Object

Representation ID: 66057

Received: 27/06/2014

Respondent: Lenco Investments

Agent: RPS Planning & Development

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Council has failed to identify an objective assessment of objectively assessed need for housing. The current proposal is deficient and therefore unjustified and thus unsound.

RPS expect the authority's housing need to be based upon the Government's latest demographic evidence with close scrutiny of their relevance for future planning, and any adjustments made to them being fully justified.

The Council has used the 2011 Interim Population and Household Projections to inform it's housing figures, however these projections only extend until 2021, whereas the Council's SHMA seeks to extend these over the period 2011 to 2031.

It is understood that the SHMA undertook two sensitivity tests. With regard to scenario PROJ1A - 2008 Headship RPS concurs that the use of the 2008 headship rate over the entire plan period in this sensitivity test is likely to be unrealistic.

The second sensitivity test PROJ1A - Midpoint Headship seeks to apply a hybrid of the 2011 headship rate data to 2021 and then 2008 rates post this to 2031. RPS concur that this is an appropriate scenario to apply within the SHMA, however RPS objects to the manner in which this sensitivity test is applied.