Comment

Representation ID: 21619

Received: 11/01/2022

Respondent: Pall Mall Investments

Agent: Highgate Land and Development

Policy HOU2: ‘Housing Density, Type and Accessibility’
Draft Policy HOU2 states that: ‘all developments of ten homes or more should achieve the minimum net densities’.
For non-strategic centre or town centre sites, minimum densities of 40 to 45 dwellings per hectare are sought by draft Policy HOU2.
First, it is not clear whether the densities apply to the gross area or the net developable area.
In our experience, there can be significant differences between the gross land area and the net developable area achievable. Hence, draft Policy HOU2 should be updated to ensure that these densities apply to the net land areas in the policy (to ensure that the densities targeted are achievable).
In addition, the ability to achieve the 45 dwelling per hectare minimum density in particular will depend upon a range of site-specific factors, such as the ability to deliver a higher amount of apartments typically in the order of approximately 20% of the overall residential
development mix. Clearly, this requirement will need to be balanced with a range of other policy density and mix requirements, as well as both market demand and need, as well as site specific constraints, throughout the BCAs.
Therefore, draft Policy HOU2 should be updated to ensure that these proposed densities should be expressed as a ‘target’ rather than ‘minimum’ density requirements.