Object

Representation ID: 44810

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

Conclusion on Existing Allocations
5.37 This source of supply (Existing Allocations in Strategic Centres not subject to review through the BCP) is relied on to deliver 4,973 homes between 2020 and 2039. The Councils claim that the application of a 15% discount rate to these sites is adequate to account for non-implementation.

5.38 There is significant doubt that the sites making up this source of supply are either deliverable or developable.

5.39 The sites are included in documents prepared in the context of the BCCS, and some are more than ten years old. There is a clear record of delivery issues with these allocations, with many of the Strategic Centre AAPs delivering significantly less than was originally anticipated.

5.40 They should not be relied on in the Draft BCP without investigation of site specific evidence through which it can be demonstrated that the sites are deliverable and developable, and thereby passing the NPPF tests. If site specific evidence is available to suggest the sites are deliverable or developable (which we do consider may exist for some sites), then they should be re-allocated through the Draft BCP, and fall into another source of the Councils’ supply.

5.41 We propose that beyond that no reliance should be placed on sites that have previously been allocated but have not come forward. If the allocations had come forward as planned, they would presumably be now counted as commitments

5.42 Furthermore, the Council’s own Viability and Delivery Study concludes that existing allocations in Strategic Centres are unviable.

5.43 As a result, without the necessary evidence base, it is necessary to remove the 4,973 homes, being the total quantum of homes relied on from this source in the plan period. It is nonetheless considered that some of this number could be offset through appropriate re-allocation, or identification of a specific existing allocation where up to date evidence is provided to confirm there is a reasonable prospect that they will be available and could be viably developed at the point envisaged.

5.44 Continued reliance on existing allocations where there is no realistic prospect they will come forward carries a risk of further compounding the pattern of delivery failure.