The NPPF starts to bite

    The NPPF starts to bite

    A recent Inspector’s report on a proposed Core Strategy provides an example of the National Planning Policy Framework’s (NPPF) pro-growth stance taking effect.

    The Inspector appointed to hold the Examination into the Bath and North East Somerset Core Strategy has recently published his preliminary conclusions.

    In his findings, the Inspector was particularly critical of the evidence produced by the Council in justifying their strategic housing requirement. The Council are proposing a housing requirement of 11,000 dwellings over the period to 2026, a significant reduction from the 16,000 dwelling target in the RSS. 

    However, the Inspector identifies “critical problems” with the Council’s approach, including a failure to assess the housing requirements of the wider housing market area and the importance that the Council unduly placed upon a link between homes and jobs. 

    In addition, the Inspector also provided some helpful guidance on the interpretation of other key matters contained within the NPPF: 

    (i) Plan Period - the Inspector recognised the 15 year time horizon for a local plan is not a requirement but nevertheless, acknowledged that “a longer term perspective is particularly important if there needs to be any review of the Green Belt.  A 15 year plan period and longer term requirements should inform any further significant work on this plan”.

    (ii) Evidence - the Inspector placed considerable importance upon the need for evidence to support the housing needs of the wider area.  Indeed, he stated that “there is no up-to-date and NPPF compliant evidence to indicate housing needs of the wider area and whether there may be needs from Bristol that should be accommodated, in part at least, within this District”.

    (iii) Under-delivery - the Inspector concludes unequivocally that there is “convincing evidence that the Council has a record of persistent under delivery in housing” and that as a result, a 20% buffer in housing land supply should be required in accordance with the NPPF. 

    The Council were faced with a choice: either abandon the Core Strategy and commence work on a new Local Plan or suspend the Examination to enable further work to be undertaken. The Council has chosen the latter option.

     
     

    Key contacts

    Nick Matthews

    Nick Matthews

    Director
    Planning

    Savills Bristol

    +44 (0) 1179 100 364

    +44 (0) 1179 100 364

     
     

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