West Berks Caught in the #NPPF Transition Period

What happens when a plan incloudes housing provision in ‘general conformity’ with an RSS but subsequent household projections etc. indicate that figure is too low?

This was the position facing the inspector into the West Berks Inspector this week.

The lack of justification for housing provision which complies fully with the requirements of the NPPF is a significant shortcoming and there is no specific main modification which I could make now to overcome this problem. What is required is a new SHMA which complies with NPPF paragraph 159, the apportionment of identified needs and demands between local authorities within the HMA, coupled with an explicit balancing of meeting those needs against environmental impacts. …

In my view, this Plan must be regarded as being unfortunately caught in the transitional period between the long contemplated demise of Regional Strategies which has still not concluded and the emergence of the NPPF as the sole higher tier guidance for the preparation of Local Plans. There is some force in the criticism that the Council could and should have responded more constructively to the changing planning context following publication of the draft NPPF last summer and my earlier preliminary conclusion about evidence of greater demand for housing….

I have considered what process would best achieve the aims of the NPPF, notwithstanding the identified shortcoming in relation to a fully compliant assessment of housing needs and demands. Paragraph 17 of the NPPF sets out 12 core planning principles, which include that planning should be genuinely plan-led, a positive process to support sustainable economic development.

In my view, there are exceptional circumstances relating to this Plan, in the context of this protracted Examination, which should be taken into account in deciding the appropriate way forward….

On balance, I consider that the Government’s planning aims, as set out in the NPPF, are best achieved in the short term in West Berkshire by the adoption of this Core Strategy (subject to the main modifications necessary for soundness), but amended to make clear that the 10,500 housing figure is a minimum and not a ceiling and requiring a review of housing provision. This review would be in 2 stages. Firstly, a review of needs and demands for housing to inform the appropriate scale of housing to be met in the District. This would be done through an update of the SHMA which complies with NPPF. This review is a stand-alone piece of work and a pre-requisite of any review of the Core Strategy itself. This SHMA should be completed within 3 years. Secondly, if the updated SHMA indicates that housing provision within the District needs to be greater than currently planned, a review of the scale of housing provision in the Core Strategy will be undertaken. It is not possible at present to set a realistic timetable for that to be completed.

The key factor here was the lack of an up to date objective assessment of need.  If this was in place then if the council had ignored it then it would have been unsound unless the inspector was capable of adding sites that had been consulted on and SEAd.  Because the council had only SEAd up to the point of sites meeting the South East Plan Target this was not possible.  This circumstance is only likley to exist in the South East, South West and East of England as other areas indicate a lessening of household formation levels since RSS was agreed.

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