Object

Representation ID: 60200

Received: 29/07/2013

Respondent: Gladman Developments

The Council's preferred approach directs development to within and the edge of exiting urban areas. It allows for a higher level of growth in more sustainable villages with a reasonable level of services, and limited growth to smaller villages and hamlets of a scale appropriate to the existing settlement. It recognises that development directed towards villages may need to be located within or adjacent to the existing village envelope, and in some instances within the Green Belt.

In principle support the Council's distribution strategy. It recognises that growth should be directed to key towns and villages with established sustainability credentials, ensuring the creation of sustainable communities that have good access to a range of jobs, housing, community facilities and key services and infrastructure.

However, it should be noted that whilst the main settlements should accommodate a larger proportion of housing growth, this should not prevent development coming forward in lower order, sustainable settlements, which could also help to sustain existing facilities and services.


One of the principles of the Council's development strategy is to avoid development which could potentially result in the coalescence of settlements.

Would welcome further clarification on the decision making criteria that would be used to implement this policy.

In particular it should be recognised that development which results in a physical loss in separation can often be accommodated without eroding the character and identity of individual towns and villages.


Sustainable Urban Extensions and Housing Supply

A significant proportion - 66% - of the of the Council's proposed housing requirement is to be met through the allocation of sustainable urban extensions (SUE).

Whilst recognising the sustainability benefits that can arise from SUEs, placing too much emphasis on these sites could further result in an under-supply of housing in the District.

Large SUEs often require extensive infrastructure and planning prior to housing being delivered. As a result often they fail to come forward as anticipated, or only start to deliver in the medium to longer term.

If the Council cannot demonstrate a five-year housing land supply upon adoption of its Local Plan there's a risk that its housing policies will be out-of-date as soon as the Plan comes into effect.


In light of the above, and to ensure housing comes forward as anticipated, the Council need to allow for the release of additional housing sites, and earlier in the Plan period to meet its housing needs.

In doing so it should consider sites that result in sustainable development and continue to support the Plan's strategy.

Village Development

The Council's 2013 Settlement Hierarchy Strategy allocates an initial range of housing growth to each of the Primary and Secondary Services Villages.

It describes how these initial figures have been based on feedback from Parish Council's and Neighbourhood Plan teams, apportioning housing based on existing settlement size, and an outline assessment of key delivery factors, e.g. services and facilities, environmental impacts and the suitability of sites.

The initial dwelling ranges for the District's Primary Service Villages are set out in Table 3 (as submitted).

With reference to the distribution strategy for the Primary and Secondary Service Villages the Council is reminded that it should not be progressing a political strategy to apportion development to settlements where people do not want to (and will not) live.

Whilst recognising the role of parish council's and local communities in shaping the development of their areas first and foremost growth should be distributed on the basis of meeting housing needs.
There may also be a need to update the village dwelling allocations in light of the Joint SHMA findings.

The Strategy goes on to state that the initial dwelling ranges for each village will be reviewed in light of ongoing work on Green Belt assessment, habitat and landscape impact and identifying the most appropriate sites - that minimise environmental impacts, contribute to the built quality of the village and deliver an appropriate scale of development - which could deliver housing in each village.

This suggests that where suitable, unconstrained sites are available a village can support housing growth at the upper end of its allocated range.

It may also be preferable to focus more growth in villages that are unconstrained by Green Belt designations.

Policy RDS5 provides further guidelines on how housing within the villages should be accommodated. These criteria include:

* Ensuring an appropriate mix of dwelling types and sizes, including affordable housing

* Ensuring acceptable design, layout and scale through a collaborative approach involving Parish Council's, Neighbourhood Plan teams and residents

* Carefully considering the quality of development and how this relates to local vernaculars; and

* Ensuring landscaping will be used positively to contribute to and protect the quality of place


Where a proposal accords with these criteria it should be considered acceptable and sustainable.

However it is noted that two further guidelines for village development set out that housing growth should be located within the village envelope and give priority to the redevelopment of brownfield and previously used sites.

Gladman Object to these guidelines in their current form.


Whilst locating sites within existing village envelopes is desirable, under Policy RDS4 the Strategy recognises that there may be a need to locate further village growth adjacent to existing settlements. This should be emphasised in Policy RDS5.

Further, whilst it is recognised that the development of brownfield sites is important, a priority should not be placed on this which would act to arbitrarily restrict development on sustainable Greenfield sites. It is also worth noting that there are likely to be brownfield sites that are less sustainable than Greenfield land options.

Infrastructure Requirements

The RDS sets out requirements for the provision of infrastructure where it has identified specific site allocations and a range of Borough-wide highway improvements.

The Council are reminded of the guidance on viability set out in p173 of the Framework, which states that "Plans should be deliverable.

Therefore, the sites and scale of development identified in the Plan should not be subject to such a scale of burdens that their ability to be developed viably is threatened".


It is noted note that the Council is yet to publish an Infrastructure Delivery Plan or test the viability of its infrastructure requirements.

The robustness of these requirements in their current form. is therefore questioned.

The requirement to provide new infrastructure should only apply where there is a clear and evidenced deficiency in the provision of existing facilities to accommodate a development.