DEVASSIST: Housing Land Supply Update

Housing Land Supply Update: Appeal for 40 Homes Allowed After Council’s Supply Drops Towards Two Years

In Lancashire, a recent appeal revealed how a drop in housing land supply can reopen sites that many assumed were off the table for development.

In mid-November, a Planning Inspector approved plans for up to 40 homes on land at the edge of Adlington, after finding that Chorley Council’s housing land supply had fallen “close to only two years”. The scheme, brought forward by Adlington Land, included 12 affordable homes on what is currently grazing land south of the village.

A safeguarded site under an ageing plan

Although the land is earmarked as a draft allocation in the emerging Central Lancashire Local Plan, the adopted 2012 Core Strategy still designates it as safeguarded land. Under that policy, development should only come forward in tightly defined circumstances to protect long-term Green Belt boundaries.

This tension between old policy and emerging strategy has become a familiar theme in recent appeals across England, particularly where councils are unable to demonstrate a five-year housing land supply.

Housing land supply is the decisive factor

The council did not defend the appeal, following further discussion with the appellant about drainage matters. Instead, the Inspector focused on the planning balance, giving significant weight to the area’s acknowledged housing shortfall.

Both parties agreed that Chorley’s land supply had slipped to around two years. For context, Planning Magazine recorded a 3.3-year supply in December 2023, meaning the council’s position has deteriorated by nearly 40 per cent in two years.

That deficit engaged the NPPF’s “tilted balance”, rendering housing supply policies out of date and requiring the Inspector to approve the scheme unless its harms clearly outweighed its benefits.

Heritage concerns weighed against public benefit

One of the key issues was the impact on Greenhalgh Farmhouse, a Grade II listed 17th-century stone building adjacent to the site. The Inspector found that the development would cause “less than substantial” harm to the heritage asset and gave that harm “great weight”.

However, the benefits were judged to outweigh the heritage impact. Socio-economic benefits also carried moderate weight.

With no adverse effects that “significantly and demonstrably outweighed” the benefits, the appeal was allowed.

Why decisions like this matter for buyers and conveyancers

This case underlines how quickly housing land supply positions can change – and how that can unlock development on sites that may appear protected or low risk. Safeguarded land, edge-of-settlement parcels and sites adjoining heritage assets may all be more vulnerable to future development where a council’s supply drops.

If your clients are purchasing in an area with an emerging plan or known supply pressures, considering the wider planning context is essential. A DevAssist report provides a clear picture of current and potential development risk, giving buyers and their advisers the insight they need to make informed decisions.

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