Looking for any views/comments/advice on how to consider a site's
'suitability' for housing' in the SHLAA/SHELAA process. This has been
something we have wrestled with for a while but would like to get
straight when starting a new strategic plan.
General purpose of SHLAAs is to identify sites that have the
potential to provide housing and assess their constraints and their
'suitability', 'availability' and 'achievability' for housing as well
as when they may be delivered and what the capacity of the site is.
The PPG suggests that these assessments can be done either in the
context of an adopted plan or an emerging plan. I'm really looking at
the latter (and working with HMA neighbours). So we are at the
beginning of preparing new strategic plans.
We are trying to take a co-ordinated approach and use same/similar
methodology but when we discuss 'suitable' as an assessment criteria
we end up going round in circles.
The PPG seems to suggest that when doing a SHLAA for an emerging plan
that pretty much anything COULD be suitable IF policy is
changed/constraints are overcome. That means that Green Wedges could
be changed through policy to accommodate new growth, green belt COULD
be changed, development COULD be acceptable in Flood Zone 3 etc. etc.
It becomes more confusing as the PPG talks about 'market signals'
affecting the suitability of a site. Isn't that more about its 'achievability/viability'?
So what is 'NOT SUITABLE'? Perhaps things like SSSIs, Wildlife Sites,
Functional Flood Plain. However, if you considered anything outside
these as being OK for housing this would set an unrealstic amount of
land in the SUITABLE category.
It might be better to say that ALL sites are NOT SUITABLE until
demonstrably made suitable. So Green Belt is 'NOT SUITABLE' until the
policy is actually changed? The SHLAA is evidence, not policy so this
issue of how much regard/weight to give to national and local policy
in considering suitability is difficult. It seems dangerous if you
have an adopted plan in place and are working on a new one, to set out
in evidence that sites constrained by your policies are SUITABLE for
housing because the polic could be changed in the next plan.
So we are stuck in this circular discussion/pattern where we can't
set out that sites are clearly SUITABLE as it requires a policy change
to make them suitable..but we need to assess sites in the context of a
new/emerging plan and so policy could be re-written and in certain
circumstances sites which are not suitable now could be made suitable.
Any thoughts/examples of how others have dealt with this welcomed...
We discussed having a 'POTENTIALLY SUITABLE' category in the SHLAA
but this seems unhelpful and unclear...or does it?
