Comment ID 1152
Document Section Proposed Submission Local Plan 2006-2028 Settlement Strategy Scale of Growth for the District and the Main Settlements Housing Policy SS4: District Wide Housing Provision View all on this section
Respondent Perrin Construction Ltd View all by this respondent
Agent Bell Cornwell (J Terry)
Response Date 10 Aug 2012
Do you consider the DPD is Legally Compliant? No
Do you consider the DPD is Sound? No
If you have responded that the DPD is unsound, Do you consider the DPD is unsound because it is:
  • Not Justified

Objection on the basis that the scale of housing growth within the District has been reduced. This is a reduction on the Proposed South West RSS requirement based on further local evidence; and reduced again, being linked to employment growth which is reduced due to the current economic climate.

  • No reference is made to the most recent population projections just released.
  • No account has been taken of cross boundary issues and how to deal with the implications of potential under provision arising from either SSDC on surrounding Districts or arising from surrounding Districts on SSDC.
  • Housing need should be taken from household and population projections rather than employment growth. Linkage to employment growth is neither appropriate nor desirable. Employment growth has been significantly impacted upon by the current economic climate but employment growth is not the sole determining factor in generating a need for housing. Such an approach also does not take any account of the changing nature of employment provision with a greater proportion of people working from home.

The scale of housing growth is not justified and the policy will not be effective. It does not comply with the requirements of the NPPF (para. 157) to cooperate with neighbouring authorities.

Objection is also made in that the NPPF requires (para. 47) an additional 5% buffer to the 50year housing land supply in order to ensure chose and competition in the market. The housing trajectory should be revised to reflect this.

What changes do you suggest to make the DPD legally compliant or sound? The Proposed RSS housing requirement of 21,670 between 2006 – 2026 should be reinstated.

The Housing Trajectory to be amended to reflect the need for an additional 5% buffer to the housing land supply.
If your representation is seeking a change, do you consider it necessary to participate at the oral part of the examination? Yes
If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: To enable adequate discussion to take place on this central issue.