BASE HEADER
H10 Bringing forward Allocated Sites in the Growth Villages
Gwrthwynebu
Publication Draft
ID sylw: 64530
Derbyniwyd: 26/05/2014
Ymatebydd: Mr Richard Thwaites
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
The preferred option for development within Hampton Magna has been overwhelmingly rejected by the residents.
The requirement for the design, layout and scale of the development to be made in collaboration with local residents cannot possibly be fulfilled.
The phasing requirement of the development will subject the existing residents to 15 years of construction traffic through small estate roads.
The local Plan is ignoring the availability of previously developed land in Hampton Magna.
The Maple Lodge site is preferred by the residents and would easily allow construction traffic access via non residential roads, to be phased with minimal disturbance to existing residents.
The preferred option for development within Hampton Magna has been overwhelmingly rejected by the residents.
The requirement for the design, layout and scale of the development to be made in collaboration with local residents cannot possibly be fulfilled.
The phasing requirement of the development will subject the existing residents to 15 years of construction traffic through small estate roads.
The local Plan is ignoring the availability of previously developed land in Hampton Magna.
The Maple Lodge site is preferred by the residents and would easily allow construction traffic access via non residential roads, to be phased with minimal disturbance to existing residents.
Gwrthwynebu
Publication Draft
ID sylw: 65250
Derbyniwyd: 27/06/2014
Ymatebydd: Deeley Group Ltd
Asiant : Delta Planning
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
Deeley Group object to Policy H10 as it does not provide a sound basis for future development for the Growth Villages.
The policy is too narrow and inflexible, provides no choice and adopts an unsustainable approach to the provision of housing for the Growth Villages.
In particular, it is considered that new housing should not only be provided on the sites shown on the Policies Map for the Growth Villages, as there are clearly other suitable sites that can assist in meeting the District's housing requirements.
Deeley Group object to Policy H10 as it does not provide a sound basis for future development for the Growth Villages.
The policy is too narrow and inflexible, provides no choice and adopts an unsustainable approach to the provision of housing for the Growth Villages. In particular, it is considered that new housing should not only be provided on the sites shown on the Policies Map for the Growth Villages, as there are clearly other suitable sites that can assist in meeting the District's housing requirements.
The Policy provides a clear opportunity to bring some flexibility to the plan and allow additional growth in appropriate locations, through a criteria based approach. As set out in objections to Policy DS10, it is considered that there is a shortfall in housing provision proposed in this Plan and a logical way to help accommodate this shortfall is from other suitable sites that may come forward within or adjacent to the Growth Villages. Whilst not all sites will be suitable Policy H10 as currently drafted is 'unsound' and should be more flexible in allowing other sustainable sites to come forward in the plan period within the Growth Villages.
Accordingly it is suggested that the policy be re-named as "Policy H10: Growth Villages", and be reworded as follows:
Housing development for Growth Villages will be permitted on sites allocated in the plan and on other suitable sites where the proposals are in accordance with the following criteria:
a) the site is within or immediately adjacent to the village envelope boundary, is outside of the Green Belt, and would have no significant adverse harm to the landscape setting of the Village or on any ecological and heritage interests;
b) the site can provide suitable vehicular access and good connectivity with existing village facilities and the public footpath network;
c) the design, layout and scale of development is established through a collaborative approach to design and development, involving District and Parish Councils, Neighbourhood Plan Teams, local residents and other stakeholders;
d) the housing mix of schemes reflects any up to date evidence of local housing need through a parish or village Housing Needs Assessment, including those of neighbouring parishes. Beyond meeting this need, or in the absence of a local Housing Needs Assessment, the scheme reflects the needs of the District as set out in the latest Strategic Housing Market Assessment; and
e) on sites allocated for 50 or more dwellings, the proposals include a phasing strategy whereby the homes are delivered across the plan period in phases of no more than 50 dwellings at a time over a period of 5 years, starting from the date the development commences on site.
Gwrthwynebu
Publication Draft
ID sylw: 65293
Derbyniwyd: 25/06/2014
Ymatebydd: A C Lloyd Homes Ltd
Asiant : Delta Planning
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
A C Lloyd Homes object to Policy H10 as it does not provide a sound basis for future development for the Growth Villages. The policy is too narrow and inflexible, provides no choice and adopts an unsustainable approach to the provision of housing for the Growth Villages. In particular, it is considered that new housing should not only be provided on the sites shown on the Policies Map for the Growth Villages, as there are clearly other suitable sites that can assist in meeting the District's housing requirements.
A C Lloyd Homes object to Policy H10 as it does not provide a sound basis for future development for the Growth Villages.
The policy is too narrow and inflexible, provides no choice and adopts an unsustainable approach to the provision of housing for the Growth Villages. In particular, it is considered that new housing should not only be provided on the sites shown on the Policies Map for the Growth Villages, as there are clearly other suitable sites that can assist in meeting the District's housing requirements.
The Policy provides a clear opportunity to bring some flexibility to the plan and allow additional growth in appropriate locations, through a criteria based approach. As set out in objections to Policy DS10, it is considered that there is a shortfall in housing provision proposed in this Plan and a logical way to help accommodate this shortfall is from other suitable sites that may come forward within or adjacent to the Growth Villages. Whilst not all sites will be suitable, and in some cases there will be Green Belt limitations, Policy H10 as currently drafted is 'unsound' and should be more flexible in allowing other sustainable sites to come forward in the plan period within the Growth Villages.
Accordingly it is suggested that the policy be re-named as "Policy H10: Growth Villages", and be reworded as follows:
Housing development for Growth Villages will be permitted on sites allocated in the plan and on other suitable sites where the proposals are in accordance with the following criteria:
a) the site is within or adjacent to the settlement boundary, is outside of the Green Belt, and would have no significant adverse harm to the landscape setting of the Village or on any ecological and heritage interests;
b) the site can provide suitable vehicular access and good connectivity with existing village facilities and the public footpath network;
c) the design, layout and scale of development is established through a collaborative approach to design and development, involving District and Parish Councils, Neighbourhood Plan Teams, local residents and other stakeholders;
d) the housing mix of schemes reflects any up to date evidence of local housing need through a parish or village Housing Needs Assessment, including those of neighbouring parishes. Beyond meeting this need, or in the absence of a local Housing Needs Assessment, the scheme reflects the needs of the District as set out in the latest Strategic Housing Market Assessment; and
e) on sites allocated for 50 or more dwellings, the proposals include a phasing strategy whereby the homes are delivered across the plan period in phases of no more than 50 dwellings at a time over a period of 5 years, starting from the date the development commences on site.
Gwrthwynebu
Publication Draft
ID sylw: 65342
Derbyniwyd: 25/06/2014
Ymatebydd: Mr Carl Stevens
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
Green belt areas in these villages should be protected at all costs
Green belt areas in these villages should be protected at all costs
Gwrthwynebu
Publication Draft
ID sylw: 65449
Derbyniwyd: 27/06/2014
Ymatebydd: Sworders
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
We support the principle of part 1 of this policy, however, the current wording is unsound as it does not enable the delivery of the development strategy.
It presents no alternatives where such stakeholder groups do not exist or where agreement cannot be reached. The policy is undeliverable because it provides no scope for the allocated sites in Growth Villages to be delivered, other than via collaboration with the various stakeholders.
This will fall foul of the NPPF paragraph 47 requirement to provide five years worth of deliverable sites and paragraph 182 requirement to be deliverable.
We support the principle of part 1 of this policy to establish design, layout and scale through a collaborative approach with various stakeholders, however, the current wording is unsound as it does not enable the delivery of the development strategy.
It presents no alternatives where such stakeholder groups, for example Neighbourhood Plan Teams do not exist or where agreement cannot be reached. The policy is undeliverable because it provides no scope for the allocated sites in Growth Villages to be delivered, other than via collaboration with the various stakeholders.
Whilst the policy does not state that the allocations must be delivered via a Neighbourhood Plan; if a Neighbourhood Plan Team exists or a Parish are intending to bring forward a Neighbourhood Plan it is unlikely that the Team/Parish Council would agree other than via a Neighbourhood Plan. Giving this much power to communities could have the effect of stalling much needed development.
Whilst we support the aspiration to enable local communities to shape their neighbourhood, this will not ensure delivery of sites and therefore assist in delivering the district's housing need.
The District Council has no control over the Neighbourhood Plan process and cannot compel communities to prepare Neighbourhood Plans or agree to the delivery of allocated sites through a collaborative approach. The NPPG states (Paragraph: 002 Reference ID: 41-002-20140306) that neighbourhood planning "is not a legal requirement but a right which communities in England can choose to use".
Even where Neighbourhood Plans are produced, they are not subject to the same rigorous tests of soundness as Local Plans, only that they fulfil the basic conditions set out in paragraph 8(2) of Schedule 4B to the Town and Country Planning Act 1990. The NPPF only requires Neighbourhood Plans to be in "general conformity with the strategic policies of the Local Plan" therefore, provided a Neighbourhood Plan does not plan for less development than stated in the Local Plan, it could be free to allocate alternative sites in favour of those which have been subject to the much more rigorous Local Plan tests of soundness.
Paragraph 182 of the NPPF does not apply to Neighbourhood Plans therefore there is no requirement for it to be deliverable. To rely on non-paragraph 182 compliant Neighbourhood Plan deliveries to fulfil the District's objectively assessed need would result in the Local Plan falling foul of paragraph 182.
The NPPG offers some additional guidance in relation to deliverability (Paragraph: 005 Reference ID: 41-005-20140306); it states that "If the policies and proposals are to be implemented as the community intended a neighbourhood plan needs to be deliverable." Deliverability therefore, whilst desirable, is not a requirement that the neighbourhood Plan must demonstrate it has satisfied, in order to pass examination.
Therefore, even if the required numbers do come forward through Neighbourhood Plans in good time; there is no guarantee that the allocations will be deliverable. Consequently, the Council cannot rely on 743 homes being delivered in the Growth Villages. This will fall foul of the NPPF paragraph 47 requirement to provide five years worth of deliverable sites and paragraph 182 requirement to be deliverable.
There is no proposed mechanism for review in the event that the Neighbourhood Plans not deliver a sufficient number of dwellings, nor is there a mechanism in the event of non-agreement with the various collaboration groups or where no such groups exist. The NPPG (Paragraph: 002 Reference ID: 12-002-20140306) states that "The Local Plan should make clear what is intended to happen in the area over the life of the plan, where and when this will occur and how it will be delivered." As drafted, the policy fails to do this.
We support parts 2) and 3) of the policy.
Gwrthwynebu
Publication Draft
ID sylw: 65478
Derbyniwyd: 27/06/2014
Ymatebydd: King Henry VIII Endowed Trust (Warwick)
Asiant : AMEC
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
The Trust recognises the positive intent of Policy 10 'Bringing forward allocated sites in the Growth Villages' but considers that as currently worded it would act to potentially jeopardise the successful delivery of housing sites as it effectively restricts house building in the Growth Villages to a maximum of 50 dwellings in any 5 year period based. We consider that the District Council has failed to recognise likely unintended negative consequences of such a policy restriction:
-construction activity being spread over a much longer period
-inefficient and fragmented improvements to and/or delivery of new infrastructure
-fragmented scheme designs if different developers build-out different parts of the original site.
Policy H10 is not in alignment with the presumption in favour of sustainable development nor does it accord with the intention of the NPPF to provide a significant boost to the supply of housing
see attachment
Cefnogi
Publication Draft
ID sylw: 65496
Derbyniwyd: 27/06/2014
Ymatebydd: Sarah Palmer
Asiant : Davies and Co
The criteria identified in the policy are reasonable and appropriate for allocated (and unallocated) housing sites in the Growth Villages. Our representations under other policies propose the allocation of a site at Red Lane, Burton Green for housing and it is confirmed here that it is accepted that such an allocation would be fully on the basis set out in this policy and its three criteria.
The criteria identified in the policy are reasonable and appropriate for allocated (and unallocated) housing sites in the Growth Villages. Our representations under other policies propose the allocation of a site at Red Lane, Burton Green for housing and it is confirmed here that it is accepted that such an allocation would be fully on the basis set out in this policy and its three criteria.
Gwrthwynebu
Publication Draft
ID sylw: 65531
Derbyniwyd: 27/06/2014
Ymatebydd: Sharba Homes Group
Asiant : PJPlanning
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
This policy puts unecessary obsticles in the way pof housing delivery contrary to the NPPF (paras 14, 47 and 154).
The first bullet point places unnecessary weight on the opinions of the stakeholders, transforming a material consideration into a development
plan policy where development may be stifled simply because it may
be seen as unwanted or unnecessary, for reasons contrary to other
aims and ambitions of the plan.
The second bullet point undue weight on the SHMA.Because the SHMA is not being subject to consultation or examination
before informing the plan, it should not be directly referenced in policy, and instead, a 'Policy On' approach should
be taken. Again, the policy fails to make a comparison on a detailed basis throughout the district, and provides no evidential basis to explain the imprecise approach taken.
The final bullet point create serious viability issues, who will be unable to develop strategic sites in a timely,and cost effective manner. This is in conflict with both Paragraphs 14 and 47 of the NPPF and will reduce the ability for there to be clear 'choice and competition for land', instead forcing developers to hold onto land for long periods before areas can be brought forward. the policy will will make surrounding areas undesiarble during prolonged construction periods and will add the development burdens. The policyu will also hamper the delivery of 5 year supply. The plicy is unjustified and unsound
Please see the attached representation submitted by PJ Planning on behalf of Sharba Homes Group
Cefnogi
Publication Draft
ID sylw: 65535
Derbyniwyd: 27/06/2014
Ymatebydd: Keith Wellsted
Local people should have their say and any development should be phased
Local people should have their say and any development should be phased
Gwrthwynebu
Publication Draft
ID sylw: 65575
Derbyniwyd: 25/06/2014
Ymatebydd: Mr Robert Cochrane
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
H28
Fails to comply with Planning and Compulsory Purchase Act 2004 - no provision for self build.
Transport policy fails to fully assess impact of increased traffic/congestion on Birmingham Road.
Doesn't consider effect on health of people in Budbrooke through air pollution/emissions.
Site area reduced but same number of houses reduced only by 10. Major highway safety concern. No local consultation on this. No integrity in plan. Govt. requires exceptional circumstances in Green Belt but there are none and infrastructure issues are incomplete
Plan not sustainable. Process confuses and angers people. Housing numbers unsound - old estimates being used so proposals could change without consultation as there is no time. Infrastructure provision not fully assessed, upgrades long overdue. flooding issues in many locations and schools are full. Planned destruction of 1100 year old town
Gwrthwynebu
Publication Draft
ID sylw: 65733
Derbyniwyd: 27/06/2014
Ymatebydd: Ms Myra Styles
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
H28
Fails to comply with Planning and Compulsory Purchase Act 2004 - no provision for self build.
Transport policy fails to fully assess impact of increased traffic/congestion on Birmingham Road.
Doesn't consider effect on health of people in Budbrooke through air pollution/emissions.
Site area reduced but same number of houses reduced only by 10. Major highway safety concern. No local consultation on this. No integrity in plan. Govt. requires exceptional circumstances in Green Belt but there are none and infrastructure issues are incomplete
Plan not sustainable. Process confuses and angers people. Housing numbers unsound - old estimates being used so proposals could change without consultation as there is no time. Infrastructure provision not fully assessed, upgrades long overdue. flooding issues in many locations and schools are full. Planned destruction of 1100 year old town
see attached
Gwrthwynebu
Publication Draft
ID sylw: 65758
Derbyniwyd: 03/07/2014
Ymatebydd: Mr Steve Halliday
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
H28 Hatton Park
Validity of consultation process
Change of site without consultation with local community
Overall housing need
No exceptional circumstances for building in Green Belt
No assessment for health and safety of people living on Birmingham Road
see attached
Gwrthwynebu
Publication Draft
ID sylw: 65992
Derbyniwyd: 27/06/2014
Ymatebydd: Barwood Development Securities Ltd
Asiant : HOW Planning LLP
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
Barwood object to the inflexible approach taken to bringing forward allocated sites
in the Growth Villages through Policy H10.
Barwood consider that the approach taken in clause (c) is overly restrictive. By the very fact that the Council has allocated a site for development, the site's
deliverability is reinforced. The Council should not therefore put a limit of the
number of dwellings which can be delivered per annum. This approach is
restrictive and does not follow the Framework's positive growth message.
Barwood suggest that this clause is removed from the Policy H10.
See attachment
Gwrthwynebu
Publication Draft
ID sylw: 66044
Derbyniwyd: 27/06/2014
Ymatebydd: Home Builders Federation Ltd
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
Within this policy is a stipulation that sites allocated for 50 or more dwellings must be phased with ''no more than 50 dwellings at a time over a period of 5 years''. This is inappropriate, as the fundamental thrust of government policy is the need to boost significantly the supply of housing.
The phasing proposal within this policy means that the Council will not be meeting its objective assessment of housing needs.
See attachment
Gwrthwynebu
Publication Draft
ID sylw: 66110
Derbyniwyd: 27/06/2014
Ymatebydd: CALA Homes (mids) Ltd
Asiant : Cerda Planning Ltd
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
Objections are raised to this policy, in particular to part (c). Restricting developments of 50 or more homes to phasing construction of a development over 5-years is contrary to the NPPF which seeks to make up the shortfall of housing immediately and to boost significantly the housing supply.It has no consideration to the practicalities of building out a site, the finances involved or the prolonged disturbance to existing residents.No evidence has been provided as to why this phasing is necessary in terms of social cohesion and no evidence is available to demonstrate that the impacts on viability have been considered.
See attachment
Gwrthwynebu
Publication Draft
ID sylw: 66119
Derbyniwyd: 27/06/2014
Ymatebydd: Mr and Mrs Martin
Asiant : Cerda Planning Ltd
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
Objections are raised to this policy, in particular to part (c). Restricting developments of 50 or more homes to phasing construction of a development over 5-years is contrary to the NPPF which seeks to make up the shortfall of housing immediately and to boost significantly the housing supply. It has no consideration to the practicalities of building out a site, the finances involved or the prolonged disturbance to existing residents. Limiting to approximately 10 homes a year will have a huge detrimental impact on sales, contractors, financing, viability, housing delivery and the social and physical environment.
See attachment
Gwrthwynebu
Publication Draft
ID sylw: 66206
Derbyniwyd: 27/06/2014
Ymatebydd: Bloor Homes Midlands
Asiant : Marrons Planning
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
H10 criterion b) requires the housing mix of rural schemes to reflect local need through a parish or housing needs assessment. However this does not take into account demographic trends, market trends or the local needs of different groups in the community as set out in the NPPF.
It also states that beyond meeting local need or where an assessment does not exist the mix should reflect the needs set out in the latest SHMA. However the evidence in the latest SHMA is based on 2011 information and is district wide. It does not reflect the local demand of the parish or village as required by the NPPF
see attached
Gwrthwynebu
Publication Draft
ID sylw: 66207
Derbyniwyd: 27/06/2014
Ymatebydd: Bloor Homes Midlands
Asiant : Marrons Planning
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
Objects to phasing of development of over 50 dwellings at a rate of 50 dwellings per 5 years. This will not boost housing in a district where a 5 year supply cannot be demonstrated It is contrary to the NPPF, will have unintended consequences on the character of villages and not support social cohesion. This approach would result in the phased delivery of infrastructure which may result in new residents being isolated from the existing settlement and services.
see attached
Gwrthwynebu
Publication Draft
ID sylw: 66217
Derbyniwyd: 27/06/2014
Ymatebydd: Savills
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Ydi
Dyletswydd i gydweithredu? Nac Ydi
The reduction in housing capacity in Kingswood from between 100 - 150 in the Revised Development Strategy to 43 in the Publication Draft Local Plan has not been justified.
see attached
Gwrthwynebu
Publication Draft
ID sylw: 66553
Derbyniwyd: 27/06/2014
Ymatebydd: Taylor Wimpey
Asiant : Barton Willmore
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
Object to part c and use of arbitary figure.
would work with the Council to bring sites forward in a manner which suited both parties, the commercial realities of delivering a site mean that restricting a delivery on site to only 50 dwellings over a five-year period is not feasible. Furthermore, there seems to be no evidence base which supports this figure as to why at this point there is an impact and whether it is significantly increased or decreased from a site of 40 or 60 dwellings.
It would clearly not be viable for a national house builder to build out schemes at a rate of 10 dwellings per annum in order to comply with this policy as there is inevitably an additional resource from being on a site for such an elongated period.
Site H21 at Barford is allocated for 60 dwellings and with average build rates of 30 dwellings per year this could realistically be built in between 2 2.5 years.
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66753
Derbyniwyd: 27/06/2014
Ymatebydd: Mr Edward Walpole-Brown
Asiant : Brown and Co
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
Policy should refer to a consultative rather than collaborate approach in involving Parish Council and Neighbourhood Plan Teams to ensure judgements are made on sound planning grounds rather than negative and over prescriptive views. Housing mix should refer to the wider area rather than just local housing need with regard to parishes and villages. It is unnecessarily prescriptive to indicate that sites of more than 50 houses need to be developed over more than 5 years.
This is not indicative of how sites tend to get developed and managed by developers and it should be more needs and market assessed to make sure that sites can be delivered in good time and comprehensively.
See attached
Cefnogi
Publication Draft
ID sylw: 66771
Derbyniwyd: 26/06/2014
Ymatebydd: Burman Brothers
Asiant : Nigel Gough Associates Ltd
Important that this policy reflects requirements of market fully. House builders are in best position to decide on range and mix of housing taking on board Council's desire, where appropriate, of any special Local Housing Need but policy should not be restrictive or unreasonable. Policy as worded is not reasonable and needs further clarification on this point.
Reference to Hatton Park restricts the number of dwellings to be built in phase one to 50 our of 80. This is ridiculous because it seeks to influence the market, the build period and economics of development on the site. No rational planning reason given and is Council interfering with release of sites and almost reverse phasing across H10 allocations contrary to NPPF and provides wholly uneconomic and restrictive policy element that should be deleted.
see attached