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Representation 6016 on BMSDC Joint Local Plan Consultation Document (Interactive) by Endurance Estates represented by Savills (Mr Paul Rowland)

Support / Object: OBJECT
Document Link: BMSDC Joint Local Plan Consultation Document (Interactive) - HOUSING, Housing Requirement, Q7
Representation: There is no robust assessment of reasons for historic under-delivery or explanation how this will be addressed. Higher target should not be ruled out simply because 'challenging'. Market evidence is smaller rural sites deliver faster.
No evidence that contingency sites will urgently speed up delivery. More deliverable rural sites should be introduced now. Likelihood of higher OAN figures from Government support this approach.
Complies with the duty to Co-operate?Yes

Original submission

At page 20 of the consultation document under the heading "Housing requirement", the plan addresses the question of deliverability but it fails to identify the reasons why there has been poor delivery or to set out an approach to tackle these reasons. One option would be to publish a higher housing target and allocate additional sites on which this could take place. This option seems to be dismissed by the Councils at the outset on the basis simply that 'exceeding OAN could prove challenging'. Elsewhere the document identifies that 60% of the houses built have been in the rural parts of the district. This suggests that the market favours the rural areas and house builders can deliver better on rural sites.
In our view additional sites should be allocated immediately to improve the potential for an increase in the volume of housing delivery. Allocation of additional sites would improve market certainty about the commitment of the Councils and allow investment decisions by a wider range of investors and builders. There should be greater priority to allocation of deliverable rural sites.
At page 22 the Councils report that delivery in recent years has been below the levels needed to meet OAN. They suggest (at Option HD1) that additional sites be identified as 'contingency sites' where delivery targets are not being met. However there is nothing to suggest why previously low delivery rates will change with the publication of a new plan. It is more reasonable to anticipate that delivery will continue as in recent years and the presence of contingency sites will tend to introduce uncertainty rather than confidence in the market. It would be sensible to adopt an approach that releases more land immediately.
In our view the Councils have failed to address this issue sufficiently robustly and more sites should be released at the start of the plan period.
The Councils suggest that Option HR1 is appropriate because there is no evidence to suggest that the housing requirement should be set at any other level. In fact this ignores the recent under-delivery of houses (as accepted by the Councils) and the need to accelerate delivery. We suggest further capacity, in the form of additional allocations, on readily available rural area sites should be introduced at the start of the plan period and not as reserve or contingency sites. The additional capacity should be in proportion to the degree of under-delivery previously. The NPPF expects sites to be 'deliverable' and the record of development of previously planned sites shows that these are not fulfilling the requirement. More sites would therefore need to be allocated to fulfil deliverability.

The context of such comments relate to the Government's recent publication of "Planning for the right homes in the right places: consultation proposals" which published an new indicative OAN for each English local planning authority. In the case of both Mid Suffolk and Babergh, the published indicative OAN is higher than the figure used in this consultation document. Whilst we appreciate that such a new figure may only be applicable dependant upon the submission date of the Plan (ie by end of March 2018), these increased figures reflect Government concerns that Councils such as Mid Suffolk and Babergh need to increase their housing figures over the plan period.. Such an approach at this stage of the Plan would be entirely appropriate.

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