Object

Representation ID: 8553

Received: 14/03/2019

Respondent: Gladman Developments

In setting out the sources of housing supply the 10% deduction made towards sites which have not yet commenced but benefit from planning consent, sites identified within the SHLAA and sites identified on the Brownfield Register is welcomed to account for non / under delivery. Council should provide evidence on windfall delivery in order to clearly demonstrate that the 2,250 dwelling windfall allowance made by the Local Plan Review is justified and realistic. The Council should review its existing allocations before rolling forward the allocation of these sites through the Local Plan Review as these were first identified in the Core Strategy which was adopted 5 years ago and have still not come forward. The allocation of a site within a development plan is not on its own enough evidence to demonstrate reasonable prospect. Is concerned that there is insufficient flexibility provided within the supply to ensure full and consistent delivery of the housing requirement. The absence of a detailed housing trajectory within the Local Plan means that it is difficult to provide any comments on the deliverability of the housing requirement. It is unclear what assumptions the Council is making in terms of the lead-in time and build out rate for each of the sites identified within the supply. There is a need for the level of flexibility within the supply to be increased to at least 20%.
Agree in principle with the two step site selection process which applies a sequential preference towards non green belt sources of supply. However considers that step 1 and step 2 assessments should be applied to all sites which do not score red. Whilst national planning policy sets out that Green Belt land is to be considered sequentially, this should not be at the cost of other sustainability factors, site suitability and deliverability. Does not object in principle to any allocation shortlisted by the Council but considers that the amount of allocations will need to substantially increase.
Considers that the Council should consider the identification of safeguarded land through the Local Plan review. The benefit of Safeguarded Land being to ensure the longevity and permanence of the Green Belt, whilst providing flexibility for future needs to be accommodated if necessary.