Proposed Modifications to the Thanet Local Plan

Document Section Main Modifications Chapter 3 - Housing strategy MM/026 MM/026 [View all comments on this section]
Comment ID 191
Respondent N/A - Tesco Stores Limited [View all comments by this respondent]
Agent Mark Buxton - RPS
Response Date 27 Jan 2020

See attached file

Policy SP11 (MM/025, MM/026, MM/027 and MM/30)

The reference to ‘at least’ 17,140 additional homes over the plan period to 2031 is welcomed in the context of the NPPF 2012 (paragraph 47) requirement to boost significantly the supply of housing.

We are however concerned that the proposed ‘stepped trajectory’ is incompatible with this aim and also the emphasis on ensuring there is a supply of specific deliverable sites sufficient to provide five years worth of housing with an additional buffer (in this instance 20%). The PPG advises that “Where strategic policy-making authorities are unable to address past shortfalls over a 5 year period due to their scale, they may need to reconsider their approach to bringing land forward and the assumptions which they make.”

It remains our contention that there is an over-emphasis on large strategic allocations, many of which seek to serve the same local housing market area which will impact speed of delivery of housing in the district. Indeed, it is noteworthy that part of the Council’s justification (in CD 9.30) for addressing the substantial housing shortfall (651 units) over a longer period is that there are “infrastructure requirements associated with strategic sites” (paragraph 3.3).

It is not clear where the figures contained within Table 3 (MM/030) are derived from. They do not tally with CD9.30. For example the ‘Note for the Inspector on Updated 5 Year Land Supply (June 2019)’ identified a total supply in Table 5 of 7,015 dwellings whereas Table 3 in the MMs calculates the Total allocations supply at 8,691 dwellings. As an aside, there are no totals provided in the trajectory within Appendix B.

It is also not at all clear within the MMs what the Council’s claimed 5 Year Housing Land Supply is. We contend this is a glaring omission and goes to the soundness of the Plan.

Furthermore, we continue to consider that Table 3 is over reliant on Windfall Sites which are proposed to deliver 225 units per year across the plan period (2011-2031).

We consider it would be more appropriate, under a plan-led system (as advocated by the NPPF), for the Council to identify and allocate additional smaller sites which are less reliant on delivery of key infrastructure rather than relying on windfalls. Under an effective plan-led system the level of windfalls should diminish over time.

We therefore continue to question whether it is realistic for this level of windfalls to be delivered year on year across the Plan period. Evidence of previous levels of windfall should not automatically be deemed “compelling evidence” (as required in paragraph 48 of the NPPF 2012) or a reliable indicator of future trends.

Approximately 26% of the total 857 dwellings required each year would be provided by windfall sites. We consider this represents an over-dependence on windfall sites being brought forward for development and the Council should instead be allocating additional housing sites such as Land North of Millennium Way.