Object

Representation ID: 9771

Received: 15/03/2019

Respondent: William Davis Ltd

Agent: Define Planning & Design

No clear justification for taking an alternative approach to the standard methodology. Using 2014 household projections proposed by the methodology the minimum annual housing figure of 767 omitting any contribution to the HMA shortfall is well in excess of the OAN for the Borough of 689 identified in the SHMA. Consultation does not seek to revise contribution SMBC is making towards shortfall in housing market area. Para 27 acknowledges that there is no clear justification why the figure of 2,000 was chosen and there is an opportunity to make a greater contribution. We support this, in that there ia an underestimation in the contribution that the Borough could make towards meeting the unmet needs of the HMA. Essential to acknowledge that local housing needs figure is a minimum and a starting point for SMBC to identify the full housing needs that can be met within the Borough. Should be a comprehensive review of SMBC contribution to meeting the HMA shortfall.