Comment

Representation ID: 40699

Received: 22/09/2021

Respondent: Bloor Homes

Agent: Barton Willmore LLP

The IIA is understood to be ‘a mechanism for considering and communicating the impacts of an emerging plan, and potential alternatives in terms of key sustainability issues’, as a document which aims to inform the plan-making process and maximise positive impacts, while minimising negative impacts and addressing risks.In considering the approach to plan-making and development across the district, the NPPF 2021 paragraph 11 presumption in favour of sustainable development should be adhered to, which for plan making means that:
• All plans should promote sustainable growth that aligns growth and infrastructure
• Provide for objectively assessed needs as a minimum as well as any needs that cannot be met within neighbouring areas.;
It is also noted that the IIA is informed by the Issues and Options document and spatial options consultation paper cited. References to these supporting evidence base
documents are included within these representations where relevant in expressing our views on the IIA.
Growth Scenarios
Of the three growth scenarios presented – lower, medium and higher growth – we consider that the higher growth option should be that which is preferred and taken
through the new local plan.
As cited above in paragraph 11 of the NPPF, the objectively assessed housing needs for the district should be seen as a minimum. Therefore to ensure sufficient delivery of homes across the plan, it is prudent to plan for a higher level of growth, thus minimising the risks of unplanned development while proactively addressing current and future needs.
Based on the assessment of growth options in Appendix I of the IIA, the following positive outcomes are the strongest in the higher growth option compared with the medium and lower growth options:
• Meeting the needs of the district and wider area, and improving cross-boundary links;
• Delivery of health and wellbeing infrastructure;
Integration and interaction of cross-boundary communities through the delivery of large-scale developments;
• Delivery of green and blue infrastructure and positive effects on the tourism economy;
• The delivery of sustainable transport connections and the realisation of crossboundary infrastructure projects;
• Delivery of new and accessible landscapes;
• Increased opportunities to focus development away from historic centres;
• Attracting government investment in significant infrastructure improvements to address climate change and environmental/air quality;
• Delivery of strategic green infrastructure in the interests of ecological and biodiversity net gains; and
• Increased co-ordination across boundaries with regard to consumption and use of natural resources.
The summary assessment of the growth options expresses the view that the lower growth options “performs better in comparison to the medium and higher growth options in relation to the landscape, historic environment, environmental quality and natural
resource themes”. This in addition to citing increasing risk of from a transport and climate change perspective.
However such a statement is counterbalanced by the fact that if a higher level of development is planned in the right areas – even if on greenfield or green belt land –
then there is a greater opportunity to not only avoid or mitigate negative effects across IIA themes, but would also constitute a more positive approach to delivery of
enhancements across the themes assessed.
In this sense, planning for a higher level of growth would represent greater consistency with the NPPF. Section 3 – Plan-making, states in paragraphs 16 and 16 that:
“Succinct and up-to-date plans should provide a positive
vision for the future of each area; a framework for
addressing housing needs and other economic, social and environmental priorities; and a platform for local people to shape their surroundings.
Plans should… be prepared positively, in a way that is
aspirational but deliverable.
Early engagement and planning for a higher level of growth would allow stakeholders and decision makers to collaboratively not enhance the district and its surroundings through increased investment opportunities for key infrastructure to be delivered, increasing the
scope and potential for higher quality of design, therefore in turn being more consistent with the recent increased national level focus on design.
Sites such as Land North of Hawkwell Road also demonstrate that some of the evidence base upon which the IIA is made is flawed in that it underestimates the opportunities for the release green belt land that could be released while still retaining and enhancing the purposes of the green belt. This is examined in greater detail within section 4 below and the landscape and visual appraisal included within appendix 3.
Therefore we recommend that the higher growth option is taken forward and that the spatial options Green Belt Study and Landscape Character, Sensitivity and Capacity study papers be immediately reviewed.
Spatial Strategy Options
Of the Spatial Strategy Options presented, we consider that option 4 presents the best combination of outcomes that will enable the authority the greatest flexibility to tailor fit a broad selection of sites spread holistically across the district and would in turn therefore function best with a higher level of growth.
Other options where growth is targeted and focused on one or a smaller selection of settlements would be inconsistent with the aspirations of the NPPF which states in paragraph 84 that planning policies should enable the sustainable growth of businesses, rural tourism and the development of accessible local services. It is through a balanced and sustainable spread of growth across the district that the prosperity of rural economies would be most highly supported through the new local plan.
By this same token, this flexibility and the positive impacts to rural communities means that greenfield and green belt release development opportunities can be realised as part of a holistic approach, thereby increasing the strength of options available for development and supporting infrastructure across the district.
Based on the ‘Assessment of the spatial strategy options’ within section A4, the following positive outcomes are particularly strong in the case of option 4 when compared with other options:
Tailored housing options to meet local needs through a more balanced supply of housing and land options;
• Facilitating health and wellbeing capacity upgrades;
• Strategic improvements to green infrastructure;
• Opportunities to capitalise on the Thames Estuary Growth Area;
• Delivery of transformative growth opportunities and wider development in the most accessible areas;
• Delivery of new regional parkland, biodiversity, ecological and landscape enhancements;
• Growth that can be tailor suited in location, massing and design to the historic environment of the district;
• Greater flexibility to avoid areas of greater flood risk and improvement of drainage strategies;
• Delivery of local and strategic infrastructure to mitigate traffic congestion from increased growth; and
• Effective use of brownfield development opportunities to minimise negative impacts on mineral resources and waste management.
Therefore in planning positively for growth and given that option 4 presents the most positive outcomes, leaves the least uncertainty regarding significant effects, and that any negative significant effects can be mitigated, we recommend that spatial strategy option 4 is pursued and that the Green Belt Study and Landscape Character, Sensitivity and Capacity study papers be immediately reviewed in the context of this.