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Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8858

Received: 29/09/2021

Respondent: Woodland Manor Hotel

Agent: Phillips Planning Services

Representation Summary:

The current housing need requirements of 970 dwellings per annum were based on a previous housing needs methodology which was allowed to proceed on the basis that the Local Plan 2030 was submitted and examined under the procedures of a former version of the NPPF. The late adoption of the Plan, and the reduction of the plan period from 2035 to 2030, resulted in the Inspector imposing a requirement for the Council to undertake and submit a review of the Plan for examination within three years of its adoption, (Policy 1 – Reviewing The Local Plan 2030).

It is therefore explicit that the Council needs to consider the review in the context of an elevated housing requirement as set out in the Standard Methodology, as well as consider the need for an uplift to be planned for as the Arc’s Spatial framework is prepared. The Council must therefore address this in this Review. If this is not adequately addressed throughout the earliest stages of the plan period, then there is danger that there will be a shortfall to meet demand, along with the commensurate need for affordable housing. If the Arc Spatial Framework requires a further uplift, this will again require another immediate review, we would therefore urge the Council to consider planning for longer term growth and avoid working to only the minimum requirements.

It has long been stated that there is need to deliver a step change in housing delivery, but this has never been more apparent than the comparison of the previous objectively assessed housing need, versus the need identified in the standard methodology. This uplift in housing numbers, as well as employment land provision, needs to be targeted from the point of adoption, and not, as has been implied in the text, pushed back five years via a stepped trajectory. This approach will undoubtedly compound the problem and will create a far greater burden on delivery between 2030 and 2040, it is also inconsistent with the objectives of the vision for the Arc.

Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption. Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities.