Comment

Representation ID: 168414

Received: 14/10/2019

Respondent: MacTaggart and Mickel

Agent: Rapleys LLP

In principle, the identification of assumptions is consistent with the PPG.

The following comments should be addressed in pursuit of a robust analysis. When selecting sites to be used to act as a barometer for delivery timescales, the Councils have elected to exclude a number of sites they consider to be 'abnormal'. Contrary to the Councils' assertion that these instances are 'abnormal', such occurrences affect many major sites and are not untypical. By choosing to exclude such circumstances, delivery is unduly positively skewed.

The assumptions made on lead-in times appear to relate to the interval between approval and a 'start on site' rather than to first housing completions. The commencement of construction will often involve a long lead in time and it is not unusual for 6-9 months between the start of development and the first houses being finished and released onto the market. Such factors must be accounted for when determining actual housing delivery.