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ID sylw: 101999

Derbyniwyd: 07/03/2025

Ymatebydd: Savills (UK) Ltd

The December 2024 revised NPPF is clear that the plan-making authority must plan for a scale of growth accommodating their own local housing need as defined by the Standard Method and, where appropriate, some or all of the local housing need of the neighbouring authorities if those needs cannot be accommodated within their respective authority areas. In particular see paragraphs 24, 27, 36 and 62. If an unmet need from a neighbouring authority exists, t is a responsibility of the plan-making authority to engage through the duty to cooperate to determine where that need is to be accommodated.

The SWLP acknowledges a degree of uncertainty regarding unmet need from neighbouring authorities. The new NPPF paragraph 28 is clear that statements of common ground should be produced during the plan-making process. If there is still uncertainty at the time of the Regulation 19 production, it is therefore incumbent upon the authorities to come to an evidenced judgement and to uplift the housing land supply to reflect those needs.

We see no need to designate 'reserve sites' separately to other allocations. It would fit better with the NPPF to simply uplift the housing requirement and allocate sufficient land.