Object

Representation ID: 9985

Received: 27/07/2022

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy is unsound as it not consistent with the requirements of national policy
13. As mentioned above the Council’s assessment of housing needs, which is set out in DS3, is consistent with the approach set out in Planning Practice Guidance and results in a minimum housing need across the plan period of 27,100 homes. However, on the basis of the necessary adjustments to land supply the local plan is unsound as it will not meet those needs in full.
14. Within this policy the Council are proposing that a stepped requirement is adopted on the basis that the infrastructure necessary to deliver the spatial strategy will not be in place until later in the plan period. PPG is clear in paragraph 68-021 that stepped trajectories may be required where strategic sites have phased delivery or will be delivered later in the plan period. This would appear to be the case for the spatial strategy being proposed.
15. However, even with the proposed stepped requirement it appears from the Councill’s estimates of supply that they will not a five-year housing land supply on adoption, or indeed across the majority of the plan period. Our estimates of the five-year land supply are set out the rolling trajectory in appendix 1. This assessment uses the Council’s proposed approach to shortfalls and applies it to surpluses which we have assumed as being delivered across the remaining plan period. There is an argument that surplus should be ignored but given that national policy is silent on these matters we have taken a proportionate approach. Using this approach, it would appear that if the Council were to adopt this local plan in 2023/24 there will be land supply of 4.84 years. Looking beyond adoption it is also notable that on the basis of their estimates the Council would not have a five-year land supply until 2033/34.
16. One approach to this situation would be to amend the trajectory to engineer a five-year land supply on adoption. However, PPG is clear at paragraph 68-021 that strategic policy makers should “… not seek to unnecessarily delay meeting identified development needs” and as such the only appropriate response is to allocate smaller sites that will come forward earlier in the plan period. Indeed, such a response would also be consistent with addressing our concern above with regard to the over estimates of supply on the two largest strategic allocations and the Council’s failure to identify sufficient small sites to meet the requirements of paragraph 69 of the NPPF.