Core Strategy Submission Document

Support the fact that the Core Strategy acknowledges the need that part of the Green Belt will need to be reallocated to meet the housing requirement in the East of England Plan.

Support the approach to sustainable development and focussing housing development in the higher tier settlements, with a proportion of the new housing in the lower tier settlements.

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

Support the findings that in order to fulfil the requirements of the East of England Plan to meet the housing need of the District, it will be necessary to allocate additional land for residential development, including land which is currently allocated within the Green Belt.

These new residential allocations should be in the most sustainable locations, as extensions to the higher tier settlements, which will require alterations to the settlement boundaries and removal of land from the Green Belt.

Support the findings that in order to fulfil the requirements of the East of England Plan to meet the housing need of the District, it will be necessary to allocate additional land for residential development, including land which is currently allocated within the Green Belt.

These new residential allocations should be in the most sustainable locations, as extensions to the higher tier settlements, which will require alterations to the settlement boundaries and removal of land from the Green Belt.

In identifying the settlements in which development should be directed, agree that residential development should avoid areas of constraint, including areas of risk of flooding.

Furhtermore, where land is released from the Green Belt to accommodate additional residential development, this should ensure that the resultant development creates a defensible Green Belt boundary, and does not result in the coalescence of neighbouring settlements.

Agree with the general locations and phasing of residential properties over the period, and the plan seeks to develop bronwfield sites prior to the release of Green Belt. 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, which may require the earlier release of Green Belt land.

Amend paragraph as follows:

It is important to phase the loss of Green Belt land to ensure that there is not an early or excessive release which may discourage redevelopment of previously developed land or undermine town centre regeneration projects. However, in order to maintain the housing trajectory it may be appropriate for the early release of Green Belt sites, to compensate for previsouly developed sites that may fail to come forward in the projected timescale; this approach will ensure that the Council maintains its five year supply.

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.

In order to ensure flexibility, this policy needs to make reference to Policy H3, in case the locations allocated under Policy H2 do not come forward in the required timeframe or deliver the required number of dwellings.

Fourth Paragraph - amend as follows:

The Council will maintain a flexible approach with regards to the timing of the release of land for residential development to ensure a constant five-year supply of land. If the locations within Policy H2 do not come forward in the required timeframe or deliver the required number of dwellings, then locations with Policy H3 should be brought forward to address this shortfall.

To ensure that an adequate five year supply, a flexible approach needs to be adopted with regards the timing and release of land for residential development. In light of the current economic climate sites that are identified for the period up to 2021, may not come forward for a variety of reasons and need to be augmented by site(s) identified in period post 2021 in order to maintain the 15 year supply. The sites for the period post 2021 should also be delineated in the Allocations Development Plan Document.

The objective of the Local Development Framework is not just about allocating sufficient land to provide new homes but is about ensuring that, subject to the prevailing market conditions, allocations will actually deliver the required amount of housing over the plan period. This relies largely on allocating sites where there is a real prospect (available, suitable and achievable), of delivery within the anticipated timescale. It also requires a mechanism to ensure that sufficient sites are brought forward at the right time to enable delivery.

This approach is consistent with the guidance contained within Planning Policy Statement 3 (PPS3) which advocates local planning authorities maintain a flexible and responsive supply of housing land that reflects the 'Plan, Monitor, Manage' approach. This supports the need for a clear policy approach that indicates the timing of potential housing sites in relation to the housing trajectory and the 5 year supply of land. In addition, to the 5 year supply of deliverable land, PPS3 also requires a further supply of specific, developable sites for years 6-10 and where possible, years 11-15. Sufficient sites will therefore be allocated up to 2026 to meet the 15 year requirement in PPS3. In the event that the market does not deliver sufficient homes to meet requirements, sites will need to be brought forward from future year's allocations to ensure housing delivery targets are met.

As we are currently in a period of recession it is not unreasonable that some of the sites allocated in the early years of the 15 year supply may not come forward as for a combination of reasons the sites may no longer be deliverable (eg no longer available and/or achievable). In addition, it is necessary to provide private housing in order to ensure that the associated/linked affordable housing is also provided.

Therefore, in order to ensure that a continuous 5 year supply is maintained it may be necessary for sites identified in future years to be brought forward and to ensure this happens these sites should also be specifically delineated on the Proposals Map, which accompanies the Allocations Development Plan Document.

Paragraph 4.24 - amend as follows:

In considering the general development locations for post-2021 development, the same issues as for Policy H2 above have been considered. These sites have been assessed for their ability to be delivered early to compensate for any shortfall in the pre-2021 site. The assessment will include a review of available infrastructure and the impact on existing communities to ensure that their early delivery would be appropriate.

In addition, to the general location and development been articulated within the Allocations Development Plan Document, in accordance with the requirement of PPS3 the specific sites should also be delineated on the Proposals Map.

This approach is consistent with the need to maintain flexibility in order to ensure certainty to the delivery of the 15 year supply, particularly if any of the locations identified in the period post 2021 need to be brought forward in order to maintain the 5 year supply. This may requier the release of land from the Green Belt ahead of the development of all the sites in Policy H2.

Amend first paragraph as follows:

Post-2021, the residential envelope of existing settlements will be extended in the following areas (as indicated on the Key Diagram) to deliver the following number of units post-2021. Prior to this time, Green Belt land within such areas will be safeguarded with the exception of land that is required to maintain a continuous 5 year supply of land in accordance with Policy H2.

Amend second paragraph as follows:

The detailed location and quantum of development will be articulated within the Allocations Development Plan Document, and delineated on the Proposals Map.