Homes methodology held to carry limited weight

Durham Council's argument that it can show a five-year housing land supply under the government's proposed housing need methodology has been given little weight by an inspector allowing plans for up to 75 homes.

The council had accepted at the inquiry that it could not demonstrate a five-year supply of housing land. Following closure of the inquiry, however, it cited the consultation document’s indicative housing need figure of 1,368 dwellings per annum, which fell below all estimates used in previous studies. As a consequence, it argued that it could demonstrate more than 5.7 years' supply and this was a material consideration that superseded the previous land supply position.

The inspector agreed that the consultation was a material consideration but found that, as it was ongoing, it could carry little weight. There was no certainty that the standard methodology suggested in the document would be formally adopted without amendment and the indicative figures had not been tested in any meaningful way, he remarked.

In that light, he relied on the position originally agreed between the appellant and the council, which confirmed that there was no five-year supply. Even on the council’s own figures, he noted, the shortfall was between 1,000 and 2,000 dwellings. Neither was he persuaded to afford weight to the council’s claim that it could show an adequate supply against a five per cent buffer for previous underdelivery, since a 20 per cent buffer had already been accepted as appropriate.

The case also explored whether the landscape around the site was valued in the context of paragraph 109 of the NPPF. Various court judgments had confirmed that such landscapes have to be more than just popular, the inspector observed. He found that the site did not lie within any nationally or locally designated landscape and, while lying within a broad landscape type comprising a coastal landscape plateau, contained no significant valued attributes. Neither would the scheme unacceptably reduce the physical separation of two settlements, he ruled.

He concluded that the tilted balance in paragraph 14 of the NPPF applied, particularly since footnote 9 was not engaged. He agreed that the appeal proposal would lead to some environmental harm, including loss of high-quality agricultural land, but gave significant weight to the need to boost the supply of open market and affordable dwellings.

Inspector: David Wildsmith; Inquiry

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