Comment

Representation ID: 44793

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

Considering the type and size of housing likely to be delivered

4.24 The NPPF requires planning polices to reflect the size, type and tenure of housing needed, and the BCHMA – as summarised in section 2 – identifies a prevailing need for larger homes that could require two thirds of all new homes over the plan period to be houses.

4.25 From review of the Councils’ evidence base supporting the Draft BCP, it is unclear if any assessment of the proposed sources of housing supply has been undertaken to ascertain whether this prevailing need for houses will be met. Draft Policy HOU2 (‘Housing Density, Type and Accessibility’) sets out generic requirements, stating that density and type of new housing provided on any site should be informed by the need for a range of types and sizes to accommodate local needs.

4.26 The Councils’ forward housing supply is heavily distorted and relies on previously developed land, with circa 85% of all supply coming from non-greenfield sources. This is reflected in draft Policy HOU2 which drives higher densities when certain criteria are met and the site is located within a Strategic Centre or Town Centre. The densities in draft Policy HOU2 are also increased from the previous policy context, with justification included in Section 2 of the Urban Capacity Study.

4.27 Given the Councils’ forward supply is so reliant on non-greenfield sources, where traditionally certain types and sizes of housing are more readily delivered due to factors such as viability and density, the Councils should closely consider whether the Draft BCP is clear or justified in the approach to supplying the size, type and tenure of housing needed, and what modifications should be made if it comes to light that the BCP is not meeting needs.