DEVASSIST: Inspector backs 110-home scheme on farmland amid ‘very severe’ housing shortfall
An appeal inspector has approved plans for up to 110 homes on unallocated agricultural land in North Warwickshire, pointing to what he described as a “very severe” shortfall in the council’s housing land supply.
The outline scheme, promoted by Richborough alongside private landowners, relates to a 6.37-hectare site near Warton. The application was originally submitted in March 2025 but was not determined by the council, leading to an appeal.
At the centre of the decision was a significant dispute over the authority’s housing land supply position.
Housing supply under scrutiny
North Warwickshire Borough Council argued it could demonstrate a 2.2-year supply of deliverable housing land. The applicant, however, contended that the true figure was far lower.
Following a detailed review of the evidence, Inspector John Longmuir agreed with the applicant’s position, concluding that the council could only demonstrate a 0.82-year supply.
In reaching this view, the inspector identified a number of weaknesses in the council’s assessment, including:
- reliance on sites with infrastructure constraints
- inclusion of sites without planning permission or with only outline consent
- overly optimistic assumptions around windfall development
On windfall sites, he noted:
“One possible indication of windfall numbers is past performance, which typically is 29 dwellings per year in the borough, extrapolating to 145 over five years,”
He also highlighted that the council had already factored in a higher number of windfall units without sufficient justification:
“The council already includes 168 dwellings permitted on known small windfall sites,” but found that no evidence had been presented “to support these higher figures”.
The resulting position places the council among the lowest in the country for housing land supply.
Tilted balance drives outcome
With such a limited supply, the National Planning Policy Framework’s presumption in favour of sustainable development was engaged.
This shifts the decision-making balance firmly towards approval, unless any harm arising from the scheme is considered to significantly and demonstrably outweigh the benefits.
In this case, the inspector concluded that “the benefits of the proposal, including housing delivery, would be substantial” and that any adverse impacts “would not significantly and demonstrably outweigh” those benefits.
On that basis, the appeal was allowed.
Why this matters
This decision underlines how quickly the planning position can change where housing land supply falls below required levels.
Even sites that are unallocated and currently in agricultural use can become viable for development where supply is constrained. The “tilted balance” remains a powerful mechanism, often overriding local policy objections.
For buyers and property professionals, this creates a more fluid landscape. Land that appears protected or unlikely to be developed can come forward unexpectedly, particularly in areas struggling to demonstrate a sufficient pipeline of housing.
It reinforces the importance of looking beyond current land use and understanding the underlying planning pressures that may influence future development.
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