Can the creation of mobile homes assist in areas with a housing deficit?

Planning permission has recently been granted, on appeal, for the change of use of land adjacent to an existing mobile home park in Berkshire. The Inspector ruled that the deficit in the housing supply in the area meant that the proposal would be of considerable benefit to housing supply numbers, which reduced the weight to be afforded to policies restricting development outside defined settlements. A copy of the Inspector's decision can be found here.

The appellant sought to accommodate an additional 82 mobile homes on land previously used for the grazing of horses.  The appeal site is located to the east of the existing mobile home park, which contains just over 500 dwellings. 

The Inspector ruled that whilst the proposed development would result in an encroachment into the open countryside  it would be similar in nature to the existing mobile home park and would not be "unduly incongruous or uncharacteristic".  The Inspector concluded that the proposed development would "protect the character and quality of the local landscape and wider countryside".

In terms of the impact the development would have on housing numbers the Inspector considered that an increase to the housing supply in an area with a "sizeable deficit in its land supply" could be considered "a benefit".   In addition, the Inspector considered that the creation of mobile homes would result in a proportion of larger traditional family homes being made available as mobile homes are typically taken up by older occupiers.

As currently defined, in the National Planning Policy Framework ("NPPF"), mobile homes do not fall within the definition of affordable housing and therefore do not count towards the affordable housing numbers. In this case, despite the local planning authority having a policy which requires on-site affordable housing provision in the majority of circumstances, the Inspector was willing to consider a financial contribution in lieu of on-site provision.

In conclusion the Inspector ruled that the lack of a five year land supply in the district meant, in accordance with paragraph 49 of the NPPF,  the relevant policies for the supply of housing  were to be considered out-of-date and carried reduced weight. The Inspector referred to the recent Supreme Court case  which made it clear that the primary purpose of paragraph 49 is to trigger the operation of the tilted balance  in paragraph 14 of the NPPF.  The important issue being whether the application of the local planning authorities polices were achieving a five year land supply, and in this case they were not.   This, when considered alongside a lack of overriding harm to the countryside or sustainable travel, resulted in the scheme being allowed.

The importance of mobile homes on housing supply numbers is supported by Section 124 of the Housing and Planning Act 2016, which recognises mobile homes as having a role in contributing towards the supply of housing in a given area. There has already been discussion in the Government's White Paper 'Fixing our broken housing market' about low cost market homes, such as mobile park homes,  and the role they can play in housing supply. It remains to be seen what impact mobile homes could have in the future, but it is unlikely this decision will be the last. 

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