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News - 23 May 2010
Underestimated potential?

Council should have “gone down every rabbit hole” to find land for housing says Senior Planning Inspector

At an exploratory meeting on Thursday to look at the city’s Core Strategy – the planning blueprint for the next 20 years – Senior Planning Inspector Roland Punshon made it clear that he doesn’t think that the Plan will pass the forthcoming Examination in Public [EiP].

He said that he had found the housing delivery element of the Core Strategy “confusing and unclear” and had called the meeting because of his concerns about the Strategy’s ability to deliver the requisite housing over the 20 years of the Plan period.

His particular concern was the reliance on “windfall sites” to deliver 36% of the target. Windfalls are sites that are not earmarked for housing but become available unexpectedly e.g. through the unanticipated redevelopment of a site not currently used for housing.

At the outset he made it clear that no Core Strategy anywhere in the UK had been found to pass the test of soundness if it relied on windfalls. He then went on to quiz the council officers about the rationale for leaving out the urban fringe as a potential residential development opportunity saying that the Strategy’s pre-2020 blanket protection policy appeared to be using the circular argument that “the urban fringe is protected because it is urban fringe and because it is urban fringe it is protected”.

He also asked why no work had been done to assess the realistic contribution of small sites capable of delivering less than 6 units suggesting that a Strategy that relied on windfalls should have looked down “every rabbit hole” in the city to find land.

The Inspector proposed four options to the Council:

  • Continue to the Examination in Public [EiP] disregarding his advice in the belief that Core Strategy housing policies are adequate but there is a possibility that it will be found to be unsound at least on these policies
  • Continue to EiP in the belief that the bulk of the Strategy itself is sound but accept that amendments need to be made to housing delivery, which is likely to involve new consultation.
  • Delay the EiP to complete any additional work but such delay could be no more than 6 months.
  • Withdraw the Core Strategy and revise it as necessary, possibly in the light of any new guidance from the new government.


The Council officers struggled valiantly to defend in planning terms a Strategy that, for housing at least, is as much a political document as it is a planning document and hinted as much when they pointed out that it has “unanimous” political backing.

But the Inspector made it clear that he has no interest in politics and is tasked solely to apply national planning guidance although he admitted that the national landscape was in a state of considerable flux with the new government pledged to “rapidly abolish” the regional spatial strategy upon which the district housing targets are based.

The LibDem/Conservative coalition government has pledged to return the decision over housing numbers to local control [see earlier story] and this may well supersede any need to revise or review the struggling housing policies in the Core Strategy.

Read related items on:
Local Development Framework
Brighton & Hove City Council

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