Table 3 - Estimated Housing Delivery for 2014-2031 Excluding Current Permissions as at 1st April 2014
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5346
Received: 05/03/2015
Respondent: Kesgrave Covenant Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Based upon the sources of supply set out in Table 3, policy CS7 states that 5,434 new homes will be allocated for development through the Site Allocations Plan, the Plan is failing to deliver enough land for housing, and needs to achieve the maximum delivery possible from the existing suitable sites within the Borough boundary.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5547
Received: 02/03/2015
Respondent: Home Builders Federation Ltd (HBF)
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Council expects a total of 1,800 dwellings to materialise in the form of windfall development over the plan period with 90% of these being on brownfield land (see also paragraph 48 of the Housing Topic Paper). This is a quite a substantial figure and it would be helpful if the Council provided some evidence to justify its assumption
Past windfall delivery: what is the evidence for this?
Table 3 on pages 29 and 30 of the plan show that some 1,800 dwellings are expected from windfall sites. (900 are expected from small windfall sites over the plan period 2015-2031. A further 900 windfalls are expected on large sites for the period 2020-2031. The Council expects a total of 1,800 dwellings to materialise in the form of windfall development over the plan period with 90% of these being on brownfield land (see also paragraph 48 of the Housing Topic Paper). This is a quite a substantial figure and it would be helpful if the Council provided some evidence to justify its assumption that windfalls of this number will come forward based upon past records. We note the contents of paragraph 9.90 of the plan and its reference to the historic contribution of small sites and backland plots to maintaining housing supply but we would query the extent to which the Council can continue to rely upon this source.