Object
Publication
Representation ID: 24059
Received: 18/03/2021
Respondent: RG Carter & Drayton Farms Limited
Number of people: 2
Agent: CODE Development Planners Ltd
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Not effective
A plan preparation uninformed by the anticipated rate of development for specific sites and instead based on an average of past delivery rates on different sites with entirely different issues at a different time with different economic and social circumstances is likely to be unsound and is certainly not transparent and tested for its ability to deliver sufficient houses within the plan period. In our view, this is particularly important where a plan such the GNLP seeks to supply a large number of homes on large scale development formats. As stated in paragraph 72 of the Framework, in identifying large scale development, authorities should "make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites...."
cc See seperate attached representation document (Reg19)
In view of the concerns and to ensure that the plan is effective and sound under this test we recommend
that:
a) evidence should be produced to define, explain and allow proper testing of the anticipated delivery rates of all committed and allocated sites. This would be in accordance with advice contained in paragraph 72 of the Framework.
b) Additional medium sized site allocations should be identified in order to reduce the over-reliance
of the plan's supply of housing on large-scale development sites. This would be in accordance
with advice contained in paragraph 68 of the Framework which confirms how small and medium
sized sites can make an important contribution to meeting the housing requirement of an area.
c) Additional contingency sites should be identified to provide greater assurance that additional
allocations could be made and delivered quickly if housing delivery in the plan area fell short of
expectation. As with additional allocations referred to in b) above additional contingency sites
should include small and medium sized sites sufficient to make a material impact on delivery and
capable of quick delivery and build-out.
d) Alternatively, other contingency sites should be identified to replace the Costessey contingency
site referred to in Policy GNLP0581/2043. The site is not considered to be justified and suitable
for development and, in any event, is unlikely to be delivered quickly given the substantial
necessary and in some cases uncertain improvements and mitigation
I attach representation to GNLP Reg 19 submitted on behalf or Drayton Farms Limited and RG Carter Farms Limited.