Object

Representation ID: 10206

Received: 29/07/2022

Respondent: Trustees of the Lawton Pension Scheme

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Spatial Strategy
2.9 Draft Policy DS2(S) sets out the spatial strategy, noting development will be focused within the urban area, at strategic locations adjacent to the urban area and at growth locations within the A421 and East West Rail corridor.
2.10 The Spatial Strategy outlines the delivery of development in the urban area through the redevelopment of previously developed land. Whilst the value of this is acknowledged in making effective use of the land, these sites are often challenging to deliver due to the high technical constraints that exist. Contamination, degraded land, ecological issues, legal and title constraints together with leaseholder concerns and the high cost of redevelopment often make these sites very difficult to develop, but moreover they cannot be relied upon to be developed in any fixed period. They are all classic windfall sites, or opportunity sites; but they are not suitable for allocation.
2.11 The allocation of these brownfield sites for redevelopment overlooks their potential to comprise windfall development throughout the plan period. Windfall sites are generally seen as tools in bolstering identified supply and addressing shortfalls in housing delivery but their allocation means that the Council can no longer fall back on these sites to cover under delivery. Their inclusion in the brownfield register (as they all should be) presents its own ‘commitment’ as a potential contribution to overall housing delivery numbers, but to allocate as well is an unsound basis for demonstrating the delivery of ‘new’ housing requirement for the Borough.
2.12 The Spatial Strategy also places significant reliance on the delivery of substantial isolated greenfield sites and new settlements. As outlined in the Stepped Trajectory Topic Paper (2022), that supports the emerging Local Plan, a range of assumptions are made in order facilitate the delivery of these settlements within the plan period. These comprise the delivery of substantial infrastructure projects on which the delivery of new settlements will be wholly reliant. Many of these infrastructure projects have been in the pipeline for a significant period of time and have experienced substantial delays in the past. Their timely implementation cannot be assured and yet the Council rely on this to happen. The reliance placed on the delivery of these strategic greenfield sites and new settlements for the delivery of homes through the Local Plan is considered to comprise significant risk and is highly likely to result in a shortfall throughout the plan period.
2.13 However, the real flaw in the planned spatial strategy is that the Council has not considered all reasonable alternatives and has not sought to identify sites in the most sustainable locations, such as on the edge of the Urban Area, or sustainable rural settlements. These sites have been overlooked in their assessment and we urge that this is reviewed.
2.14 This is the most sustainable location for growth. The Council must include these sites in advance of the identification of new settlement locations, especially where there is clear deliverability and cooperation with landowners and developers to pursue their development.
2.15 It is considered that the Spatial Strategy is flawed, overlooking sustainable locations for development in favour of uncertain new settlements and difficult brownfield sites that should be left as windfall opportunities. The Council has not looked closely at the preferred alternative site locations on the edge of sustainable settlements such as Milton Ernest, where this representation relates.