Review Report

The HBF objects to some of the wording as it is wrong to say that it is the changes to TAN1 which have caused the under delivery of new homes, TAN1 is only a way of measuring the genuinely available land, it does not have an impact on the actual delivery of homes.
Additional wording is required in light of the Ministers recent statement regarding LDP's and the need for them to move forward jointly.

The HBF are concerned that the wording of this paragraph suggests that the only way to deliver more homes is to ask for less in the first place. The housing provision should be set taking account of the identified need as a starting point as advised in PPW, and then making adjustments to allow for any economic or other aspirations which are linked to the need for housing, the wider North Wales Growth Deal is relevant for instance. It would be wrong for the plan to set the housing need at a level just to give a better chance of being able to deliver the numbers particularly if this is based on historical build rates. What is more important is to ensure that the sites allocated are the right ones and can be delivered and that other policies do not affect this deliverability.

The HBF suggest that this would be a good point to include a reference to the potential impact of the North Wales Growth Deal and its ambitions for economic growth which will need to be matched by the provision of new homes in the right locations. There doesn't appear to be any mention of it anywhere else in the document.

The HBF do not consider that this paragraph on windfall's currently provides all sides of the story. There are many factors which could affect the level of windfall development, firstly the windfall level could have been set at an unrealistic level so was never going to be achieved. Secondly by their nature there is not an unlimited supply of windfall sites and no guarantee of when they will come forward so their availability is likely to reduce over time, both of these points should be included within the paragraph. Further if it is just down to small sites as explained in the paragraph it would help to provide some data to support this.