Object

Representation ID: 22369

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

Part 1 of Policy CSP1 – Development Strategy states that it will deliver sustainable economic and housing growth and ‘to meet strategic planning targets’ by, inter alia, delivering at least 47,837 net new homes and at least 355 hectares of employment land. The figures quoted in the policy appear to represent the BCP’s housing and employment needs for the Plan period, but this is not the case.

Whilst RSL appreciate why these figures have been included in Policy CSP1, we consider this could well mislead some readers as the actual levels of housing and employment needs required within the area during the Plan period are much higher. Whilst Table 2 that follows Policy CSP1 provides a summary of the distribution of growth, detailing a ‘Grand Total’ of 76,076 homes and 565 hectares of employment land, there is no explanation that these figures are the levels of housing and employment needed within the BCP area during the Plan period. It is not until the Duty to Co-operate section (paragraph 3.20 onwards) that some clarification is provided that the figures used within Policy CSP1 represent only 63% of both its housing and employment needs, leaving significant shortfalls of 28,239 homes and 210 hectares of employment land. The actual levels of housing and employment need are each then only referred to one further time within a Plan extending to 727 pages. As one of the most important strategic planning issues to be covered within the BCP, the challenges and implications in not meeting in full the area’s future housing and economic growth aspirations should be given greater coverage.

RSL consider that the BCP would therefore benefit from a clearer explanation earlier in the document in order for all to fully appreciate the circumstances within which the future development needs of the area are being addressed. This should set out more specifically the challenges of meeting the full housing and employment needs within the Plan area, the implications of this under the Duty to Co-operate and the risks if all of the identified shortfall cannot be accommodated by neighbouring authorities in terms of the legal compliance of the BCP.