Although POS agrees with the principle behind building more homes on brownfield land, we have serious concerns regarding the proposals as set out in the consultation document. Namely, the quantity of work involved in having Local Development Orders (LDOs) in place on all defined brownfield sites and the inappropriateness of some sites to the LDO process. In addition POS believes that any sites which are deliverable through the suggested policy would already be designated as housing in the Local Plan or would be on the LPAs radar, through pre-application discussions. The proposals represent a considerable additional burden on LPAs without sufficient additional funding at a time of reducing local council funding, the benefits of which are unproven. These are fundamental concerns which underpins the idea behind this consultation proposal. On this basis, and, taking into account some of the practicalities that the consultation document itself identifies, POS would strongly suggest that the proposal is tested through the use of pilots. This would help to better understand the benefits, any practical challenges and potential ways of resolving these.
The concerns that POS has are set out in the full response.