Object

Representation ID: 14927

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Housing Land Supply (and Spatial Strategy):
- Limited information available to assess the robustness of the Council’s overall HLS.
- Council should set out in details its assessment of the capacity of SHLAA, Brownfield Register, Town centre and UK Central Hub Area sites.
- Deliverability of these locations will be dependent on viability of PDL and demand for high density urban living post Covid-19.
- HBF not wish to comment on individual sites, but notes the Council has provided no data on a site by site analysis of the deliverability of individual site allocations; critical the Council’s housing trajectory is correct and realistic based on lapse rates, lead in times and delivery rates, supported by site promoters.
- Lack of contingency in Council’s housing supply, as land supply and requirement are same figure, with only 10% lapse rate.
- HBF advocates as large a contingency as possible, and housing requirement should be treated as a minimum rather than a maximum, to provide optimum flexibility, changing circumstances and flexibility to provide greater choice and competition.
- Overall land supply should include a wide mix of sites, short and long-term supply, strategic and non-strategic allocations; housebuilding companies require widest possible range of products and diversified portfolio of housing sites for range of household types.
- None of proposed allocations are less than 1ha, which is inconsistent with 10% requirement in NPPF.
- Notes the housing delivery phases for sites
- Notes that housing trajectory is stepped
- Surplus in 5YLS is only 329 dwellings, can be easily eroded by changes in circumstances. If Council cannot demonstrate 5YLS on adoption of Local Plan it shall be found unsound.