Development Special: Local Plan Tribulations
Hastings Borough Council Leader GLENN HAFFENDEN outlines the severe complexities of drafting a Local Plan that will be acceptable to residents as well as to Government
HIP: What is the crossover between the Town Plan and the National Planning Policy Framework, to which the council recently responded?
Cllr Glenn Haffenden: The National Planning Policy Framework (NPPF) is the government’s overarching policy framework for planning in England. It sets out the principles and policies that all local planning authorities must follow when preparing their Local Plans and when making decisions on planning applications. The Local Plan must be consistent with the NPPF to be found sound at examination. This means for example policies on land use, sustainable development and design standards all need to reflect what the NPPF requires.
The council is keeping the progress of the draft NPPF under review in progressing its Local Plan. Consultation closed in March and government has issued no final guidance which is likely to be some months away.
HIP: In February the Government Housing Minister Matthew Pennycook wrote to you, criticising the minimum housing requirement in the Draft Plan of 175-187 dwellings per annum (dpa) a figure which he said represents less than 27% of the area’s local housing need of 697 dpa. He also effectively threatened that the Housing Inspector might not find Hastings Local Plan ‘sound’ unless you increased that figure in line with the NPPF. At the time you said you were ‘furious’ with the letter. Are you still furious?
GH: The simple answer is yes I am! We of course need more housing but what we need is affordable housing for Hastings. I have urged everyone to email our MP Helena (Dollimore) over this as it would be great for her to stand up in parliament and defend Hastings and its need for affordable housing and to also protect our green spaces etc. We will wait and see if she will do this or not!
HIP. Is there any way that Hastings’ housing needs could be met by brownfield development alone?
GH: The housing requirement for Hastings, is determined using the Government’s ‘standard method’. At present this requires us, the borough, to plan for nearly 700 homes per year. Over the plan period, this equates to around 12,500 new dwellings.
The draft Local Plan Preferred Options (Regulation 18), identifies capacity to deliver between 3,141 and 3,373 net new homes over the plan period, focused on a sustainable pattern of distribution across the borough, with priority given to the regeneration of brownfield sites.
However, our assessment of housing land supply potential (Strategic Housing and Economic Land Availability Assessment (SHELAA), which includes every site assessed for potential development, shows that even if every brownfield site were brought forward and fully delivered, this would still be insufficient to meet either the levels identified in the Local Plan or the housing requirement from the Government’s standard method. The council remains strongly committed to prioritising brownfield land wherever possible and will continue to do so.
However, the capacity of brownfield sites is not sufficient on its own to meet the full housing requirement set by national policy. A sustainable and deliverable Local Plan will therefore require a balanced approach that includes both brownfield and suitable greenfield sites.
HIP: What happens now with the draft Local Plan?
Following the consultation the council will consider all representations received. The responses will inform a revised version of the plan. This is the final draft version of the Plan which will be agreed by Full Council before being published for a further statutory consultation stage, Regulation 19.
Once Regulation 19 is complete, the plan and all representations will be submitted to the Planning Inspectorate for independent examination. An Inspector is appointed by the Secretary of State to assess whether the plan is sound and legally compliant. If the Inspector finds the plan sound, with or without modifications, the council can then formally adopt it. At that point it becomes the statutory development plan for Hastings and is used to determine planning applications.
From the Draft Local Plan:
‘The Local Plan must take need into account and provide for an adequate amount, quality, and type of housing in the appropriate places. Policy SP2 states that the Local Plan will make provision for the delivery of a minimum of 3,174 – 3,446 dwellings over the period 2023-2041 (176 – 191 net new dwellings per annum), of which 1,187 – 1,454 are allocated in the Plan. 6.4.
The housing allocations have been informed by the suitability, availability and deliverability assessment which forms part of the Strategic Housing and Employment Land Availability Assessment (SHELAA) process. The site allocations have also been informed by Sustainability Appraisal (SA) process to ensure that sustainable development is achieved in accordance with the NPPF. 6.5.
The plan allocations reflect a brownfield first approach to development, however given the significant land constraints within Hastings greenfield sites have been identified to help meet housing needs in the borough.
The council is aware of the importance of monitoring the delivery of allocated sites in order to ensure housing needs are being met and in order to maintain a continuous five-year supply of deliverable sites. In accordance with the NPPF, the council shall annually identify and update a supply of specific deliverable sites, sufficient to meet its housing requirement for five years plus an additional buffer as applicable.’
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