Object

Representation ID: 60192

Received: 13/08/2013

Respondent: Catseby Estates Ltd

Agent: Framptons

Submissions made on behalf of Catesby Estates Ltd in respect of the land edged red, at Oak Farm, Rouncil Lane, Kenilworth.

The RDS does not satisfy the tests of soundness in that it has not been (NPPF para 182):
* Positively prepared
* Justified
* Effective
* Consistent with national policy

The revocation of the regional strategies has brought a responsibility for local planning authorities when preparing development plans to make adequate provision for housing (and other development) needs.

Para 47 of the NPPF requires LPAs to [inter alia]:

* rapidly address the problems of housing delivery in view of the adverse social and economic effects that are brought about where inadequate land for housing is provided; and
* increase the buffer to 20% (moved forward from later in the plan period) (emphasis added) to provide a realistic prospect of achieving the planned supply and to ensure choice and competition in the market for land (Where there has been a record of persistent under delivery of housing)

In order to significantly boost housing land supply the Plan should identify a broader range of housing sites, which are free from technical and environmental constraints, and where house builders are keen to build new homes early in the plan period.

The land identified off Rouncil Lane is free of constraints that might preclude the early delivery of new homes, other than the policy constraint imposed by the Green Belt.

It is evident that the housing strategy for the number of houses presently proposed in the Local Plan relies upon some provision of land from the Green Belt.

As such the exclusion of this site from the Green Belt does not raise a fundamental matter of principle, whether land from the Green Belt is required.

Rather the issue is the amount of land that should be released from the Green Belt in order to ensure that the housing policies in the Local Plan are sound and predicated upon a robust evidence base.

It is submitted that the release of this site is justified in order to contribute to the housing needs of the District in the early part of the plan period.

It is acknowledged that development would result in 'an encroachment into the countryside'.

However in order to meet development needs which cannot be satisfied from an existing urban area such as Kenilworth, this consequence has to be accepted.

It is submitted that the release of this site from the Green Belt would not harm any other purpose for the inclusion of land within the Green Belt (Framework para 80).

A sustainable pattern of development would be achieved that is consistent with the guidance set out at paragraph 84 of the Framework.

The extended edge of the urban area would become the defining boundary of the redrawn Green Belt, and clearly recognizable. 'Permanence' will be provided by the application of Green Belt policy for the surrounding land.