Object

Representation ID: 56646

Received: 29/07/2013

Respondent: A C Lloyd Homes Ltd and Northern Trust

Agent: Framptons

Section 4.1 of the Revised development Strategy (RDS) correctly confirms the fact that the level of housing growth is an interim figure and that this may alter as a result of the findings of the Joint SHMA and the resulting co-operation between the authorities.

Against this background it is considered that the statement at the end of paragraph 1.3 of the RDS is untenable, which states, "the Council believes that the evidence base which underpins the RDS is robust and the housing growth requirements are unlikely to change substantially as a result of the new assessment".

There is no evidence to indicate that the Council's position as expressed at the end of paragraph 1.3 of the RDS is robust. It should be deleted.

Windfall Allowance

It is considered that the windfall allowance is excessive and unjustified. It seems to ignore the evidence from the SHLAA (which provides for 300 dwellings on small urban sites) and assumes an unrealistically high level of windfall sites for the plan period. The Council's evidence is based on a subjective manipulation of past trends rather than any considered examination of the evidence that may exist in terms of the potential capacity of the urban areas to accommodate such a high level of windfall moving forward. Accordingly, in the absence of a clear and robust evidence base from the Council the proposed windfall allowance is rejected.

Further consultation

It is apparent that the publication of the joint SHMA in early 2014 will be an important factor in determining the final format of the Local Plan. As such, it is submitted that the Council should consider a further round of consultation on the output of the SHMA prior to going forward to publish a Submission Draft Plan.