Comment

Representation ID: 21291

Received: 11/10/2021

Respondent: Owl Homes

Agent: Barton Willmore

Draft Policy HOU2 – Housing Density, Type and Accessibility

Draft Policy HOU2 seeks to locate new homes in places with good sustainable transport access to key residential services and provide a mix of housing types and densities which are appropriate to their location and to help meet local needs.

The principle of optimising the density of development in locations that are well served by public transport is supported and considered to be consistent with national policy (NPPF, paragraphs 125 and 141). However, it is considered that the wording of the policy should be amended so that section (4) of the policy only applies on Sites not allocated for housing within Chapter 13. Chapter 13 identifies the site allocations for each of the BCA areas and provides details of what it considers to be an appropriate density for each site. This is based on an assessment of each of the sites undertaken in the ‘Sites Assessed for Housing’ report, that includes a range of considerations including local context and individual site constraints. As such, this is considered to be a more robust density standard which aligns with paragraph 124 of the NPPF and the NPPG on achieving appropriate densities (see ‘Effective use of land’ Paragraph 004 Reference ID: 66-004-20190722). For example, in the case of this Site, part 4c) of Policy HOU2 would apply, which would set a minimum net density of 40 dwellings per hectare for the Site. However, the draft site allocation in Chapter 13 estimates an appropriate capacity of 35dph, given that the Sites Assessed for Housing report had identified a very low character density of 17dph in the local area.