Object

Representation ID: 10156

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Spatial Strategy (DS2(S))
The reliance on brownfield site’s as housing allocations is a flawed approach as it overlooks the role that brownfield site’s have as windfall opportunities. Their inclusion on a brownfield register, also negates the need to allocate as they are by definition acceptable for redevelopment. They should not be included in the plan to deliver new development.
The Plan relies too heavily on new settlements. They are not the most sustainable locations, take a very long time to emerge from conception to implementation and rely on significant new infrastructure. The Plan promotes new infrastructure opportunities but until these are in place there should be no reliance on their delivery because they are largely influenced by control outside of the Council.
The Plan fails to recognise the importance of small and medium sized site’s, which is specifically supported by the NPPF. Moreover, there are many site’s that are located on the edge of the contiguous edge of the Urban Area, or on the edge of existing sustainable communities in the rural area. These site’s are more sustainable and more deliverable than the proposed new settlements and offer a better solution to deliver essential new homes into the borough.
Neighbourhood plans expire in 2030 and yet this plan is until 2040. There is a 10 year gap, at the very least where no development is proposed for much of the rural area, amounting to an embargo on development. This will have an impact on those communities as their need for homes increases whilst supply is not provided.