Individual borough housing needs calculation favoured over joint approach

A scheme for 180 dwellings including 30 per cent affordable has been approved on safeguarded land adjoining a Lancashire settlement, with the social and economic benefits of the housing in an area of shortfall outweighing the adverse impacts of conflict with the safeguarding policy and other impacts on landscape, visual amenity and heritage assets.

A determining issue in the appeal was the calculation of the local housing need for the area and here the council argued a recently produced joint strategic need study, based on redistributing aggregated standard method based needs, highlighted a housing need of 278 dwellings per annum. The appellants argued that this was too low and when applying the standard method for the indivdual borough, which could be considered as a separate housing market, a much higher 569 dpa figure resulted.

The inspector considered both arguments but ultimately favoured the use of the individual borough standard method in this case because he felt the joint strategy document, although an agreed position by the councils involved, was only a consultation document and had not been subject to examination as part of the emerging plan process. Although he acknowledged that the document was a material consideration following the judgements in St Modwen v SSCLG and East Riding, 2016, he could only afford it limited weight in his decision. In addition, the inspector felt the council’s argument that paragraph 2a-013 of the PPG applied regarding the re-distribution of housing needs across a joint area for strategic policy-making purposes was flawed as he held that that particular reference in the PPG applied to plan-making rather than decision-making. The inspector concluded the council could only show a 2.7-year supply of housing land. 

The inspector’s conclusions on the five-year housing land supply indicated to him that the restriction on the development of safeguarded land in the local plan policy was preventing the council from being able to provide an adequate housing land supply, against its standard method need within the current plan period to 2026. This view was further supported by the fact that the emerging plan identified all but one of the areas of safeguarded land in the original plan policy, including the appeal site, as site proposals to meet the borough’s housing needs for the period 2021-2036. On this basis, the inspector also concluded the policies establishing the amount of housing needed in the borough and designating the appeal site as safeguarded land, so preventing it from contributing to those needs, were out of date.

In the planning balance, the inspector opined the tilted balance was engaged and concluded that the adverse impacts of granting planning permission would not significantly and demonstrably outweigh the benefits of the proposed housing in an area of need when assessed against the policies in the Framework taken as a whole. He also opined that even were the tilted balance not engaged he would have come to the same conclusion.

Inspector: Mike Hayden; Inquiry

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