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ID sylw: 101983

Derbyniwyd: 07/03/2025

Ymatebydd: Savills (UK) Ltd

Draft Policy Direction 1 still makes reference to the HEDNA. This may be relevant to the economic requirement but NPPF Paragraph 62 is clear that the Standard method must be used as the basis for calculating housing requirements. All references to the HEDNA should be removed from sections applying to the proposed housing requirement. The policy should also be changed to make it clear that the 54,700 dwellings to be planned for through the SWLP is a minimum rather than an "up to" figure. This is essential to comply with Paragraph 62 as well as 36(a) and 36(d) of the NPPF.

Table 3 lists sources of housing supply and a residual "to-find" figure to be delivered through new allocations. It isn't clear whether this represents all sites with a permission or a 'discount' has been applied for non-delivery. There is also an assumption of 375 dwellings on windfall sites. The supporting text should explain the evidence these numbers have been derived from. The only relevant evidence on the website is the Urban Capacity Study which has a figure of 19,950 dwellings rather than the 26,443. It is difficult to judge the soundness of the emerging SWLP without this information.