Proposed Submission Draft Local Plan Sustainability Appraisal

Object

Representation ID: 13631

Received: 01/05/2025

Respondent: NS Consultancy Limited

Agent: Marrons

The SA process did not test the refined options against a higher or lower housing requirement. There is a clear and compelling case to test a higher housing requirement not only because of recent housing delivery trends but because of the wider issue of an HMA-wide shortfall over the plan period beyond 2036. A higher growth figure could at least potentially provide sufficient headroom to respond to this longer-term strategic challenge and this has not been addressed given that alternative scales of growth were not tested beyond the initial spatial options.
The overall quantity of growth has not been adequately tested through the SA process and therefore the housing requirement lacks justification.