Draft Policy DS7 sets out the various categories from which the overall housing requirement will be delivered. In general terms, given our comments above in respect of the overall housing requirement, there will be a need to identify additional sites for development.

More specifically, we note that the breakdown includes sites with planning permission at 1st April 2013 and sites with planning permission granted between 1st April 2013 and 31st December 2013. It is not clear from the supporting text, and we would therefore query, whether any discount has been applied to this figure or whether there is an assumption that all of the sites with planning permission will be delivered in full within the plan period. It would be normal practice to apply a 10% reduction to committed sites for non-implementation and to ensure robustness.


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We also note that there is a substantial allowance for deliveries from windfalls, small urban sites assessed in the SHLAA and a consolidation of existing employment areas. It is not clear whether there is any 'double-counting' of sites and we would query the robustness of including a windfall allowance if allowances are being included for small SHLAA sites and the consolidation of existing employment sites, given that these categories are likely to make up a large proportion of what would normally be regarded as windfall sites.

In this respect, we are concerned that the Plan may not be effective in that it does not ensure the delivery of the housing requirement within the Plan period.