BASE HEADER

No

ID sylw: 105917

Derbyniwyd: 06/03/2025

Ymatebydd: Sworders

Asiant : Sworders

In terms of housing delivery, we believe Draft Policy Direction 1 is too broad and lacks precision. It should be more certain of providing the number of homes required under the new standard method.
The wording of Draft Policy 1 must be amended such that the Local Plan will make provision for the delivery of at least 2,188 dwellings per annum not 1,679. The use of the HEDNA figures is not in accordance with Paras 36(a) and 62 of the NPPF which detail that “strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance.” The current wording has not been positively prepared and is not considered to be sound
in accordance with Para 36(a).
We would question the assumed Windfall allowance over the plan period. This suggests 17% of housing need will come from windfall sites which is very excessive.
Regard should be taken to how the delivery of new settlements provides a more sustainable community and economy with the provision of new infrastructure, schools and amenities being included as part of such developments.
Under the new method the shortfall in delivery will then be carried forward into the next five-year period. Without the allocation of new settlements, the housing and employment land provision will risk being in deficit for a significant part of the plan period,
as such we would like to emphasise our client’s land’s availability, suitability and deliverability to deliver the significant housing numbers required by the new methodology which should be used