8. Overview
Object
Proposed Submission Development and Site Allocations (DaSA) Local Plan
Representation ID: 24419
Received: 06/12/2018
Respondent: Gladman Developments
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Chapter 8 identifies a residual need of 1,574 dwellings to come forward through the DaSA and Neighbourhood Plans. The DaSA confirms allocations for 1,562 dwellings, there is therefore a shortfall against the total requirement.
The plan is silent on the status of neighbourhood plans in Rother and whether it is realistic that these will allocate the level of housing envisaged and make up the difference in units aspired to hit the 5,700 unit total. There is less than 10 years of plan life left to achieve this figure and the Council does not seem to be building in any flexibility for sites not coming forward as envisaged or being delayed. The reliance on neighbourhood plans to deliver the balance of development and what would in effect be a buffer to ensure overall plan levels of development are delivered is not sound.
It is likely the plan will fail to deliver its housing needs over the plan period due to the lack of flexibility in site options to meet the overall figure. We would envisage that a flexibility buffer of at least 10% in allocations over requirement is necessary to give some comfort that the overall plan target will be delivered.
Gladman do not wish to comment specifically on any of the individual allocations at this time, however we would comment on the overall level of housing supply within the plan. Paragraphs 8.1-8.18 set the context for the levels of development which have been achieved so far and the commitments that are made, a residual
need of 1,574 dwellings to come forward through the Site Allocations DPD and Neighbourhood Plans is identified. The Site Allocations DPD confirms allocations for 1,562 dwellings in Figure 18, there is therefore a shortfall against the total requirement.
The plan is silent on the status of neighbourhood plans in Rother and whether or not it is realistic that the forthcoming neighbourhood plans will allocate the level of housing envisaged in Figure 18 and make up the difference in units aspired to hit the 5,700 unit total. What must also be remembered is that whilst the target
may be 5,700 units to be delivered, there is less than 10 years of plan life left to achieve this figure and the Council does not seem to be building any flexibility into the plan for sites not coming forward as envisaged or being delayed. The reliance on neighbourhood plans to deliver the balance of development and what would
in effect be a buffer to ensure overall plan levels of development are delivered is not sound.
Gladman consider it likely the plan will fail to deliver its housing needs over the plan period due to the lack of flexibility in site options to meet the overall figure. We would envisage that a flexibility buffer of at least 10% in allocations over requirement is necessary to give some comfort that the overall plan target will be delivered.
As a leading land promoter Gladman would welcome the opportunity to further discuss the content of this representation at the examination into the soundness of the Site Allocations DPD.