Object
Publication Draft
Representation ID: 66231
Received: 24/06/2014
Respondent: Crest Strategic Projects
Agent: d2planning
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
The objections to this policy should be read in conjunction with our objection to Policy DS6 'Level of Housing Growth'. The objection to Policy DS6 was on the basis that insufficient housing provision had been made to meet the housing needs of the District including adjoining districts. It must therefore follow that objections are made to this policy on the basis that the overall housing provision is too low. Furthermore, in meeting the housing requirement calculation it is important that the advice both in the NPPF and NPPG in respect of identifying the availability and deliverability of sites is followed. Whilst we reserve the right to comment on the detail of the calculation it is apparent that:
1. No allowance for the shortfall in housing provision pre 2011 is made;
2. The windfall allowance is excessive and not justified;
3. Potential double counting exists between windfall sites and small urban sites; and
4. Ensure that allocated sites are available and deliverable.
see attached