The allocation of the Stambridge Mills site for residential development is supported as a matter of principle. The Stambridge Mills site is the subject of a current full planning application for redevelopment to provide 96 units. The Sequential Test and Exceptions Test have been passed.

Objections are, however, raised to the overly prescriptive nature of Policy BFR3. Specifically, the Concept Statement includes a series of quantitative requirements for the provision of affordable housing, Lifetime Homes (LTH) standards, public open space and play space which are not considered appropriate or reasonable.

Affordable housing and LTH requirements are principally addressed through Core Strategy Policies H4 and H6 respectively. Both policies recognise that the level of provision will need to be reduced where full compliance would threaten the viability of a particular development. Similarly, the level of provision of open space including play space will need to have regard to site characteristics and context, scheme layout and design constraints, and the need to achieve a viable development outcome. Whereas, the development of greenfield sites may allow a more prescriptive approach to these standards, brownfield sites give rise to generally higher costs in terms of historic acquisition values and site clearance/preparation.

It is also disputed whether it is reasonable to require high levels of open and play space provision in the context of full compliance with private amenity space standards. Adopted SPD2 (Housing Design) confirms that children's play spaces are not usually considered necessary because of the reasonable garden sizes required by the LPA. Access to off-site open space facilities will also be a consideration along with the maintenance and supervision issues which can arise from play spaces within residential developments.

Therefore, while this site can reasonably provide areas of public open space including play space, Policy BFR3 is not considered to be sound on the basis of its over prescriptive approach to the application of planning standards. It is noted that the Implementation, Delivery & Monitoring Chapter of the document states, in respect of Policy BFR3, that the Council will adopt a flexible approach to the requirements of the Concept Statement where compliance would threaten the viability of the scheme. This approach should be embedded within the policy itself.