Object

Representation ID: 5019

Received: 20/12/2022

Respondent: Vistry Group

Agent: Rapleys LLP for Vistry Homes

Legally compliant? No

Sound? No

Duty to co-operate? No

The Infrastructure Delivery Plan (IDP), as it was in 2021 at the time of the Regulation 18 Plan publication, is still prepared on the basis of the unresolved uncertainty regarding the overall unmet housing requirement need.
addition, whilst there has been dialogue as part of the DTC, it is clear that the Regulation 19 sites have been allocated without regard (or little regard) to highway modelling – paragraphs 5.22-23 of the IDP refers. This is not only risky in terms of potential need for significant and costly improvements, but is also contrary to the PPG (paragraph 059).
As noted above in the PPG, the DTC extends to other infrastructure providers. The DTC Paper lists all the bodies that the Council has consulted/collaborated with. One glaring omission is Network Rail/Rail Operators. This is particularly important in the context of the delivery of Cross Green (in whole or in part), one of the strategic allocations – further detail and commentary on this is provided in paragraphs 3.10-3.16 below.
In short, the lack of a SOCG, whether that be in the context of the GBBCHMA housing need or in terms of infrastructure provision with key providers/service delivery organisations/etc raises questions about the delivery of some of the allocations either in their entirety, or in part within the plan period. This goes to the heart of the soundness or otherwise of the plan.
Vistry considers that the Plan is unsound in this context as it is not ‘positively prepared’ and it is not ‘justified’ (i.e., based on proportionate evidence base).