Object

Representation ID: 5106

Received: 16/03/2023

Respondent: Seaward Properties Ltd

Agent: Smith Simmons Partners

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The identified housing need has been informed by the 2022 Housing and Economic Development Needs Assessment (HEDNA). It explains that based on the standard methodology, since the last HEDNA in 2020, the district wide housing need has increased from 746 dpa to 763 dpa (621 dpa in the Plan Area to 638 dpa) with the balance to be found in the national park. The proposed 638 dpa for the area of the district outside the national park is the figure that will be tested at the forthcoming Examination.
We have already explained why the failure of the Council to plan for the 638 dpa in the Regulation 19 Local Plan has not been justified in connection with the duty to cooperate and no evidence has been presented in any statement of common ground with neighbouring authorities to show how development needs could be met elsewhere.
We note from policy H1 that the housing supply includes existing housing commitments from the 2015 adopted Local Plan, the Site Allocations DPD, and ‘made’ Neighbourhood Pans all without planning permission. It also includes planning permission for schemes of over 4 dwellings granted consent as of 1 January 2023.
However it is unclear how the supply from these categories of development have translated into the strategic and non-strategic allocations in policies H2 and H3.
For instance, has it informed the strategic allocations of 300 dwellings to Chidham and Hambrook in policy A12 and the 220 dwellings at Loxwood in policy A15? Have the categories of supply as commitments at each settlement been ring fenced to count against the new proposed allocation? We would welcome further lower case policy clarification to confirm that the allocations are fixed, and no further adjustments will be made to the figures.