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T7.3: Evolving An Approach To Housing Proposals: The Evidence Base

Where a scheme promoter or local authority is advocating a particular mix of types and sizes of units, it is critical that this is supported by robust evidence.

Where the planning policy is in place and is up to date, this will establish the overall required split between market and affordable provision, and the likely profile of both market and affordable households. At the level of the individual major development site, strategic housing market findings should ideally be augmented by more localised information on need, ways it can be met, and balanced against wider planning requirements. 

Where the evidence or robust policy basis is not in place, a collaborative approach should be taken to the compilation and assessment of the evidence required to support planning policies on the basis of housing market areas. The NPPF makes clear that LPAs need to have a clear understanding of local housing issues, and should prepare a Strategic Housing Market Assessment to assess need, and a Strategic Housing Land Availability Assessment to assess sites to meet that need. These are intended to inform planning and housing strategies but it must be recognised that they will not always be able to provide definitive answers on need, demand and market conditions at any given time or specific location. Where housing market areas span authority boundaries, Local Authorities will also need to work together. 

The NPPF reiterates the need to identify and update annually a supply of specific deliverable sites to provide 5 years worth of housing, introducing a need for an additional buffer of 5% to ensure choice and competition, which could increase to 20% where there is a record of persistent under delivery. According to the NPPF, relevant policies for the supply of housing should not be considered up to date if the local planning authority cannot demonstrate a five year land supply. In such circumstances, the presumption in favour of sustainable development applies.

At the individual site level findings from Strategic Housing Market Assessments can be augmented if necessary by more localised market information. Together these can provide valuable information on the composition of the local housing stock compared to the local population in need, thus helping to identify where actual or projected shortages or over-supplies may exist. For example, there may be a shortage of medium-sized properties across all tenure types (due partially say to sub-divisions or redevelopments of these properties). This can suppress the upward-movement of growing households or even inhibit the local economy as larger households looking to move into a locality to meet employment opportunities find it difficult to find suitably-sized properties. Other factors such as the under-occupation of larger sized properties may also be picked up by local surveys. 

The Blyth Valley BC case in July 2008 established that a councils' affordable housing policy needs to be underpinned by evidence that is financially viable and thus deliverable. This directly relates to that stated requirement in (the former) PPS3, paragraph 28. The Court of Appeal Judgment, held that in respect of the proposed affordable housing proportion target, the target was flawed as no consideration was given to the issue of economic viability. The importance of economic viability has been restated in the NPPF.

Last Updated on Friday 20/04/2012 - 02:05PM

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Advisory Team for Large Applications (ATLAS), 2017