Object

Representation ID: 6505

Received: 13/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

Growth and spatial strategy options (paragraphs 3.3 to 3.5)
Firstly, we wish to commend the Council on seeking to embrace a housing figure for the plan period which directly reflects our recommendations at I&O stage. At the point of the previous consultation the Council was equivocating over a figure somewhere within a wide range of 800 to 1,305 dwellings per annum (dpa). Following our own assessment of the appropriate housing requirement for the Borough, and on review of the likely Local Housing Need figure to be used as the start point in the calculation of the Objectively Assessed Housing Need, we recommended the following:
“The indicative range upon which the Borough’s emerging housing requirement should be based is 1,153 to 1,305 dwellings per annum. Based on a 20-year plan period until 2040 and taking into account existing commitments of approximately 11,000 dwellings this results in a revised residual requirement for the plan period of between 12,000 and 15,000 dwellings by way of new allocations.”
The Council’s current proposed annual requirement is 1,275dpa (a figure which reflects the upper end of our own suggested range) which results in a residual requirement from new allocation of a minimum of 12,500 dwelling (once again in accordance with our recommendations).
Where we do have concerns is the suggestions around the potential plan trajectory, maintaining the current delivery rate of 970dpa over the remainder of the current plan period until 2030 and only then stepping up to a requirement of 1,580 dwellings beyond this point. This would represent an abdication of the Council’s duty to boost significantly the supply of housing in the face of what is a current and urgent need for at least 1,275dpa. By way of a reminder this Local Housing Need figure is based on immediate levels of natural demand (the Office of National Statistics’ 2014-based household projections) boosted appropriately by an uplift to rectify local issues in respect of affordability. The raw ONS data alone suggests that an average of 985 new households will be created annually over the period 2020 to 2030. The maintenance of delivery of 970dpa prior to 2030 would not even meet naturally occurring demand never mind seeking to rectify issues in respect of affordability. It is imperative that as a priority the new Local Plan 2040 identifies sufficient deliverable sites that could meet the requirement for the LHN-derived 6,375 homes within the first 5 years of the plan period.