Background of the urban fringe housing sites

The examination of the City Plan Part One in 2013 identified the need to look at the city’s urban fringe to help reduce the city’s significant housing shortfall.

There are not enough brownfield sites to meet the city’s objectively assessed housing need in full. The Plan must look at all opportunities to meet the housing need. 

The adopted City Plan Part One (March 2016), identified potential for around 1,000 new homes in parts of the city’s urban fringe. It also indicated that sites would be allocated through the preparation of City Plan Part Two. 

The housing sites proposed in City Plan Part Two (Policy H2) cover only 7% of the city’s urban fringe. This means the vast majority of the existing green space will continue to be strongly protected. 

The allocations give positive opportunities to secure new publicly accessible open space, nature conservation and ecological improvements. This will include:

  • space for food growing as part of new developments
  • more family housing and affordable housing
  • higher standards of sustainability

Council owned sites offer opportunities to meet the housing needs of local communities. This includes support for community led development, community right to build and housing co-operatives. 

The need for brownfield and urban fringe sites 

The adopted City Plan Part One strategy already seeks to maximise development on the city’s brownfield sites. Around 88% of all new housing development being planned for up to 2030 will be on brownfield land. 

All available brownfield sites have been thoroughly assessed subject to detailed assessment through the council’s Strategic Housing Land Availability Assessment (SHLAA), which has considered their development capacity. 

The adopted City Plan Part One estimated the city’s total assessed housing need at over 30,000 homes. The City Plan only provides for a minimum of 13,200 homes, leaving a significant shortfall. Only if the full housing need could be met entirely from brownfield sites would it be justified not to consider urban fringe sites.

National planning policy requires that the City Plan seeks to meet the city’s full assessed housing need, or as much of it as possible taking account of constraints. 

The council must demonstrate that the City Plan Part Two housing allocations will contribute to meeting the City Plan minimum housing target and maximise the city’s housing potential as much as possible. Housing delivery over the Plan period to date has averaged well below the annual City Plan requirement of 660 homes per year. 

The council’s most recent housing figures show a potential housing supply up to 2030 which is above 13,200 homes, but still well below the city’s total identified housing need. Delivery rates over the next few years depend on factors outside the council’s control. This includes housing market conditions and the actions of landowners and developers. 

Therefore the urban fringe housing sites are still needed. To remove them would make it likely that the City Plan Part Two would be found unsound at examination.

Why some housing sites include parts of Local Nature Reserves (LNR) and Local Wildlife Sites (LWS)

National planning policy requires that locally designated sites such as Local Nature Reserves (LNR) and Local Wildlife Sites (LWS) should be protected and enhanced. However, national policy considers the ecology value and importance of these sites is less than international and national sites such as Castle Hill (which is a National Nature Reserve).

The City Plan Part One examination inspector instructed the council look at the housing potential on all urban fringe sites that are not subject to national designations. The Council were also instructed to look at the scope to limit or mitigate the effects of housing development such as through careful design and layout of development. 

All urban fringe sites affecting LNR/LWS have been subject to ecological assessment in the Urban Fringe Assessment (UFA) studies commissioned by the council in 2014 and 2015. The 2015 study set out recommendations for avoidance, mitigation and enhancement linked to the development of the allocated sites. 

City Plan Part 2 requires that development proposals on the urban fringe sites are accompanied by Ecological Impact Assessments to help minimise the impacts of development and provide biodiversity net gains.