Housing supply policies not out of date even though based on old requirements

A proposal for 51 new homes at a former sand quarry at the edge of a village in Bedfordshire was refused for significant harm to the landscape character of the site and appearance of the area generally, and regardless of the housing land supply position.

200-007-042 (Image Credit: PHD Chartered Town Planners)
200-007-042 (Image Credit: PHD Chartered Town Planners)

One of the main issues in the case was whether a five year supply of housing land could be shown. In assessing housing need carefully in the absence of an up to date housing requirement in an adopted local plan, the inspector found that the council’s 2017 strategic housing market assessment was thorough and robust and he accepted a lower baseline household projection than the DCLG 2014 figures and the market signals uplift figure. He attached little weight to the DCLG standard methodology which would have required a much higher requirement as it was still a consultation document. In terms of housing supply, the inspector accepted the council’s evidence with respect to disputed sites and ultimately found a five year supply of housing land could comfortably be demonstrated.

The inspector also disagreed with the appellant and held that local plan was not out of date because its housing supply policies were based on a housing requirement based on a revoked regional strategy, as a five year supply of housing land was being delivered. To say otherwise, he opined, would be inconsistent with the thrust of the Supreme Court judgement in Suffolk Coastal DC v Hopkins Homes Ltd, etc ([2017]. Equally he found that the settlement boundary policies were still applicable despite being drawn up in the context of an out of date housing requirement.  He felt the principle of settlement boundaries was not inconsistent with the NPPF, which expects planning to take account of the character of different areas recognising the intrinsic character and beauty of the countryside, provided those settlement boundaries were not preventing the delivery of a supply of housing ?

Overall, he concluded that the benefits of the proposed development would be outweighed by the significant environmental harm it would cause to the character and appearance of the local landscape character area. Although the ‘tilted balance’ did not apply in this case, even if it were to be triggered, he concluded that the adverse impacts identified would still significantly and demonstrably outweigh the benefits of the proposed development.

Inspector: Mike Hayden; Inquiry

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