COMMENT.

Table 7.1 sets out the details of the number of dwellings which the Council believes need to be allocated in the plan once committed housing sites (1,224), small urban SHLAA sites (290) and other windfall housing sites (2,300) have been subtracted from the overall District housing provision figure 10,800 (2011 to 2029). On reading the SHLAA we understand that the Council has assumed that all existing housing commitments will come forward and, along with newly emerging windfall sites, will provide the housing supply over the next 3 to 5 years. However, given the volatile state of the housing market in recent years and, amongst other things, the reduced likelihood of public funding being available for infrastructure, we feel the that the Council's assumption that 'suitability' equates to 'deliverability' is overly simplistic. Furthermore, we believe that the SHLAA should not have assumed that all existing housing commitments will come forward in the first phase of the plan.

In accordance with best practice, the housing trajectory and the five-year supply of specific deliverable sites in the SHLAA should be based on whether:
* sites with planning permission are now under-construction and what progress has been made;
* planning applications have been submitted or approved on sites and broad locations identified by the Assessment;
* progress has been made in removing constraints on development and whether a site is now considered to be deliverable or developable; and
* unforeseen constraints have emerged which now mean a site is no longer deliverable or developable, and how these could be addressed.

It follows that as part of the SHLAA all commitments should have been assessed as to when and whether they are likely to be developed and phased accordingly. More specifically with regards meeting the 5 year housing land supply requirement, sites should be completely removed from said supply if new evidence questions their 'availability' or 'achievability'. In the absence of such an assessment we consider that it would be appropriate to apply a 10% reduction to the amount of dwellings expected to come forward from existing commitments to reflect the likelihood that not all planning permissions will be implemented.

A 10% reduction in the stated overall number of committed housing sites would be 122 dwellings. Table 7.1 should be adjusted accordingly with the 'balance to be allocated in the plan' increased from 6,986 to 7,108 dwellings