Object

Representation ID: 1720

Received: 30/01/2015

Respondent: Cogent Land LLP (Cogent)

When taking an average of completions across the plan period, SBC is on target to meet the housing need identified in the Core Strategy. However, we consider it unacceptable for a Council to use an 'average' figure to make up for shortfall in completions within other years and effectively 'mask' a persistent under delivery. As such we would expect a 20% buffer to be applied to the calculation of Objectively Assessed Need (OAN) to take account of the persistent under delivery in housing across the Borough since 2007. We therefore believe that the Council currently has a housing land supply of 4.75 years, as applying a 20% buffer to the OHN indicates a need for 2,003 dwellings.

Based on this above analysis, it is therefore vital that all identified sites in the Borough come forward. The Council should therefore take steps to ensure that the CIL charges are set well below the margins of viability to ensure that they do not threaten the delivery of the identified housing need. An argument supported by the CIL Guidance, which states that "charging authorities should set a rate which does not threaten the ability to develop viably the sites and scale of development identified in the relevant Plan".7