Comment

Representation ID: 168410

Received: 14/10/2019

Respondent: MacTaggart and Mickel

Agent: Rapleys LLP

The Councils have used the NPPF 2019 definition of deliverable, which is supported.

The obligation to provide 'clear evidence' rests fully on the LPA. Support the approach used by the Councils of using the list of examples of clear evidence to inform a questionnaire sent to all relevant sites, alongside the Councils' assumptions in terms of build out and delivery rates. However, it is unclear how the questionnaire outputs have been weighted to inform the judgements regarding deliverability. Deliverability should consider ownership, planning status and site constraints.

Where a questionnaire has not been returned, the Councils have relied on their own assumptions. This approach fails to take account of the requirement to adduce clear evidence. Failure to respond to an invitation to advise on housing delivery should be treated as a significant impediment to housing supply coming forward within the five year period.

Should have full regard to the commentary set out within recent appeal decisions that have grappled with the matter of deliverability.

It is noted that the Councils continue to include major sites without full planning permission. These sites should be rigorously reviewed in accordance with current deliverability criteria.