Object

Representation ID: 6503

Received: 13/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

National context and plan period (paragraph 1.5)
A key point that the Council will need to address, and one that has admittedly arisen since the beginning of the consultation period, is the requirement set out at paragraph 22 of the new National Planning Policy Framework (NPPF, published 20th July 2021) which provides an expectation for local plans which encompass strategic scale development to include a vision looking ahead for the next 30 years. The new text states:
“Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.”
This policy is subject to a transitional arrangement and applies only to plans that had not reached Regulation 19 (pre-submission) stage at on 20 July (or equivalent stage for Spatial Development Strategies). In which case it is applicable to the emerging Local Plan 2040. It is noted that the Government has decided against defining ‘larger-scale development’, instead concluding that this will depend on context, scale and setting and should be decided locally and tested at examination. Examples provided within the policy, however, include new settlements and large-scale extensions of existing settlements. On review of the spatial options set out at Section 3 of the consultation document this very much describes the types of development opportunities being explored by the Council.
The question which is therefore presented to the Council is whether this has any direct implications on both the plan period (currently 2020 to 2040 but plausibly should now be extended to 2050) and whether this has any additional impact on the growth targets set by the plan. Admittedly the response required by the Council is yet to be clarified in accompanying guidance (the Government’s Planning Practice Guidance is still to be updated). However, plausibly, there may now be a necessity to update the housing and jobs targets to cover an extended period beyond 2040. This could potentially increase the level of new homes to be delivered by the plan by up to 13,500 units (the current Local Housing Need figure over ten years plus a 5% uplift), although it is unclear what the repercussions on the extension of the vision would have on the objectively assessed needs to be planned for.
What is evident is that the same option no longer exists to the Council to arbitrarily shorten the plan period to address issues in respect of long-term delivery, a move taken prior to the adoption of the Local Plan 2030 and one which we maintain has now presented significant pressure on the Council to significantly increase housing delivery across the Borough in the short term (the first 5 years of the new plan period). The plan must include a positive and ambitious approach to the delivery of new homes from the very first year of the plan period to ensure a pipeline is in place to guarantee growth for the next 30 years.
What we do consider is now of critical importance in the preparation of the current plan is showing that the strategic sites to be included within it are demonstrably developable (that is there would be a reasonable prospect that they will be available and could be viably developed at the point envisaged). This issue must be met head on by the Council this time around. Indeed, the implications of paragraph 22 of the new NPPF would have resulted in a dramatically different outcome to the Local Plan 2030 which could realistically have embraced our client’s land as an allocation at that stage, a step which would have seen it delivering houses now. The problems faced in respect of the defunct Colworth village proposals aside, and despite the positive resolution of the Inspectors presiding over the examination of the Local Plan 2030, it is our view that there were (and remain) significant gaps in the evidence base surrounding how and when some of the Council’s strategic sites are to be delivered (Land South of the River and Ford End Road continue to represent sites of significant concern to our client).