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

Object

Representation ID: 6689

Received: 14/09/2021

Respondent: Peter David Homes Limited

Agent: Phillips Planning Services

Paragraph 1.48 advises that the Council will provide Parish Council’s with a choice as to whether they wish to allocate sites around their villages through the preparation of Neighbourhood Plans (NP’s).

This is a process that can work well if the Parish’s act reasonably quickly following indication of an initial intention to prepare a NP.

However, whilst some Parish Councils have taken forward NP’s, others have not and some have stalled such that potentially good quality sites have not come forward as there is no process in place for their allocation.

It is submitted that where Parish Council’s confirm a desire to prepare an NP that will allocate new housing there should be a Policy within the Borough Plan that makes this commitment clear.

The policy should provide a guideline for the level of growth that the NP will seek to deliver i.e. 50 homes, 75 homes etc.

In order to provide an incentive for expeditious preparation of an NP the policy should also make clear that if the NP has not been made within 3 years of the adoption of the Borough Local Plan, the settlement boundaries for that particular village can then be held to be out of date and so applications for new housing development close to or adjoining settlement boundaries would then benefit from a presumption in favour of sustainable development.

Where Parish Council’s confirm that they do not intend to prepare a NP it would be reasonable for allocations to be made through the Borough Plan (please see separate representations in respect of the small sites topic paper)

Object

Representation ID: 6692

Received: 14/09/2021

Respondent: Peter David Homes Limited

Agent: Phillips Planning Services

NPPF Paragraph 69 states that Development Plans and Brownfield Registers should identify land to accommodate 10% of a Local Authorities housing requirement on small and medium sites no larger than one hectare (1ha).

However, the Small Sites Topic Paper states that this requirement can be achieved without making site allocations beyond the urban area due to completions on windfall sites. We do not agree with this assertion.

We would argue that the Council is not addressing this requirement in the way envisaged by the NPPF, i.e. through Development Plans and Brownfield Registers. The Council should not be relying upon windfall development to deliver on a national policy requirement. In order to be positively prepared the Plan needs to take a proactive approach by allocating land through the Local Plan process.

As recognised by the NPPF, “Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.” (Paragraph 69)

The Council should be actively encouraging small and medium sites to come forward, whether that be by allocating sites in the Local Plan, or delegating such allocations to local communities, to be delivered by Neighbourhood Plans. (We have made separate representations on the matter of NP’s in response to paragraph 1.48 of the consultation paper).

There is an opportunity to achieve the objective of housing delivery on small and medium sized sites by directing some growth to the villages where a greater proportion of small sites are being promoted. This will facilitate some proportionate growth in these settlements which will contribute towards their vitality, and the viability of existing services and facilities.

There is also an opportunity to achieve the requirements of housing delivery on small and medium sites in conjunction with the Council’s obligation to deliver Custom and Self-Build opportunities by making some of these allocations for self-build plots.

The Plan going forward needs to plan for a significant increase in housing numbers up to 2040, and small and medium sites can make a meaningful contribution towards this. The Council should therefore make provision for this in the Local Plan.