BASE HEADER

PARAGRAPH 4.10 LEVEL OF HOUSING GROWTH
1.1 These submissions relate to the proposed level of housing provision to be accommodated within the District's most sustainable village locations.
1.2 The Council acknowledge at paragraph 2.13 of its consultation report that its interim level of growth of 683 dwellings per annum set out within the Revised Development Strategy (June 2013) may be revised pending the findings of the Joint Strategic Housing Market Assessment (SHMA). This SHMA has now been published and, whilst its findings have yet to be tested, it concludes that the assessed housing need for the District is 720 dwellings per annum.
1.3 Over a plan period to 2031, the interim level of growth is therefore some 740 dwellings less than the most up-to-date evidence of assessed need. The SHMA also provides up-to-date evidence as to affordability, the numbers of newly forming households in need of affordable housing, as well as market signals.
1.4 The Council will therefore need to reconsider its future housing requirement figure in light of this evidence and the possible need to accommodate housing requirements from other authorities under the Duty to Co-operate. Furthermore, it will also need to test the implications of higher housing figures than that indicated in the Revised Development Strategy, and reconsider the level of growth proposed for the most sustainable villages. Bloor Homes have made submissions to the Council previously as to the need and potential for the rural area to accommodate higher levels of growth than envisaged within the Revised Development Strategy.
1.5 In this context, it is of concern that the Preferred Options set out within this consultation report have failed to even achieve the housing provisions made to the most sustainable villages (1,000 dwellings in total) as part of the interim level of growth within the Revised Development Strategy. The statement within paragraph 4.10 of this consultation report that the lower figure now proposed of 835 dwellings reflects environmental and access restrictions will need to be robustly demonstrated if this is to be taken forward into the Draft Local Plan and found 'sound'.
1.6 The Council will be aware of the relevant test within paragraph 14 of the National Planning Policy Framework (referred to as the 'Framework'). This requires that objectively assessed needs are met unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies of the Framework taken as a whole.
1.7 In respect of its land interests not allocated as Preferred Options, Bloor Homes do not consider the Council has demonstrated within its evidence base that the adverse impacts of their development would significantly and demonstrably outweigh the benefits. Moreover, having regard to paragraphs 17 and 70 of the Framework and the requirement to allocate land of lesser environmental or amenity value where consistent with other policies of the Framework, Bloor Homes do not consider the Preferred Options identified in some of the villages represent the most appropriate when assessed against their alternative land interests which are more consistent with the policies of the Framework. The evidence to support these statements is set out in within separate submissions.