Whilst, we agree with the general locations and phasing of residential properties over the plan period, however, in light of the current economic conditions and the need to maintain an adequate five year supply; the policy needs to adopt a flexible approach with regards the timing and release of land for residential development.

This Policy advises that it will prioritise brownfield development, through sites identified in the Strategic Housing Land Availability Assessment (SHLAA). However, the main sources for potential housing sites within the urban areas, including employment sites, schools, redevelopment of existing residential sites (eg development of garage blocks), and areas of open space. There is a concern that unless appropriate consideration is not given to the development of these sites, this approach could result in the loss of valuable employment sites and amenity space and/or inappropriate 'backland' development, which would have a detrimental impact upon the overall environmental quality of the area and the living conditions of the residents. Furthermore, if sites are developed with a higher proportion of family housing this will reduce the overall density.

Since the Preferred Option document was published the Council have introduced the four industrial sites that could be redeveloped, for alternative appropriate uses (including residential). It then goes on to state that alternative employment locations will need to be identified in appropriate locations, which due to the shortage of sites in the existing urban areas would need to be in the Green Belt.

In order to ensure that a co-ordinated approach is taken to the release of Green Belt land, the requirements for both employment and housing land should be considered together. The idea of not releasing land for residential and then releasing it for employment purposes is a contradiction, as it still requires the release of Green Belt.

In terms of the site at Stambridge Mill, this is located in an area which has a high risk of flooding. The policy advises that in order to redevelop this site it would be necessary to satisfy the PPS25 exceptions test.

However, in order to manage risk, PPS25 would only permit development in areas of flood risk when there are no reasonably available sites in areas of lower flood risk and the benefits of the development outweigh the risks from flooding. Furthermore, the Exception Test should be applied by decision-makers only after the Sequential Test has been applied.

In respect of Stambridge Mill this site would fail to meet the requirements of sequential test as more sequentially preferable sites (within Zone 1), have been identified as part of the Core Strategy. The allocation of this site would also be contrary the fourth bullet of paragraph 4.19, which advises that development will directed to the most sustainable locations on the edge of settlements, having regard to amongst other things: the potential to avoid areas of constraint, such as areas at risk of flooding.

In order to meet the number of jobs required in the RSS, additional employment sites will be required. The Employment Land Study recommends that any de-allocations of employment land be compensated for by the allocation of 18 hectares of new employment sites. As the supply of employment land within the District is tight, this will require the release of Green Belt land.

Reword Policy as follows:

First Paragraph - unaltered

Second Paragraph - reword as follows:

'The Council will prioritise the reuse of previously developed land and ensure the delivery of appropriate sites within existing settlements identified by the Strategic Housing Land Availability Assessment. Consideration should also be given to the creation of balanced, well-designed mix of housing, which have been provided at a range of densities; as in every instance it may not be appropriate to maximise the density of a site due to the site characteristics and/or the need to provide a larger proportion of family housing'.

Third Paragraph - reword as follows:

'The Council will seek the redevelopment of Rawreth Lane Industrial Estate, Eldon Way/Foundary Industrial Estate and Star Lane Industrial Estate, for appropriate alternative uses, including residential development and replacement employment uses'.

Fourth Paragraph - delete

Remaining paragraphs of policy unaltered