• LDPs should ‘allocate sufficient land to fully meet society’s needs.’
(Functions of LDP)
• An assessment of social and affordable housing delivery in relation to the Housing Executive’s Annual Housing Need Assessments should be an important element of the Annual Monitoring Report. (Q12)
• There should be a duty on the Department, when considering PAC recommendations and subsequent modifications to Plans, to consult statutory consultees on any modifications. (Q11)
• Compared to current acute and growing housing needs, there is significant under-provision of land for social and affordable housing in many out-of-date adopted plans.
• We therefore do not consider the transitional arrangements proposed adequately address the urgent requirement to rectify this to ‘meet society’s needs’ before new LDPs are adopted.
• Given the likely timeframes for the adoption of Local Policies Plans, it is vital that strategic housing sites are included within Plan Strategy documents, with a Key Site Requirement for social and intermediate housing.
• Adopted Plan Strategies should come into force to supersede out of date plans, and the Ards and Down Area Plan and BMAP, prior to the LPP being published and adopted.
• Transitional arrangements should also be considered that allow for emerging Local Development Plans (LDPs) (both Plan Strategies and Local Policies Plans) to be given weight – and potentially take precedence over – out-of-date adopted plans, informed by approaches taken in other UK jurisdictions.
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