Object

Representation ID: 8481

Received: 27/09/2021

Respondent: Richborough Estates

Agent: Fisher German LLP

The proposal to utilise a stepped trajectory, referenced at 3.5 of the draft Plan, is not supported and not considered sound. Whilst the Council point to difficulties in achieving the uplift against the current housing requirement, this is primarily due to the approach to reduce the adopted Plan period, to a functional period up to 2030, despite the concerns of the development industry at the time. It is to us entirely inappropriate that these reported difficulties can be used as justification to delay current housing needs to later in the Plan period. This approach is particularly considered problematic in that, as detailed previously, housing needs will increase further; this, combined with stepping the trajectory to deliver increased numbers later in the Plan period will only further compound delivery. We have not seen any specific evidence which to us leads to the conclusion that a higher quantum of housing cannot be delivered in the short term and we are aware of a number of sites, including land east of Newton Lane, Turvey, which are available and can make an immediate contribution to the Council’s housing land supply. On this basis, there is no justification for a stepped trajectory to be utilised.