (2011-16) if the NPPG
definition is followed. The former Manston Airport site was not considered as part of the
SHLAA.
The draft Thanet Local Plan (Preferred Option, 2015) sets out policies to deliver around
12,000 homes. Specific sites are identified to accommodate 9,954 units, of which 4,150
units (42%) are within 4 strategic sites. We consider there to be development constraints
associated with the strategic sites which pose a risk to delivery, particularly in the short
term. Furthermore, the draft Local Plan is dependent on an unidentified windfall allowance
of 2,480 dwellings (approx. 20% of planned for supply), which introduces significant
uncertainty in terms of the deliverability of necessary supply that the draft policy is
dependent on.
4. Relationship of Need to Supply
A step-change in housing delivery rates is needed in the district in order to meet

objectively assessed needs (the completion rate achieved in 2013/14 must more than
double).
The Council is unable to demonstrate an NPPF compliant 5-year supply of deliverable

housing land supply, therefore in national policy terms there is an-principle need to identify
additional deliverable housing land in the district now.
The policies set out in the draft Local Plan (Preferred Options, 2015) fall well short of
meeting OAN in full (approx. 4,000 dwelling shortfall), of which the achievability of some of
the identified supply is uncertain particularly in the short term (due to the reliance on
windfalls and sites with deliverability constraints). Accordingly, there is a need to identify an
additional supply of deliverable and developable land over and above that identified in
the draft Local Plan (with capacity of around 4,000 units as a minimum).
The SHLAA identifies an unconstrained land supply sufficient to meet OAN in full, in theory.
However, the identified supply of genuinely deliverable sites falls well short of OAN.
Accordingly, there is a clear misalignment between assessed levels of housing need and
identified land supply in the district, with a clear need to identify an additional supply of
land over and above that identified in the SHLAA in order to meet OAN in full.
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5. The Appropriateness of the Former Manston Airport Site for Housing
The site was not assessed in the SHLAA and therefore comprises an additional source of
potential supply over and above that identified in the SHLAA.
Had it been assessed in the SHLAA it is our view that it would have scored highly, as justified
by the suite of assessment work and supporting material submitted with the planning
application. This confirms that the site is suitable for housing development and is available
now with a willing developer in place (completions anticipated to commence within 2
years, underpinned by a robust business plan). In other words, it is a deliverable site.
Accordingly, it is our view that the former Manston Airport site should be treated as a
preferable site for housing development in principle.
8.2
The outcome of the above is a well evidenced case for the appropriateness of residential
development on the former Manston Airport site, as part of wider mixed use development.
The housing case contributes to a total place approach to future development and the
clear inter-dependency between the employment, housing, community, cultural, and
sport/recreation uses in achieving a truly rounded sustainable development proposition.
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Appendix I
Housing
Evidence
Surrounding
Districts
(March 2015)
gva.co.uk
Former Manston Airport Site
Housing Evidence
Canterbury Housing Need Evidence

The key documents that contribute to the evidence base for housing need in Canterbury are the East
Kent SHMA (2009), Canterbury Housing Strategy 2012-16 &, Canterbury District Local Plan Review
Public Examination - Topic Paper 2: Housing November 2014, and the Canterbury Development
Requirements Study (2012).
This sub-section provides a very brief overview of housing need evidenced for Canterbury within these
key documents. This contributes to gaining a wider understanding of the levels of housing need within
the East Kent HMA, which includes Canterbury, which is important considering the inter-relationships of
housing need and demand between districts within a defined HMA.
East Kent SHMA (2009)

As already discussed in relation to the East Kent SHMA, its publication came prior to the publication of
the NPPF and subsequent NPPG, with it being produced in line with the CLG (2007) Strategic Housing
Market Assessments Practice Guidance and Planning Policy Statement 3 (PPS3).
Table 19 shows the key housing need for figures identified in the SHMA for Canterbury, based on the
period from 2006-10, addressing backlog over a 5 and 10 year period. This determines Canterburys
gross backlog need of 3,248 dwellings and annual newly arising need over the 5 year period of 1,276
dwellings.
Incorporating 5 year backlog reduction Canterburys net annual housing need is
calculated at 1,473 dwellings.
Incorporating 10 year backlog reduction Canterburys net annual
housing need is calculated at 1,104 dwellings.

The forward projections from these 2006-10 based need figures to cover the period from 2011 to 2026
is split into three phases; 2011-15, 2016-20 and 2021-26, however this is only focussed at the wider East
Kent sub-region level, so does not provide local authority specific need figures to 2026.
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Housing Evidence
Table 19 - Canterbury Housing Need (including 5 and 10 year backlog reduction)
Backlog need
Annual quota of backlog
reduction over 5 or 10 years
Total newly arising housing need
Annual supply of social sector
re-lets
Net annual housing need
Canterbury (5 year backlog
Canterbury (10 year backlog
reduction)
reduction)
3,248
3,248
650
325
1,276
1,276
452
497
1,473
1,104
The South East Plan (proposed changes) target figure identified for Canterbury, is 10,200 units from
2006-26, which equates to 23% of the South East Plan total figure (44,400 units). Although a new SHMA
has not been undertaken by the Council, the Draft Local Plan Publication consulted on over June
July 2014 (which has now been submitted to the Secretary of State for examination) identifies a
housing land requirement of 15,600 units from 2011-31 (3,000 from 2011-16 and 4,200 for each of the
following five year periods to 2031). This is supported by the objectively assessed need adopted from
the Canterbury Development Requirements Study (2012), as discussed below.
Canterbury District Housing Strategy 2012-16

The Canterbury District Housing Strategy documents 5 year forward looking ambitions for the District,
but doesnt address the scale and location of demand for new homes, which it indicates will be
addressed in the Local Plan.
The Strategy refers to the outdated 10,200 housing need figure identified in the South East Plan, but
confirms that its abolition means that the council must decide how many new homes to plan for
(page 19). It provides detail on the need for affordable housing in the District, referenced from the
SHMA, but does not provide any update on overall need.
Canterbury Development Requirements Study (2012)

The Canterbury Development Requirements Study (2012) was undertaken by NLP, providing a more
up to date identification of the development requirements to 2026 and 2031, including the Districts
housing need. This used updated population and household data from the East Kent SHMA, although
this is no longer the latest available data, particularly in relation to aspects such as travel to work
data.
The Study involved the testing of a number of population, housing and economic growth scenarios,
which resulted in a range of outputs, with 10 specific scenarios (A J). The housing need outputs
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Housing Evidence
range from a low of 80-150 dwellings per annum to a high of 1,100-1,200 dwellings per annum, which
over the period from 2011-2031 equates to a range from 1,600-3,000 dwellings to 22,000-24,000
dwellings.
Some direction towards the most appropriate level of need is provided, with the suggestion of a
requirement of 600-700 dwellings per annum, however it is emphasised that the Council will need to
consider the most appropriate level of housing need over the period for the new Local Plan.
District Local Plan Review Public Examination - Topic Paper 2: Housing November
2014
This Examination Topic Paper refers to the East Kent SHMA (2009) and the updated Canterbury
Development Requirements Study (2012) sets the Districts housing land approach to support the Draft
Local Plan Publication Draft 2014.
The paper details the steps taken by the Council following the publication of the Development
Requirements Study, which were to undertake a Sustainability Appraisal of Development
Requirements (2012) study (carried out by AMEC) to review the scenarios calculated in the
Development Requirements Study. The outcome of this Study was the recommendation of Scenario
E, 780 dwellings per annum, which offered the greatest potential to achieve the appropriate
balance (to optimise growth and minimise detrimental environmental effects) (page 9).
This 780 dwellings per annum figure was adopted as the objectively assessed need for the Council
and taken forward into the Draft Local Plan, updating the figure within the East Kent SHMA (2009).
Dover Housing Need Evidence

The existing East Kent SHMA (2009) is the key document contributing to Dovers housing need
evidence base, which supports the adopted Core Strategy (adopted in February 2010). This subsection provides a very brief review of the housing need identified for Dover within the East Kent
SHMA, which contributes to gaining a wider understanding of the levels of housing need within the
East Kent HMA, which includes Dover. This is important considering the inter-relationship of housing
need and demand between districts within a defined HMA.
Table 20 shows the key housing need for figures identified in the SHMA for Dover, based on the period
from 2006-10, addressing backlog over a 5 and 10 year period. This determines Dovers gross backlog
need of 5,968 dwellings and annual newly arising need over the 5 year period of 578 dwellings.
Incorporating 5 year backlog reduction Dovers net annual housing need is calculated at 1,489
dwellings. Incorporating 10 year backlog reduction Dovers net annual housing need is calculated at
781 dwellings.
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Housing Evidence
Table 20 - Dover Housing Need (including 5 and 10 year backlog reduction)
Backlog need
re-lets
Dover (5 year backlog
Dover (10 year backlog
reduction)
reduction)
5,968
5,968
1,194
597
578
578
283
394
1,489
781
The South East Plan target figure (proposed changes) identified for Dover is 10,100 units from 2006-26,
which equates to 23% of the South East Plan total figure (44,000 units).
The Adopted Core Strategy 2010 identifies four housing growth options; low growth (6,100 units based
on original RSS level), medium low growth (8,100 units), medium high growth (10,000 units based on
proposed changes to RSS level), and high growth (14,000 units based on Dover Regeneration Strategy
level). Following option testing in the Preferred Options Local Plan version and Sustainability Appraisal,
the increased target of 14,000 new dwellings is adopted as the Districts housing need figure over the
plan period to 2026, which equates to 875 new dwellings per annum.
Shepway Housing Need Evidence

The existing East Kent SHMA (2009) and the Shepway LDF Core Strategy: Strategic Requirement Report
(April 2011) are the key documents contributing to Shepways housing need evidence base, which
support the adopted Core Strategy (adopted in September 2013). This sub-section provides a very
brief review of the housing need identified for Shepway within these key documents, contributing to
gaining a wider understanding of the levels of housing need within the East Kent HMA, which includes
Shepway. This is important considering the inter-relationship of housing need and demand between
districts within a defined HMA.

Table 21 shows the key housing need figures identified in the East Kent SHMA for Shepway, based on
the period from 2006-10, addressing backlog need over a 5 and 10 year period. This determines
Shepways gross backlog need of 5,671 dwellings and annual newly arising need over the 5 year
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Housing Evidence
period of 1,318 dwellings. Incorporating 10 year backlog reduction Shepways net annual housing
need is calculated at 671 dwellings.
Table 21 - Shepway Housing Need (including 5 and 10 year backlog reduction)
Shepway (5 year backlog
Shepway (10 year backlog
reduction)
reduction)
5,671
5,671
1,134
567
585
585
402
481
1,318
671
Backlog need
re-lets
The South East Plan target figure (proposed changes) identified for Shepway is 5,800 units from 200626, which equates to 13% of the South East Plan total figure (44,400 units).
Shepway LDF Core Strategy: Strategic Requirement Report (April 2011)

This report provides justification for the strategic requirements identified within the Core Strategy,
including support for the identified housing need figures. Considering the demographic and socioeconomic analysis undertaken in the report, it identifies a figure of 400 dwellings per annum as the
Core Recommendation for the Core Strategys housing target.
This 400 dwellings per annum figure was adopted within the Core Strategy as the upper (preferred)
target for housing delivery over the period from 2006 2026, equating to an overall target of 8,000 new
dwellings. 350 dwellings per annum is identified in the Core Strategy as the minimum new housing
delivery target to be achieved, which would equate to an overall target of 7,000 new dwellings.
This 350-400 dwellings per annum set in the Core Strategy falls significantly below the net annual
housing need figure identified in the East Kent SHMA for Shepway, which ranges from 671 to 1,318
dwellings.
Swale Housing Need Evidence

The existing East Kent SHMA (2009) and the Strategic Housing Market Update and Development
Needs Study (2013) are the key documents contributing to Swales housing need evidence base,
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Housing Evidence
which support the Swale Borough Local Plan Part 1 Publication Version, the preferred options Local
Plan which is currently under consultation prior to its submission for examination in Spring 2015. This
sub-section provides a very brief review of the housing need identified for Swale within these key
documents, contributing to gaining a wider understanding of the levels of housing need within the
East Kent HMA, which includes Swale. This is important considering the inter-relationship of housing
need and demand between districts/boroughs within a defined HMA.

Table 22 shows the key housing need figures identified in the East Kent SHMA for Swale, based on the
period from 2006-10, addressing backlog need over a 5 and 10 year period. This determines Swales
gross backlog need of 5,739 dwellings and annual newly arising need over the 5 year period of 884
dwellings. Incorporating 10 year backlog reduction Shepways net annual housing need is calculated
at 857 dwellings.
Table 22 - Swale Housing Need (including 5 and 10 year backlog reduction)
Backlog need
6nnual supply of social sector relets
Swale (5 year backlog
Swale (10 year backlog
reduction)
reduction)
5,739
5,739
1,148
574
884
884
315
601
1,717
857
Strategic Housing Market Assessment Update and Development Needs

This SHMA Update and Development Needs Study was undertaken by NLP in 2013, updating the
housing evidence from the East Kent SHMA (2009) to provide supporting evidence for the objectively
assessed housing and economic needs identified in Swales emerging Local Plan. This adopted a
NPPF and NPPG compliant methodology, using significantly more up to date data than was used in
the existing SHMA.
In terms of housing need, this review tested 9 different future growth scenarios (five demographic
drive, three economic driven and one policy/supply driven) to obtain a range of housing need
May 2016 gva.co.uk
Housing Evidence
outputs over the period from 2011-31. The objectively assessed need outputs from these scenarios
ranged from as low as 329 dwellings per annum (zero net migration scenario) to 887 dwellings per
annum (2011 interim SNPP). This equates to a range of 13,400 to 17,700 new additional dwellings over
the period from 2011-31.
The Study concludes with the recommendation that Swales objectively assessed need falls within the
range of 60 900 dwellings per annum, which equates to 12,000 18,000 new dwellings over the 201131 plan period. It is advised that this range receives further consideration in relation to key constraint
issues, however it is suggested that a mid-point figure of approximately 750 new dwellings per annum
could represent the most appropriate objectively assessed need figure.
The range for the objectively assessed need figure from the 2013 Study was updated, using the 2012
based SNPP, in October 2014. This resulted in a figure range of 612 828 dwellings per annum,
reducing the SHMA recommendation to 734 dwellings per annum, equating to an overall plan period
target of 14,680 new dwellings. However, when considering the deliverability of housing development
over the plan period, whilst also considering the findings of the 2014 Sustainability Appraisal, the
emerging Local Plan adopts a housing target of 540 dwellings per annum, which equates to 10,800
new dwellings over the 2011-31 plan period (significantly below the objectively assessed requirements
figure).
May 2016 gva.co.uk

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STONE HILL

LIVE WORK PLAY

A brighter future for

Stone Hill Park

Assessment of Housing Delivery ................................................................................................................ 4

Published Housing Need Evidence .......................................................................................................... 6

GVA Calculation of Objectively Assessed Housing Need ................................................................. 23

Assessment of Land Supply ...................................................................................................................... 44

Alignment Between Need and Supply.................................................................................................. 55

Appropriateness of the Former Manston Airport Site.......................................................................... 58

Housing Evidence Surrounding Districts (March 2015)

For and on behalf of GVA Grimley Limited

May 2016 gva.co.uk

Stone Hill Park

Housing Evidence Base Context

Thanet Local Plan Monitoring Report (2014).

Thanet Strategic Housing Market Assessment (SHMA) 2016;

Kent County Council Economic and Demographic Forecasts (2013);

Thanet District Council Housing Topic Paper (2013);

Thanets New Local Plan Options Consultation (2014);

Draft Thanet Local Plan: Preferred Options (2015); and

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Stone Hill Park

Strategic Housing Land Availability Assessment 2013 Update; and

Thanet Local Plan Monitoring Report (2014).

The report is structured as follows:

Section 4: GVA Objective Assessment of Housing Need provides a re-calculated

Of key importance here is establishing an

understanding of the likelihood of identified potential sites coming forward, particularly in

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Stone Hill Park

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Stone Hill Park

Assessment of Housing Delivery

This section reviews the latest Thanet Local Plan

Monitoring Report (2014) in order to

Source: Thanet Local Plan Monitoring Report 2013

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Stone Hill Park

Previously Developed Land Targets

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Stone Hill Park

Published Housing Need Evidence

KCC (Thanet) Economic and Demographic Forecasts (2013);

Thanet District Council Housing Topic Paper (2013);

Thanet Local Plan Options Consultation (2014);

Thanet Local Plan Preferred Options Consultation (2015); and

Thanet Strategic Housing Market Assessment (SHMA) (2016).

(i) East Kent SHMA, 2009

This was prepared by

Findings & Recommendations

Incorporating the 5 year

Stone Hill Park

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Stone Hill Park

Assuming no growth in affordable supply

High price scenario

Mid price scenario

Low price scenario

Assuming high growth in affordable supply

High price scenario

Mid price scenario

Low price scenario

May 2016 gva.co.uk