Object

Representation ID: 10159

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Distribution of Growth (DS5(S))
The approach to rely on new settlements to deliver homes in the latter part of the plan is flawed as has been addressed, as it holds back 88% of the new allocations for the second half of the plan placing incredible burden on the first 10 years to deliver no less than might be needed.
Whilst it is noted that the distribution of growth identifies an excess of 1,274 dwellings above the requirement this does not go far enough to counter the very likely under supply from the new settlement strategy.
The distribution of growth policy reinforces the absence of any site’s proposed on the edge of sustainable settlements. It also relies on the allocation of brownfield site’s, some of which will be identified on the brownfield register. As indicated by the NPPF (para 23) these site’s should not be allocated in the plan where they are identified in the register. Potentially this allows a redistribution of up to 1,200 units to the rural areas or the edge of the Urban Area to deliver vital homes in the first ten years of this plan.