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Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6572

Received: 13/09/2021

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

Representation Summary:

Growth Strategy Options
2.11 In respect of the proposed growth strategy options, at this stage we consider the distribution of housing
should be displayed as a percentage, that way it can more quickly respond to changes in housing
requirement for example, whilst maintaining the spatial distribution of housing.
2.12 In respect of the proposed options, we consider it almost inevitable that the spatially optimal solution is
likely to be a hybrid of a number of the referenced options. Our favoured approach would be an approach
which seeks to continue delivery in the urban areas, deliver higher growth on key transport corridors,
particularly the A421, but retains an apportionment of growth to be disbursed to the rural area. The issue
with the other options is that they place too significant an emphasis on delivery on limited areas. Such
an approach reduces the ability of the market to function most efficiently, as the variety and competition
will be reduced. This reduces the ability for small and medium housebuilders to enter the market and
reduces the options for home purchasers. This will become particularly apparent if a higher housing
requirement is deemed to be appropriate, placing further emphasis on a more limited pool of
settlements. Dispersed growth as well as assisting delivery, encouraging a wider range of housebuilders
into the market delivering concurrently, also has the benefit of supporting rural communities remain vibrant and ensuring a healthy demographic composition, preventing issues such as village ageing.
2.13 Dispersed growth (or Village related as it is referred in the consultation material) in our opinion should
form part of every spatial option, albeit the level to be delivered could of course differ option to option.
We would wholeheartedly reject any attempt to constrain any dispersed growth, as it is well established
at this point the significant harm such an approach has caused in recent years nationally, as reflected in
matters such as declining public transport routes, closure of village pubs, closure of shops and the
general decline in vitality of village life generally where development has been withheld. Whilst the current
plan makes some provision going forward, clearly this is to be delivered up to 2030, and thus would result
in a 10-year period with no proposed growth which would be unacceptable and as such some provision
must be provided to ensure sufficient provision is made over the extended Plan period.
2.14 A dispersed pattern of growth is better enabled through the availability of modern technology including
recent modal shifts in online shopping, improvements to high-speed broadband provision, the increasing
prevalence of home working and the greening of private vehicles through developments in electric
vehicles, which by the end of the Plan Period are likely to be highly prevalent, with new petrol and diesel
car sales ending in 2030. Post lockdown there is likely to be a continued demand for semi-rural
opportunities, with the COVID-19 pandemic placing a greater emphasis on space and outdoor living.
2.15 Whilst we do not object to the principal of identification of a new settlement as a facet of future delivery,
we would urge caution be applied if the Council are to rely heavily on delivery arising from new
settlement/s to meet the overall quantum of housing growth necessary over the Plan period. Such sites
are notoriously difficult to deliver and require significant amounts of planning and infrastructure delivery
prior to the first dwellings being delivered. Our preferred approach in this scenario is to positively allocate
such sites above and beyond the sites needed to meet housing needs. If work is underway and delivery
has started, this can be reflected in later plan reviews. This ensures that the site is allocated, which
should provide the confidence needed to the market to commit to the works and evidence necessary to
obtain the appropriate planning consents but means that housing delivery will continue if work is delayed or doesn't come forward at all. We would not object if Strategic Sites were used to facilitate an increase
in housing requirement, to provide delivery later in the Plan period. This should not be delivered through
a stepped trajectory, with sufficient land needing to be allocated to deliver Local Housing Need in full
through the Plan period.
2.16 The above approach is potentially beneficial in that it means the Council can retain an element of control,
meaning they can ensure the new settlement/s comes forward in an acceptable manner, and are not forced to compromise on key elements to ensure the site is delivered due to an over reliance on delivery.
If it becomes apparent at a future Local Plan Review that the site is going to deliver, through evidence
and appropriate planning consents, then the Council can begin to rely on delivery to meet base Local
Housing Need. Given the likely lead in times, it is considered unlikely any development will be forthcoming
until the latter end of the Plan period. As such if a higher housing requirement is assessed as being
necessary, additional smaller sites will need to be identified in the early years of the Plan. This approach
however could provide supply in the long term and an important avenue for future delivery, particularly
towards 2050.