Comment

Representation ID: 22374

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

Policy HOU2 – Housing Density, Type and Accessibility details the approach to a range of matters including housing density. Whilst RSL fully support the objective of making the most efficient use of land, we consider some clarity is required regarding the densities expected to be achieved on allocated sites. Part (1) of the policy correctly identifies the 3 key factors that should inform an appropriate density for an individual site, taking account of the need to provide a range of house types and sizes, the site’s level of accessibility to sustainable transport; and the need to achieve high-quality design and minimize amenity impacts. Part (4) of the policy then sets out 3 density ranges depending on accessibility standards as detailed at Table 5, which are applicable to all developments of 10 dwellings or more. Part (5) of the policy then refers to Chapter 13 of the BCP which details the appropriate density to be sought on each housing allocation site.

RSL consider Parts (4) and (5) appear to therefore contradict each other. Chapter 13 comprises detailed guidance for each allocated site and provides an assumption of the appropriate density, presumably informed by the specific circumstances relevant to the site, which must have taken account of the 3 key factors detailed at Part (1) of the policy. It is notable that some of the proposed allocations are for densities below 40dph, the lowest of the 3 density ranges at Part (4) of the policy. RSL therefore consider that this contradiction should be rectified to ensure appropriate minimum net densities are clear for each site.