Deeley Group objects to Policy DS7 and the associated table for the reasons set out in it objections to Policy DS6, i.e. that the period used for housing provision should extend to 2031. In accordance with that objection the overall housing target should be increased by at least 1,428 dwellings.

Furthermore, Deeley Group objects to the Table in Policy DS7 as it is considered that it makes an over estimate of the likely delivery from windfalls during the plan period. Given that there is already separate provision allowed from small urban sites (which are by definition also windfalls as they are not allocated), and given insufficient evidence base to justify the levels proposed, it is considered that the windfall allowance is not robust.

Accordingly, the amount of housing to be allocated on new sites within the plan should be increased from 6,238 to at least 8,000 both in order to meet the shortfall from the missing 2 year period to 2031 and also to allow for a lower delivery from windfalls.