Strategic policy considerations
3.1 Environmental constraints and scarcity of land impose limitations
on the ability to provide new housing. However, there is a duty
and legal requirement to provide people in Torbay with a decent
home. This requirement extends to those who are not able to afford
market housing. Whilst we are no longer in a regime of ‘predict
and provide’, information on population, including its
growth and age composition, tells us a great deal about Torbay’s
requirements for homes, jobs and all the other facilities which
serve the community. These should be provided for in the Local
Plan.
Population change
3.2 The Plan preparation and Local Plan Inquiry predated the
2001 Census. Detailed information from this did not become available
until mid 2003, which was 8 years into the Plan period of 1995-2011.
The population and housing assumptions in the Local Plan are
based on mid and late 1990s estimates. Some figures for the 2001
Census are included here for information purposes. However, these
will be taken into account in the preparation of the Local Development
Framework, which will constitute the first review of the Local
Plan. Care should be taken in interpreting the 2001 Census figures,
due to differences in methodology. In particular, the 2001 Census
is likely to have picked up a formerly un-represented ‘hidden’ population.
The resident population of Torbay’s three towns is as follows:-
Figure 4: Resident population of Torbay
Town
|
1991 Census
|
1999 mid year
estimate
|
2001 Census*
|
Torquay
|
59,587
|
61,800
|
63,998
|
Paignton
|
41,442
|
42,900
|
48,251
|
Brixham
|
18,645
|
19,400
|
17,457
|
Torbay
|
119,674
|
124,100
|
129,706
|
Source: 1991 and 2001 Censuses
- mid-year estimates.
Note:* For information only.
3.3 Torbay’s population growth has slowed down since the
rapid expansion of the 1960s and the early 1970s as Figure
5 shows.
3.4 Figure 5 also shows the most recent ODPM
population projections for Torbay up to 2011. Whilst the projected
rate of growth is low compared to the boom years of the 1960s,
it is an increase on recent years. However, the following factors
need to be borne in mind:-
-
The strategic framework is the Adopted Devon Structure Plan
First Review (1999) and the Local Plan housing provision
is in line with this. There is therefore no need to increase
the housing provision in this Plan.
-
The Government has moved away from ‘predict and provide’ to
a ‘plan, monitor and manage’ approach. The projection
in Figure 5 takes no account of strategic
planning (including environmental) factors which are accepted
by Government, RPG and the Structure Plan to be important
in Torbay (see paragraphs 2.10 to 2.20).
One consequence of the ‘plan, monitor and manage’ approach
will be that the Local Plan’s housing provision will
be reviewed after a few years. By that time, the population
forecasts may have changed again.
-
It is important, in order to achieve sustainable development,
to ensure that there is a balanced provision between economic
development (and employment) and housing provision. In future,
there needs to be more ‘coupling’ of these two
aspects rather than continuing to attract new residents without
the corresponding appropriate amount of employment.
3.5 The average household size in Great Britain had been about
4.6 people for many years until the early 20th Century. Figure
6 shows the move towards smaller households since 1981,
indicating an increase in demand for additional housing. 1998
estimates indicate that the average household size in England
is 2.37 people. In the South West it was 2.34 and 2.25 in Torbay.
There is every indication that the average household size is
set to fall further with the increasing tendency to form single
person households (about 30% of households in Devon) with fewer
traditional nuclear families, although this is slightly offset
by very recent evidence of increasing cohabitation. This, together
with the fact that people are living longer, has implications
for housing provision in the Local Plan, not only in allocating
more dwellings for a given population than hitherto, but also
in making provision for an increased number of smaller dwellings
to meet the needs of Torbay’s existing and future residents
through the Plan period. However, there is even a demand from
many smaller households for increased space provision in the
form of bedrooms for visitors, storage and space for hobbies,
activities or for working from home.
Figure 5: Population growth in Torbay
|
|
Year
|
Population
|
Change (10 year
periods)
|
% increase per annum
|
Actual
(Census)
|
|
1951
|
85,300
|
|
|
|
|
+ 5,900
|
+ 0.69
|
1961
|
91,200
|
|
|
|
|
+14,700
|
+1.61
|
1971
|
105,900
|
|
|
|
|
+7,100
|
+0.67
|
1981
|
113,000
|
|
|
|
|
+6,700
|
+0.59
|
1991
|
119,700*
|
|
|
1997**
|
122,900
|
(+10,000)
|
(+0.83)
|
(2001)
|
(129,700)
|
|
|
Projected
|
|
2001
|
124,700
|
|
|
2006
|
128,600
|
+8,900
|
+0.71
|
2011
|
133,600
|
|
|
Source: DETR (now ODPM) population
projections 1998 - Census.
Notes:
2001 Census figures for information only (see paragraph 3.2
above).
* Includes for the first time imputed wholly absent households.
** Office for National Statistics mid-year estimates.
Figure 6: Reduction in average household size
in Devon 1981-2021
|
1981
|
1991
|
1996
|
2001
|
2006*
|
2011*
|
2016*
|
2021*
|
% per annum change 1981-2001
|
% per annum change 1981-2011
|
Average house- hold size
|
2.57
|
2.40
|
2.33
|
2.28
|
2.23
|
2.17
|
2.13
|
2.09
|
0.29
|
0.32
|
Source: Projections of Households
in England to 2021(DETR 2000)
Note: * Projected.
Figure 7: Resident population
Age group
|
|
|
Torbay Residents
|
|
|
|
1971
|
1981
|
1991
|
1997*
|
1999*
|
2001++
|
0-4
|
6,000
|
5,075
|
6,410
|
6,459
|
6,515
|
6,276
|
5-15
|
13,725
|
14,887
|
13,896
|
15,558
|
15,919
|
15,470
|
16-retired
|
55,020
|
59,700
|
66,037
|
68,387
|
69,382
|
74,611
|
Retired
|
31,325
|
33,239
|
33,331
|
32,457
|
32,298
|
33,349
|
Source: 1971, 1981 and 1991 Censuses.
Notes:
++ 2001 Census for information purposes only.
* ONS Mid-Year Estimates 1997 and 1990 (figures may not be strictly
comparable with Census data).
** males 65+; females 60+.
3.6 Another critical aspect of the population make up is its
age structure. Figure 7 shows the growth of
the resident population since 1971 and highlights Torbay’s ‘top
heavy’ age structure. The growth of the working age group
is also evident.
3.7 Figure 8 compares Torbay with the average
age structures for Great Britain and Devon. The high proportion
of the elderly reflects the heavy migration rates, particularly
of the retired, experienced over recent decades. There has been
and continues to be a net inward migration of people to Torbay
in nearly all age groups, without which the population would
naturally decline. However, the proportion of the elderly in
Torbay has fallen slightly in recent years, from 29.5% in 1971
and 29.4% in 1981 to 27.9% in 1991, to 26% in 1999 and 25.72%
in 2001. However, the elderly population is likely to rise in
the Plan period, due to the nation’s ageing population
structure. In particular, the number of people aged 85+ is likely
to increase. Figure 9 illustrates the population structure changes
experienced in Torbay between 1991 and 2001.
Figure 8: Population structure (1991)
Age groups
|
Torbay %
|
Devon %
|
G.B. %
|
Under 16
|
17.0
|
18.5
|
20.1
|
16-retired
|
55.1
|
58.2
|
61.2
|
Retired
|
27.9
|
23.3
|
18.7
|
Source: 1991 Census.
Figure 9: Population structure of Torbay -
Change 1991-2001
Age
|
1991
|
2001
|
0-17
|
19.3%
|
20.4%
|
18-44
|
33%
|
0.7%
|
45-64
|
23.0%
|
26.3%
|
65-84
|
21.6%
|
18.9%
|
85+
|
3.1%
|
3.75%
|
Source: 1991 and 2001 Censuses.
Strategic housing provision: plan, monitor
and manage
3.8 The overriding housing aim of the Government is to provide
everyone with the opportunity of a decent home. The strategic
approach to achieving this in the context of sustainable development
stems from the White Paper ‘Planning for the communities
of the future’ (1998) which stated “For too long
we have been stuck in a ‘predict and provide’ approach
to meeting demand for new homes. This Government intends to break
that mould.” The Government’s policy document ‘Sustainable
Communities - Building for the Future’ (February 2003),
informally known as ‘The Communities Plan’, reinforces
its commitment to developing houses - and especially affordable
housing - within a sustainable context.
3.9 ‘Plan, monitor and manage’ is the phrase now
given to this new approach, which is set out in PPG3 ‘Housing’ (2000).
This links with the six housing objectives as set out in Figure
3 Strategic statement, aims and objectives of the Local Plan.
It comprises the following elements:-
-
The plan element includes the need, within
a long-term context, to take a realistic and responsible
approach to future housing provision - firstly at a regional
level which is then cascaded down to structure plans and
finally, at a more detailed level, in local plans. There
needs to be a balance between housing and economic growth
and a reconciliation with social and environmental considerations.
-
The monitor element includes the need to
keep both housing requirements and housing provision under
regular review, based on factors such as household projections,
economic needs, the capacity of urban areas to accommodate
more housing, environmental implications of new development
and infrastructural capacity.
-
The manage element includes the phasing
of land releases to ensure that new infrastructure is co-ordinated
with new housing development and that the rate of development
of brownfield sites is on target and does not lag behind
the development of greenfield sites. Managing should also
guard against under or over-provision of housing - i.e. in
this Local Plan, in relation to the Devon Structure Plan
provision to 2011.
Regional Planning Guidance
3.10 The 1994 version of Regional Planning Guidance for the
South West (RPG10) set the regional context to 2011. Torbay was
identified as a one of the main urban areas, to accommodate “a
substantial proportion of the Region’s housing and other
development in ways which make the most effective use of land,
transport and other services whilst protecting adjoining rural
areas”. RPG10 also cited Torbay’s environmental quality
and limited scope for substantial growth, and these environmental
limitations have influenced the Structure Plan’s constrained
housing provision for Torbay.
3.11 The revised RPG10, adopted in September 2001, also acknowledges
that environmental and transport constraints restrict the potential
for physical expansion of Torbay. However, the need for substantial
economic diversification and regeneration is identified in Policy
SS16. RPG10 sets out regional objectives of providing everyone
with the chance of a decent home; minimising greenfield development
by prioritising re-use of previously developed land, bringing
empty properties into use and conversion of existing buildings;
creation of mixed communities, sustainable patterns of development
and well designed residential environments to promote urban renaissance
(paragraph 7.1). Policy HO2 promotes the monitoring and management
of housing provision, whilst HO3 encourages the provision of
sufficient affordable housing. HO5 and HO6 relate to maximising
use of previously developed land, and mix of housing types and
densities respectively. The Local Plan’s preparation period
coincided with the preparation of the revised RPG10, the context
of which it therefore reflects.
Devon Structure Plan
3.12 The Adopted Devon Structure Plan First Review (1999) is
part of the development plan for Torbay and sets out strategic
housing provision. The Structure Plan indicates that about 6,200
dwellings are to be accommodated in Torbay during the Plan period
(1995-2011), whilst recognising that:
-
firstly, land suitable for new housing is becoming an increasingly
scarce resource in Torbay;
-
secondly, a high level of commitments already exists in
terms of planning permissions; and
-
thirdly, the extensive urban area of Torbay offers scope
for increased housing through the development of small ‘brownfield’ sites,
redevelopment and conversion, without loss of amenity.
3.13 The Structure Plan housing provision is constrained to
a far greater degree than is the case for employment land, for
reasons set out in Chapter 2. Figure 10 illustrates
the level of housing constraint for Torbay, South Devon and the
entire Devon area in relation to the demographically implied
provision. The ‘demographically implied provision’ is
the amount of housing provision which would be provided solely
on the basis of population estimates, i.e. if environmental constraints
had not been taken into account.
3.14 Figure 10 shows that the Structure Plan
housing provision for Devon almost equals the demographically
implied provision. In fact, South Devon was the only sub-region
out of the four Devon sub-regions to receive a constrained housing
provision and the Torbay provision is close to the South Devon
average.
Figure 10: Structure Plan housing provision
for Torbay and South Devon
Area
|
Demographically
implied provision
|
Structure Plan Provision
|
Structure Plan Constraint
|
Devon
|
76,700
|
75,800
|
-1.2%
|
South Devon
sub region
|
18,700
|
14,900
|
-20.3%
|
Torbay
|
7,500
|
6,200
|
-17.3%
|
Source: Adopted Devon Structure
Plan First Review (1999). Accommodating Change in Devon (1996),
Proposed Modifications (1998) and Structure Plan demographic
work.
3.15 In order for the Local Plan constraint strategy to take
effect, the Council considers that, as a first step, it must
ensure that the high level of unimplemented planning permissions
is not increased even further ahead of the completion rate, and
that large sites which already have permission for housing should
be targeted for development.
3.16 Policies to control the rate of new approvals are essential
to this strategy. They also need to be monitored in relation
to completion rates to ensure that they are applied in a responsive
and flexible way. The Council considers that, once existing commitments
have been reduced, the restraint policy should aim to achieve
an average completion rate of about 350 dwellings a year. Towards
the end of the Plan period this should be treated as a maximum.
3.17 It important that Torbay’s growth does not run out
of control. Torbay can meet most of its Structure Plan requirements
on committed sites, allocations on previously developed (brownfield)
land and a continuation of the existing rate of brownfield windfall
development. The Local Plan therefore contains proposals to release
only two additional greenfield housing sites which were not previously
identified in the Adopted Torbay Local Plan (1991) which covered
the period 1981-1996, (in addition to one mainly brownfield site
on the edge of Brixham).
Range of forecasting
3.18 The forecasting of dwelling requirements is not an exact
science and standard models to assess the future levels of housing
demand probably do not take sufficient account of local circumstances.
Even during the comparatively short period since 1981 there has
been considerable variation in the completion rate in Torbay.
Using completion rates as a guide to future provision over the
Plan period, estimates would vary from 4080 (i.e. 104 dwellings
x 20 years) at the lowest rate to 12,500 (625 x 20) at the highest
rate. Taking the average over the 1981-2001 period, the figure
would be 8,350 (417.5 x 20) dwellings.
3.19 Figure 11 shows the number of housing
completions for each year from 1981 to 2003. The Local Plan is
seeking to achieve a significant reduction in the level of housing
development, compared with that achieved during the speculative
years of the late 1980s and very early 1990s.
Figure 11: Housing completions
Financial Year
|
81/82
|
82/83
|
83/84
|
84/85
|
85/86
|
86/87
|
87/88
|
88/89
|
89/90
|
90/91
|
91/92
|
92/93
|
Completions
|
204
|
266
|
376
|
518
|
446
|
466
|
274
|
625
|
625
|
566
|
264
|
294
|
Financial Year
|
93/94
|
94/95
|
95/96
|
96/97
|
97/98
|
98/99
|
99/00
|
00/01
|
01/02
|
02/03
|
03/04
|
Completions
|
392
|
469
|
527
|
285
|
432
|
638
|
449
|
448
|
571
|
481
|
354
|
Source: Torbay Survey of Housing
Land 1999, Torbay Housing Land Monitor 2003.
Completion returns from HBF and Environment Services.
Note: Figures show numbers of dwellings.
Making provision for completions
3.20 The way in which the Structure Plan requirement of 6200
dwelling completions for the period 1995 to 2011 is to be accomplished
is shown in detail in Figure 12, see below:-
Figure 12: Meeting the Structure Plan housing
requirement
|
Category
|
Potential consents
|
Certainty of completions
|
Estimates of completions
|
1.
|
Dwellings built 1995 - 2001
|
2880
|
100%
|
2880
|
2.
|
Dwellings under construction 2001
|
251
|
100%
|
251
|
3.
|
Dwellings with planning permission
|
|
|
|
|
i) large sites
|
955
|
95%
|
907
|
|
ii) small infill sites
|
208
|
75%
|
56
|
|
iii) small redevelopments
|
208
|
75%
|
154
|
4.
|
Brownfield potential
|
|
|
|
|
i) small infill sites
|
596
|
70%
|
417
|
|
ii) small redevelopments
|
191
|
70%
|
134
|
|
iii) conversions
|
500
|
100%
|
500
|
5.
|
Local Plan H1 sites
|
1041
|
85%
|
885
|
|
Total
|
6827
|
70-100%
|
6284
|
Source: Torbay Housing Land Monitor
2001 and Urban Housing Potential Study 1998.
Inspector’s Report into Objections to the Plan - Recommendation
no. 3.04.
Notes:
1. The percentage completion rates are based on the 1998 data
used in the Council’s Urban Housing Potential Study with
a slightly more conservative estimate of conversions. In updating
the figures to 2000/1, the percentage completion rates have been
reduced in categories 3, 4 and 5 (except conversions) to reflect
the fact that there were two fewer years of the Plan to run.
However, a more conservative rate of actual conversions has been
applied.
2. See Inspector’s Report into Objections to the Plan,
Section 3.2.3, Issue (e), pp 23-24 for his comments on certainty
of completion assumptions.
3. These figures will be reviewed in the light of further monitoring,
e.g. completion rates, expired permissions, etc, when reviewing
the Plan and in considering the release of Phase 2 sites.
4. Only H1 proposals which did not have planning permission
in April 2000 are included in these figures, i.e there is no
double counting with committed dwellings in 3 i).
3.21 Figure 13 is a bar graph which shows at
a glance the contribution made by the categories of the previous
table (Figure 11) and the relationship of consents
to completions.
Figure 13: Local Plan housing provision 1995-2011

[Click to see larger image in a pop-up window]
Minimising greenfield development through
a sequential approach to housing provision
3.22 Government advice, in particular PPG3 ‘Housing’ (2000),
and the sustainable development agenda in general, encourage
Councils to maximise the provision of new housing on ‘brownfield’ or
previously developed land within urban areas, subject to proper
environmental considerations. This is in order to minimise the
loss of countryside and promote sustainable communities, with
housing located close to other uses, such as employment land.
PPG3 also advocates the application of a sequential approach
to the release of housing land and the phasing of land to ensure
that urban areas are targeted first. However, the Government
is also determined to promote urban renaissance in which everyone
has the opportunity of a decent home. It is important to ensure
that the emphasis on housing development within the urban areas
does not compromise the quality of life already enjoyed by urban
residents through ‘town cramming’.
3.23 Following Government advice and the sustainable development
agenda and based on the results of the Urban Housing Potential
Study, the aim of the Local Plan is to achieve at least 65% of
its housing provision on brownfield sites. This is well above
the target of 60% by 2008 set out in PPG3 (paragraph 23). This
strategic housing aim will be used by the Council as a basis
for monitoring the release of new housing sites.
3.24 Figure 12 shows that a significant proportion of the Structure
Plan requirement (70.1% as of 2001) is already built, under construction
or with planning permission and estimated to be completed within
the Plan period. The Council’s sequential approach to achieve
the remainder of the Structure Plan housing requirement, includes:-
-
Making best use of existing housing stock.
-
Making a realistic allowance of the potential of small urban
brownfield sites (below 0.4 hectares/1 acre) based on the
Urban Housing Potential Study (see below) and developing
land at as high a density as is appropriate (Policy
H10).
-
Identifying large brownfield sites of over 0.4 hectares/1
acre as Policy H1 housing sites.
-
Only identifying greenfield sites of more than 0.4 hectares/1
acre as Policy H1 housing sites to meet
the outstanding residual need not met through the development
of brownfield sites.
-
Phasing releases in two periods to ensure a 5 year land
supply from 2000-2005 and 2006-2011. Whilst the release of
the brownfield sites will not be constrained, the release
of greenfield sites will be constrained in order to ensure
that over-provision does not occur.
3.25 It is important to realise that the granting of planning
permission or the inclusion of a proposal in the Local Plan -
and to an even greater degree, the identification of an allowance
for small ‘windfall’ sites - does not guarantee their
development, either within the Plan period or at all. The Structure
Plan provision is for housing completions, and for the Plan to
be realistic, it is necessary to apply a ‘certainty of
completion’ factor to each category of development in Figure
12. The certainty of completion factor used in the Local
Plan is based on experience and on discussions with local developers
and was raised at the Devon Structure Plan Examination in Public.
It ranges from 70% for small sites identified in the Urban Housing
Potential Study, which do not have planning permission, to 95%
for larger sites with planning permission. These percentages
were supported by the Local Plan Inquiry Inspector, but will
be reviewed in the light of further monitoring.
3.26 The implications for Local Plan allocations are that:-
a) an allowance has to be made for certainty of completion,
i.e. the total number of potential consents has to exceed the
estimated completions total by a carefully calculated margin;
and
b) it is important to ensure against significant over-provision
of completions on greenfield sites which would be detrimental
to the Local Plan’s environmental policies. It is therefore
extremely important to monitor the rate of completions to ensure
that significant under or over provision does not occur.
3.27 The Council will monitor the implementation of greenfield
sites carefully through the annual Torbay Housing Land Monitor.
Major new greenfield releases will be controlled through Policy
H1A in order to ensure that the development of brownfield
sites is on course to meet the Council’s 65% brownfield
target. Progress towards this will form an important basis of
the review of the Plan.
3.28 In the face of rising house prices the Treasury and ODPM
commissioned a major study of housing supply in the UK in 2003.
The resulting study, the Barker Review of Housing Supply, was
published in March 2004. This identified the need to significantly
increase numbers of housing completions in order to reduce house
price inflation. The Review suggests a national need for between
70-120,000 additional new private sector homes per year and up
to 26,000 additional affordable homes per year. The Barker Review
is a study intended to inform policy and not in itself a policy
document. The Review’s findings are likely to influence
emerging Planning Policy Statements, particularly PPS3, and will
be a material consideration in the review of the Local Plan through
preparation of the Local Development Framework. They should not
be taken as a justification for varying the plan, monitor and
manage strategy outlined above.
Large housing sites
3.29 In accordance with PPG3 and other current Government advice,
the Local Plan defines several large housing sites in Policy
H1, in order to provide a positive lead for development
and certainty for both the community and developers about land
use changes. Allocating large housing sites also allows the development
of mixed communities, served by a range of community facilities
and public transport. Some of these sites have planning permission
and their identification represents a commitment to renew these
permissions during the Plan period and safeguard key aspects,
e.g. affordable housing or design considerations. Policy
H1A phases the release of greenfield sites, in accordance
with the plan monitor and manage approach.
3.30 A major change in the Local Plan from the 1999 Deposit
Version is the reduction in the number of greenfield housing
sites by over 200 dwellings and an increase in provision on brownfield
land. In the Adopted Plan about 66% of the H1 sites are greenfield,
compared with 75% in the Deposit Version. Moreover, the overall
housing provision in the Local Plan represents a major shift
in emphasis to providing housing provision on smaller sites,
in particular within the urban area, that have been identified
by the Urban Housing Potential Study. It is considered that sufficient
large sites have already been allocated in the Local Plan and
unallocated large greenfield sites will not be granted permission
for housing development. Policy H1 clarifies this point. Policy
H1.22A sets out special considerations applying to the
former Dolphin Holiday Camp in Brixham.
Allowance for small sites and the Urban Housing
Potential Study.
3.31 In order to maximise urban capacity, PPG3 indicates that
local authorities should carry out studies of urban capacity.
The Council’s Urban Housing Potential (1999) provides a
realistic assessment of how much of Torbay’s housing requirement
can be met from its urban areas through ‘windfalls’,
i.e. brownfield sites which are too small to be identified on
the Proposals Map. This includes analysis of infill sites and
redevelopment of derelict /rundown buildings. Although it pre-dates
the March 2000 version of PPG3, the assumptions contained in
the Urban Housing Potential Study are broadly in line with the
definition of previously developed (brownfield) land contained
in Annex C of PPG3. An estimate of sub-division of residential
and conversion of commercial premises has also been made. The
Study is a supporting document to the Local Plan and explains
the methodology and conclusions in more detail. The Urban Housing
Potential Study was debated at the Local Plan Inquiry and the
Inspector broadly supported its methodology and conclusions (see
paragraphs 3.2.3, Issue b, pp 19-20 of the Inspector’s
Report).
3.32 The Study estimated that a total of 1975 new housing consents
were likely to come on stream over the period of 1998-2011, which
translated to about 1677 completions based on certainty of completion
estimates. Figure 14 summarises the Study’s
findings for each town and by the main types of windfalls.
Figure 14: Torbay - Potential housing opportunities
on previously developed sites 1998- 2011
Town
|
Redevelopments
|
Infills
|
Conversions
|
Total
|
Torquay
|
313
|
379
|
507
|
1199
|
Paignton
|
123
|
214
|
211
|
548
|
Brixham
|
10
|
156
|
127
|
293
|
Torbay Total
|
446
|
749
|
780
|
1975
|
Average per annum
|
34
|
58
|
60
|
152
|
Source: Urban Housing Potential
Study 1998.
3.33 The Urban Housing Potential Study identifies a high potential
for new windfall housing arising within Torbay’s urban
areas. Translating this potential into new homes is critical
to achieving the Council’s target of at least 65% of all
new residential development taking place on previously developed
(brownfield) land. This is above the Government’s latest
target of 60% and well above the Regional Planning Guidance more
modest target of at least 50% for the South West Region to 2016.
3.34 Of course, windfall housing developments by their very
nature are not foreseen and any estimate of potential completions
has to be extremely cautious. The Local Plan needs to strike
a balance between certainty of development, by giving a clear
steer to specific sites for development, and placing an emphasis
on developing appropriate urban areas, which means relying on
windfall sites. Policy H2 outlines the Council’s
policy towards housing proposals on unallocated sites, and its
commitment to ensure that an appropriate supply of consents occurs
which does not lead to significant under or over housing provision.
|