Last week saw an appeal allowed for Hallam Land Management on Land at Carr Road/Hollin Busk Lane, Sheffield. Outline planning permission was granted for up to 85 residential dwellings including open space, with all matters reserved except for access.
Image courtesy of UDAG
The decision turned on three matters:-
· The effect of the proposed development on the character and appearance of the area;
· The effect of the proposed development on heritage assets; and
· Crucially, the planning balance including housing land supply.
At Inquiry, Sheffield City Council stated its housing land supply to stand at 5.4 years, as outlined in the “5-Year Housing Land Supply Monitoring Report December 2020” and as explored by Crowley Associates here. As we also explained in that article, this calculation is based on the ‘old’ standard method housing need figure (i.e. before the “Urban Cities and Urban Uplift” increase is added). Sheffield is one of the top 20 cities and urban centres required to apply a 35% uplift to its housing need figure.
In the Carr Road decision, the Inspector was clear that whilst the City Council wanted to wait until it published a revised 5-Year Housing Land Supply Monitoring Report to adopt the ‘new’ standard method figure (applying the 35% uplift) it must be applied for decision-making as of June 2021. Further, there are no provisions for Local Authorities to ‘opt-out’ of avoiding the effect of the uplift from this date.
Adding the 35% uplift at this stage puts the City Council in trouble with their supply. In this appeal, the Appellant put forward evidence which, with the uplift applied, resulted in a supply deficit of 3,214 dwellings and thus a housing land supply of 3.95 years. Critically, the Inspector sided with the Appellant and found that the City Council cannot demonstrate a 5-year housing land supply.
Added to this, the Inspector also found that the City Council had erred in adding 2,763 student housing units to their supply and therefore discounted them from the entire calculation. In doing so, this further reduces the City Council’s housing land supply to 3.25 years.
This appeal decision now becomes a material consideration in the determination of planning applications in the City and by establishing that the Council cannot demonstrate a 5-year housing land supply, the decision renders all planning policies which control the supply of housing to be out of date, leaving somewhat of a policy vacuum in Sheffield.
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