We finally have the much anticipated Inspectors report for Dacorum – I have blogged about this plan herem where I questioned whether an inspector had the power to make a plan with a significant housing shortfall ‘temporarily’ sound pending an early review. At least two counsels opinions submitted by objectors supported my view.
In order that the concerns [over housing shortfall] will be fully addressed it is recommended that a section be included in the CS entitled ‘Future Partial Review’ [MM28]. This confirms that the Council is committed to a partial review of the CS, to be adopted by 2017/18. This will identify the full objectively assessed needs for market and affordable housing, assess whether or not those needs can be met (including in neighbouring local planning authority areas) and if not draw robust conclusions as to where the balance between meeting full needs and the other NPPF sustainability considerations should lie. As part of this work it is agreed by the Council that a review of the green belt should be undertaken, including the potential for the identification of safeguarded land and I am told that this work has already commenced.
I have attached great weight to the guidance on soundness in the NPPF but paragraph 13 confirms that it is guidance and not statute. I have also balanced the advice that decisions need to take local circumstances into account (paragraph 10) and that it is highly desirable that local planning authorities have an up-to-date plan in place (paragraph 12). Weighing all these elements in the balance I am satisfied that the shortcomings in the submitted document are not of such significance to justify finding the document as a whole not sound. The issues can best be addressed through the preparation of an early review because in the short to medium term the Core Strategy will provide a sound basis on which planning decisions can be taken.
A number of respondents to the MM consultation raised concerns regarding the appropriateness of relying on an early review of the CS as a means of securing a sound document. In other circumstances I may well have attached more weight to these concerns but at Dacorum there are two important factors. First the housing shortfall is about 15% and, more importantly, there would be a general over-supply of housing in the short to medium term, especially over the next three years (as identified in the up-dated Trajectory). This oversupply would broadly be the equivalent to meeting the annualised CLG projection figure of 538 dwellings. The Review of the CS would therefore deal primarily with the likely shortfall towards the end of the plan period and as such the current CS housing target would be interim in nature. In order tofurther encourage housing delivery the overall total currently being proposed by the Council should be seen as a minimum provision, pending the outcome of the review, although this should not be interpreted as a justification for speculative proposals in the green belt prior to the conclusion of the current partial review of the CS.
So Dacorum would not have a shortfall in the period whereby housing proposals for the full plan period were being set.
So Dacorum does not set a precedent for other authorities to generally undershoot housing needs and punt the issue back till after the next gneral election.