Object

Representation ID: 56440

Received: 29/08/2013

Respondent: Bloor Homes

Agent: Marrons Planning

These submissions relate to the proposals for meeting the housing requirement referred to in Policy RDS1. This proposal will need to be reviewed by the Council following the proper assessment of the housing requirement for the District. However, the following comments are made on the basis of the proposal at this stage. The proposal contains a heavy reliance (23%) on sites not identified or to be allocated within the final plan (i.e. windfalls), and it is questioned whether such an approach is consistent with the Framework in requiring the Council to demonstrate it is planning positively to meet the development requirements of the area.

Moreover, the evidence base to support the assumptions about windfall rates does not justify the level of growth indicated as it is primarily informed by past trends in a stronger economic climate and a far more relaxed planning policy context towards windfalls.

By way of example, on the basis of the evidence put forward in the GL Hearn Employment Land Review Update 2013, the vast majority of employment sites will be protected by the Council for such uses in the future and therefore rates of redevelopment of large sites for residential development are not likely to return to previous levels seen prior to 2007 and the adoption of the current Local Plan Policy SC2. If the Council are to rely on such levels of windfalls delivering the housing growth it requires to meet its needs in its draft Plan, it will need to demonstrate that the other policies of its Plan are framed in such a way as to enable such proposals to come forward.