Revised Development Strategy

Object

Representation ID: 55335

Received: 28/07/2013

Respondent: Sharba Homes

Agent: PJPlanning

The RDS will fundamentally conflict with the NPPF's approach [set out in paras 83 and 84 in respect to the Green Belt] since it does not channel development to the type of areas set out in paragraph 84 of the NPPF.

On the contrary, it channels over half of the 'village' development toward 'washed over' villages in green belt.

It does this:

* Despite accepting that more work needs to be done to assess the capacity of villages to accept development
* Ignoring the capacity of the 'other villages' to accept development. This is not an insignificant capacity. For example, if each of the 'other' settlements was to receive a single additional dwelling each year (which is perfectly possible), then that could account for almost 400 dwellings over the plan period.

It follows that the location of development in Green Belt has been considered as closer to a first, rather than a last, resort and that the necessary exceptional circumstances have not yet been demonstrated.

Recent announcements by the Secretary of State have made it abundantly clear that a simple need for additional housing cannot in itself provide the exceptional circumstances necessary to justify amendments to the Green Belt boundary, and it is very clear that this Strategy takes this approach.

Since the consequence of the local planning authority's policy approach would involve significant intrusions into the green belt around a number of 'washed over' villages, the minimum necessary evidence should be a clear demonstration that it is impossible to meet the housing requirements within or adjacent to existing settlements.

This includes Primary and Secondary Service Villages outside green belt as well as the main urban areas, since all of these have been identified as 'sustainable' locations.

This should be allied to a full green belt review to demonstrate, for example that the extension of 'washed over' villages is a more sustainable approach to the use of Green Belt land.

Until all of these matters are demonstrated, the Strategy is unsound:
* It has not been demonstrated to be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence.

It is not, therefore, 'justified'.

* It does not enable the delivery of sustainable development in accordance with the policies in the Framework - in this case, specifically, sustainable development and Green Belt policies.

*It is not, therefore, consistent with national policy

Resolving Objection:
The next version of the Strategy should promote a pattern and rate of development that:

* Is based on the full objectively assessed needs for market and affordable housing in the housing market area
* Fully assesses the capacity of locations outside Green Belt to enable the creation of sustainable development towards meeting that need
* Following a full review of Green Belt, identifies sustainable locations in the green belt sufficient to meet any shortfall in capacity.