Housing supply years 10-15, NPPF para 47, 'broad locations' and suitable si - Public forum - Planning Advisory Service (PAS)

Hi Roger, Here's a few thoughts on this. "Sites should be in a suitable location for housing development" Firstly, do we take this use of 'sites' literally? There is no reference to 'broad locations' in Footnote 12. Regardless, I don't think it would be wise to be relying on a site OR a broad location that is not in a suitable location for housing development. "There should be a reasonable prospect that the site is available and could be viably developed at the point envisaged" Again, this refers to 'the site' not the broad location. I'm afraid I don't know if this is deliberate. I am less sure how critical it is though. Wouldn't you want to know if a broad location was going to have some major issues to resolve that would bring into question the prospect of delivery? You could have a potential choice of 'north or west of a town' for example. You'd need to know which one had a 'reasonable prospect' of coming forward before proceeding, I would have thought? If I was doing this, I would ask myself what I would need to do to demonstrate there is a reasonable prospect of the site being delivered from year 6 onwards. So, perhaps (and not exhaustively): Understand ownership and consider if any constraints would require significant amelioration Contact owner(s) to ascertain their view on development, and ask them about known covenants etc Speak to Agencies about the prospect of development - what sort of infrastructure needs to be provided, what prospect is there of any funding for this? What you're looking for, I think, is an 'in principle' agreement. I don't think it requires a signature in blood, or a cheque at this stage though. It is not reasonable to expect infrastructure providers to be able to commit funding etc at this stage. But they should be able to tell you what they think will be required, and what that will mean for the viability of the site. I think you should also build in some monitoring at this stage. Showing the Inspector that you are aware of 'triggers' will be helpful. Is there a point in the next 1-5 years at which something will need to be done/a decision will need to be made for the site to be able to progress in what is currently year 6 or later? If this date passes with no work/decision made then you'd need to consider alternatives. What do others think? There are quite a few post-NPPF plans adopted now. How did you deal with years 6-15?

Adam, Many thanks for taking the time to consider this. I see your general point that the NPPF ‘Developable’ emphasis seems to apply to sites, since the footnote 12 does not mention broad locations. I also see your point that to some extent it we should be seeking to apply the same tests to broad locations anyway. I note the example of a ’broad location’ you use (e.g 'north or west of a town') implies the consideration of major urban extensions outside settlements. However, the original CLG SHLAA Practice Guidance from 2007 (para 46) gave a wider definition of Broad Locations, one that also included ‘areas within settlements, areas where housing development could be encouraged’. Logically this may be in or around town centres/transport nodes; or perhaps low density residential urban areas with scope for intensification. Whilst similar conversations can be had with infrastructure providers in such areas, the scope for understanding multiple individual owner aspirations is much more limited. It would also seem logical that even where there are ownership constraints in such areas, there is a ‘reasonable prospect’ of them being overcome over a 10-15 year period, particularly if the SHLAA has given the development industry greater certainty about where development will be encouraged? Clearly the SHLAA Guidance encouraged Lpas to factor in the housing potential of such areas. It therefore seems logical that there is also an equivalent mechanism to factor them into the Statutory Development Plan’s housing supply? Thanks again for your thoughts