Object

Main Modifications to the Proposed Submission Core Strategy

Representation ID: 21459

Received: 27/09/2013

Respondent: Persimmon Homes South East

Agent: JB Planning Associates Ltd.

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The evidence base does not show conclusively that a higher level of development could not be accommodated or that it would not be sustainable. Development should not be restricted, as this would be contrary to the requirements of the NPPF, and the plan as drafted fails to meet housing needs.

Full text:

The premise that a higher level of development could not be accommodated within the rural area has not been proven in the updated evidence. We note in our representation on proposed modification 12.6 that the additional text which is proposed to follow Figure 12 would seek to restrict the level of development in the rural area if 'previously unidentified' sites were to come forward in advance of a site allocations DPD.

We understand that these 'previously unidentified' sites would not have been identified in the Council's latest SHLAA. We also understand that the proposed housing requirement figures for the villages, set out in the proposed replacement version of Figure 12 (proposed modification 12.5) are closely modelled on the suitable, achievable and deliverable sites the Council have identified in their SHLAA. Should additional sites be granted planning permission, they would also by definition be suitable, achievable and deliverable sites, and their presence alongside the SHLAA sites would indicate that there were more such sites in the rural area than the Council currently believe to be the case, and therefore than the capacity for development is also greater.

This would in turn imply that it would be possible to deliver a greater level of housing in the rural area than is currently anticipated, without unacceptable harm with regard to environmental factors. We support the Council's proposal for the new housing target to be a minimum figure (proposed modification 7.6). It is consistent with this principle that the Local Plan should anticipate that more development may come forward in the District as a whole, and we believe most probably in the rural area, through windfall sites. This development should not be restricted by any provisions within the plan, as to do so would be contrary to paragraph 47 of the NPPF, which requires local authorities to meet the full housing needs of the housing market area. The plan does not do this at present, and any means by which this may be achieved should not be discounted.