Comment

Representation ID: 168560

Received: 14/10/2019

Respondent: Bidwells

There is a notable change in emphasis in the definition of deliverable from the previous NPPF. All major development with the principal of development established but without detailed planning permission will not normally be deliverable unless there is clear evidence.

'Clear evidence' means the assessment must be sensible, logical and supported by enough information to make it obvious how the conclusions were met. It is not intended to be a definitive assessment of probability of what will be delivered but rather what probably could be delivered in the time period.

It is not clear if the new definition of deliverable is a closed list and sites that do not benefit from an allocation or planning permission should not be included. If it is not a closed list, the evidence necessary to demonstrate that sites are deliverable would be greater for those in part (b). The level of evidence necessary to demonstrate deliverability of sites in part (b) would mean that the inclusion of such sites would be exceptionally rare.