Comment

Representation ID: 9617

Received: 26/07/2022

Respondent: Land Allocation Ltd

Agent: AAH Planning Consultants

Since there are no exceptional circumstances identified by the Council, we support the use of the standard method to calculate the housing requirement for the Borough, since this is currently prescribed method of calculating housing need. The latest calculation sees a significant 40% increase in the Boroughs housing need, rising from 970 per annum, to 1,355 per annum. In total, 27,100 dwellings are needed between 2020 to 2040.

As per our previous representations, the Local Housing Need can fluctuate year on year when calculated using the Standard Methodology. Equally, the buffer that is required in the context of five-year housing land supply can also fluctuate. We maintain that unless the Council decide to confirm their five-year housing land supply, a 20% buffer would ensure the plan is future-proofed and provides flexibility, choice and competition in the housing market, reflecting government guidance. As per previous representations, we are not clear on what consideration has been given to an appropriate buffer.

We also cannot see that an uplift has been included to take into account economic growth. The Standard Method itself does not take into account economic growth, and we, therefore, recommend a housing requirement figure, calculated by the current calculation of the time, in this case, the Standard Method, but also takes into account the economic growth. This is of particular importance when Policy DS4(S) Amount of Housing Growth seeks for the provision of 26,700 additional jobs over the plan period. We do, however, support the allocation of specific employment sites and note that Policy DM8, New employment development in the countryside, builds on Policy 7S of the Local Plan 2030 to provide a better framework for economic growth in the rural areas, helping to maintain their vitality and viability.

Despite these positive steps, we maintain that a housing requirement uplift is necessary to support the economic growth and ambition of the plan. Therefore, we currently consider that the plan is not aspirational nor positively prepared as the target of new homes per annum (especially if using a stepped trajectory discussed further below) is insufficient to realise job-led housing needs across the plan area. In order to be found sound, the Local Plan should be targeting a higher growth within the Local Plan, incorporating an economic uplift and an appropriate buffer. Indeed, the NPPG identifies other factors which need to be considered when determining the housing requirement as detailed in previous representations, all of which suggest a higher housing need should be sought.

We reiterate the key government objection to ‘significantly boost’ housing supply and maintain that greater emphasis should be placed on the wording of Policy DS3, that 27,100 dwellings over the plan period is recognised as the minimum housing required. This key objective is highlighted in Paragraph 61 of the NPPF, and the associated NPPG guidance, is clear that the standard method represents the “…minimum number of homes needed…” and the plan must respond to the Government’s key objective of boosting the supply of housing. We continue to consider that it is important that there is flexibility in the number of housing allocations to ensure that a five-year housing land supply can be maintained over the plan period in order to meet the housing requirement and consider that the Council should be seeking to over-allocate housing land to ensure flexibility, choice and competition in the housing market reflecting government guidance.

In regards to the stepped trajectory and Policy DS3(S), Amount and timing of housing growth, we note that for the first five years (2020/21 – 2024/25), there is no increase in the provision of the number of dwellings than the current local plan (970) requires per annum. In the next five years (2025/26 – 2029/30), there is a marginal increase of 80 dwellings per annum (1,050). The last 10 years of the plan see a significant increase in the trajectory, requiring 1,700 dwellings per annum. Whilst the principle of a stepped trajectory is acceptable, we have concerns that having a stepped trajectory that is so low in the first five and ten years of the plan period, there is a high chance that the actual housing need of 1,355 dwellings per annum is unlikely to be met as the proposed trajectory is so far below the actual requirement. In turn, this could lead to a lack of five-year housing land supply, triggering the titled balance. We suggest that a more even and achievable trajectory is considered.