H1 (part)

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, are existing employment sites. There is a
concern that unless appropriate consideration is given to the development of these sites, this
approach could result in the loss of valuable employment sites, which would have a
detrimental impact upon the availability of employment sites in sustainable locations.

In particular, the Council has included 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 Policy ED4, 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 to the fourth bullet of paragraph
4.19, which advises that development will be 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 proposed number of jobs, additional employment sites will be required.
The Employment Land Study recommended the 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 - 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, welldesigned 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 areas
characteristics and / or the need to provide a larger proportion of family housing'.

Third Paragraph - reword the first sentence as follows:

'The Council will seek the redevelopment of Rawreth Lane Industrial Estate, Eldon
Way/Foundry 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.