we wish to make the following points:

In relation to Chapter 3 Part 3.15 (pg 46), Objective HO056 would be problematic in many cases as it talks of an absolute density of 25 houses per square kilometer.

Part 3.16, objective HOP26 would be problematic for agricultural/ rural housing development where the only access is via a regional road. 

Part 3.13 (pg 30-43) Sets out rural housing guidelines. On the economic needs, the 15ha idea is too specific. For example, there are several operators who do not own any land and still have significant farm operations. These should fall into part (ii). But it is not clear if you need to own land. We would also see a problem with the 7 years prior ownership. It shouldn't cause an issue for most but a person who had to move for example, due to compulsory purchase would not be able to provide themselves with a house for 7 years.

In relation to the social side of things, 16 years is unnecessarily long and the emphasis should be on establishing genuine cases from those which are not. We welcome objective HO045 (Page 37) which puts a minimum term of occupancy to 10 years from a previous 7 years. Enforcement of the same would be more appropriate than putting extra restrictions on genuine people who have a genuine requirement to live in their home (not their property).