Javid Favours Liverpool Approach in Planning Appeal

Land to the North of Dark Lane Alweras recovered appeal

There are two commonly used methods for addressing an accumulated shortfall. The ‘Liverpool approach’ apportions the shortfall across the remaining years of the plan period, whilst the ‘Sedgefield approach’, seeks to make up the shortfall during the next five years. The Secretary of State has had regard to the Guidance which advocates the ‘Sedgefield approach’ stating that Local Planning Authorities should aim to deal with any undersupply within the first 5 years of the plan period where possible.

30.However, he notes that this was an issue recently considered by the Local Plan Inspector who found, following rigorous examination, that the ‘Liverpool approach’ was more appropriate in the case of Lichfield notwithstanding the advice in the Guidance. The Local Plan Inspector’s conclusion was reached having regard to past rates of delivery in the district, including prior to the recession, and the requirement for completions far in excess of the highest levels ever achieved in the district if the ‘Sedgefield approach’ were adopted. The Local Plan Inspector highlighted that plans are required to be realistic as well as aspirational and that the Local Plan would likely fail if the Sedgefield approach was used.

31.The Secretary of State further notes that the Local Plan Inspector recognised the potentially critical impact of using either the Liverpool or Sedgefield approaches, and the Guidance, before reasoning that the required housing trajectory using the ‘Sedgefield approach’ was highly likely to prove unrealistic due to the serious doubt about the necessary high rate of delivery over five years would be attainable in market terms.

32.The Secretary of State has carefully considered the parties submissions in favour of the ‘Sedgefield approach’ being adopted. These are, in summary: That past rates of delivery were constrained by policy to direct development towards the urban area; That the Council has published increased housing projections; and That in the period since the LP Inspector considered this issue, it has become clear that the under-provision of housing in Birmingham will lead to increased housing demand in Lichfield (IR 12.50).

33.Having carefully considered these issues, the Secretary of State considers that these matters do not represent sufficient grounds to not follow the ‘Liverpool approach’ to addressing shortfall adopted within the LP following rigorous examination and, therefore, he agrees with the LP Inspector and the Inspector (IR 12. 51) that the shortfall should be apportioned across the remaining plan period.

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