I was recently asked the question: “Once we reach the total in SAMDev, can we stop giving planning permission for more houses?”
The answer is: “Probably No”. There is every likelihood that we could end up with more housing than the SAMDev total before the current local plan expires in 2026.
The Site Allocations and Management Development document (SAMDev) sets housing totals for many of the settlements in Shropshire, including Ludlow. The current version will be agreed by Shropshire Council on Thursday and will then proceed to the planning inspectorate for examination.
But even when SAMDev is adopted later this year or early next, it doesn’t put an absolute cap on housing development in Ludlow.
It works like this. SAMDev says on page 140:
The guideline for growth in [Ludlow] is for around 875 new dwellings and a minimum of 6 ha of employment land between 2006 and 2026.
Note that word guideline. Note also that the planning period begins in the past, 2006. A few houses have been built since 2006 and rather more have been given planning permission. Some sites, such as the old brickworks on Fishmore Road, have permission for nearly 100 houses and not a single property has been built. However, given the building and the planning permissions since 2006, Ludlow is due 344 extra dwellings by 2026.
SAMDev allocates 280 of these homes beyond the bypass at Rocks Green and beside the Eco Park. The rest of the houses are expected to come from windfall sites, mostly within the existing town.
But hang on!
We have a bid before the planning committee at the moment for around 215 houses off Bromfield Road. There is an application for an extra 20 houses or so on Fishmore Road. Developers are eyeing up the land between Foldgate Lane and Greenacres for maybe 150 homes. This is perhaps only the tip of the iceberg.
So can we reject applications that take Ludlow above the housing allocations in SAMDev?
I put this question to Ian Kilby, Planning Services Manager at Shropshire Council. He replied:
In essence the target figures for each settlement, while significant (when SAMDev is adopted), are not an absolute…. It is not the case therefore that a target figure for a settlement can be used a reason per se to determine planning applications unless for example the cumulative impacts of successive schemes are significant.
Ian is not saying that developments have to be permitted. The closer we are to our allocation of homes, the more we can resist speculative bids that are not in SAMDev. And SAMDev does say:
Exceeding the settlement housing guideline by too great a degree can result in unsustainable development that stretches infrastructure and community goodwill towards breaking point.
More details are below. I’ll write more posts on SAMDev as it goes through the examination process. My view has long been that we cannot in the longer term resist development beyond the bypass. We should grasp the nettle now and plan for a well-designed garden suburb.
Policy MD3 in SAMDev
3. The settlement housing guideline is a significant policy consideration. Where development would result in the number of completions plus outstanding permissions exceeding the guideline, decisions on whether to exceed the guideline will have regard to:
i. The degree by which the requirement is exceeded; and
ii. The likelihood of delivery of the outstanding permissions; and
iii. Evidence of community support; and
iv. The benefits arising from the development; and
v. The presumption in favour of sustainable development.
4. Where a settlement housing guideline appears unlikely to be met by the end of the plan period, additional sites beyond the development boundary that accord with the settlement policy may be acceptable subject to the criteria in paragraph 3 above.
4.16 Delivery of the Shropshire-wide housing target for 27,500 new homes over 2006-2026 is essential to the long-term prosperity of Shropshire. Individual housing guidelines for each settlement are provided in policies S1-S18. To ensure that delivery is achieved, a positive approach will be taken towards partial reviews of the Local Plan;
4.17 Allocation of a site for development does not reduce the quality requirements in any way. The Local Plan design requirements are largely detailed in policies CS6, CS7, CS17, MD2, MD12 and MD13. New development should be a good neighbour that does not unacceptably impact on existing residential amenity;
4.18 To reflect the emphasis that the NPPF places on ensuring a suitable mix of housing and apply Core Strategy policy CS11, the Shropshire Place Plans will provide information on the different types of housing required at a local level. In this manner the needs of different groups in the community will be identified, including for example the needs of older people, people with disabilities, service families, people looking for their first home, people unable to afford market housing, and people wishing to build their own homes;
4.19 Some planning consents are kept ‘alive’ by repeated renewals of planning consent that is not accompanied by any action to bring forward development. To avoid such sites causing problems for the delivery of housing, applications for renewal of planning permission will have to demonstrate some commitment to delivery;
4.20 Should there not be a five year supply of housing land in Shropshire as a whole, then paragraph 49 of the National Planning Policy Framework (NPPF) effectively allows sustainable housing developments to take place beyond settlement development boundaries. To ensure that a flexible, responsive supply of housing land is maintained throughout the plan period, if a settlement is struggling to achieve its housing guideline within the plan period then a positive approach will be taken to development on sites that may lie outside the development plan boundary but are otherwise in accordance with Shropshire Site Allocations and Management of Development (SAMDev) Plan. In addition, a partial review of the Local Plan would be actively considered as a means of making further allocations of land to ensure delivery or where a new community-led plan identifies significant additional provision for growth;
4.21 To ensure that there are no barriers to delivery, most allocations of land for development in settlement policies S1-S18 do not make any reference to phasing. Only in cases where there is a specific infrastructure requirement or other specific influence on timing is there any reference in the site allocations to development timescales. For the majority of developments phasing will occur naturally, reflecting market forces and the practicalities of site development. It is expected that the market will improve towards the latter part of the plan period, with higher rates of development in the period 2021-2026 as anticipated in Core Strategy policy CS10;
4.22 The term “sustainable development” in the policy will be interpreted to include whether the development is within the settlement guideline as this reflects detailed consideration by the local planning authority and the community on what level of development is sustainable and appropriate during the plan period. Exceeding the settlement housing guideline by too great a degree can result in unsustainable development that stretches infrastructure and community goodwill towards breaking point.