The battles over that most notorious hole in the NPPF – the Liverpool or Sedgefield is getting ever more nasty.
No-one has any doubt that where possible and realistic any backlog of need should be cleared as early as possible. But in large growth areas with many big sites inevitably any trajectory will be endloaded, even if that trajectory in its early years easily meets household growth plus a boost.
The problem if you take Liverpool too literally is the tail wags the dog – you reject a perfectly sensible sustainable strategy capable of delivering housing numbers at scale over the long run in favour of a short term binge festival on scattered sites around villages that could only last a few years at most before the infrastructure of those villages was maxxed out. Sewerage authorities have never planned for large scale growth around such villages and the capacity of sewage work s will soon be exceeded.
Quite the most extreme example of Sedgefield fundamentalism was the recent exchange at the Greater Nottingham EIP where the HBF has challenged the growth strategy and even threatened JR. So far at ALL of the four local plan EIPs where LPAs have proposed growth strategies with large strategic sites and consequently endloaded the inspectors have backed them. Hence the HBF tactics.
At appeals though things continue to be made up as they go along with the SoS reliant on adhoc Liverpool or Segdefield judgments – for example at Bicester where the startegy is based on a large extension (0ne of the four remaining ecotowns) as ‘All eggs in one basket’ – errr where is that a criteria in the NPPF?
The worst injustices though have been suffered by South Northants, one of the three West Northants joint plan authorities – and the second largest growth area in England. The Inspectors have backed a growth oriented strategy with some endloading based on huge urban extensions. Yet at several S78 appeals inspectors have simply ignored the plan findings of their fellow inspectors, ignoring the prematurity and ‘degree of conformity tests’ and even the trajectory approach – all of which are embedded in the NPPF.
“this would become a self-fulfilling prophecy which would drive the supply of housing land even lower. The council’s preferred trajectory is manifestly inconsistent with the requirement to ensure a five year housing supply.”
Is patently absurd when the joint plan is about to release the largest tranche of new land in any development plan in England for over two decades. Cheer on South Northants.
Part of the confusion here is there is two issues. One is confusing the level of need with how quickly that need should be met. If the reason for endloading is practical then I for one have no objection. The problem is if it is related to recovery of the housing market. Several local plan exminers have said that if the annual need is x you should allocate under the NPPF for x even if the market will only build out x-y. The problem then you immediately have a zombie plan as you only build x-y rather than x. This has a simple solution. Set a MINIMUM figure on which to base your 5 year trajectory and grant allocations and phasing which would permit more if the market can bear it – up to any level set by physical capacity constraints (which almost always will be based on settlements and places rather than plan area). This is a technical planning issue which has dogged planning policy for 20 years long before the NPPF yet its solution is not difficult.
Update – Bolsover policy LC5 proposes something very similar – now at examination – so in future we may speak of the Bolsolver method not merely Liverpool and Sedgefield.