PARAGRAPH 4.10 LEVEL OF HOUSING GROWTH
1.1 These submissions relate to the proposed level of housing provision to be accommodated within the District's most sustainable village locations.
1.2 The Council acknowledge at paragraph 2.13 of its consultation report that its interim level of growth of 683 dwellings per annum set out within the Revised Development Strategy (June 2013) may be revised pending the findings of the Joint Strategic Housing Market Assessment (SHMA). This SHMA has now been published and, whilst its findings have yet to be tested, it concludes that the assessed housing need for the District is 720 dwellings per annum.
1.3 Over a plan period to 2031, the interim level of growth is therefore some 740 dwellings less than the most up-to-date evidence of assessed need. The SHMA also provides up-to-date evidence as to affordability, the numbers of newly forming households in need of affordable housing, as well as market signals.
1.4 The Council will therefore need to reconsider its future housing requirement figure in light of this evidence and the possible need to accommodate housing requirements from other authorities under the Duty to Co-operate. Furthermore, it will also need to test the implications of higher housing figures than that indicated in the Revised Development Strategy, and reconsider the level of growth proposed for the most sustainable villages. Bloor Homes have made submissions to the Council previously as to the need and potential for the rural area to accommodate higher levels of growth than envisaged within the Revised Development Strategy.
1.5 In this context, it is of concern that the Preferred Options set out within this consultation report have failed to even achieve the housing provisions made to the most sustainable villages (1,000 dwellings in total) as part of the interim level of growth within the Revised Development Strategy. The statement within paragraph 4.10 of this consultation report that the lower figure now proposed of 835 dwellings reflects environmental and access restrictions will need to be robustly demonstrated if this is to be taken forward into the Draft Local Plan and found 'sound'.
1.6 The Council will be aware of the relevant test within paragraph 14 of the National Planning Policy Framework (referred to as the 'Framework'). This requires that objectively assessed needs are met unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies of the Framework taken as a whole.
1.7 In respect of its land interests not allocated as Preferred Options, Bloor Homes do not consider the Council has demonstrated within its evidence base that the adverse impacts of their development would significantly and demonstrably outweigh the benefits. Moreover, having regard to paragraphs 17 and 70 of the Framework and the requirement to allocate land of lesser environmental or amenity value where consistent with other policies of the Framework, Bloor Homes do not consider the Preferred Options identified in some of the villages represent the most appropriate when assessed against their alternative land interests which are more consistent with the policies of the Framework. The evidence to support these statements is set out in within separate submissions.

1.1 These submissions relate to the proposals for meeting the housing provision for Hatton Park of 70 to 90 dwellings as set out within the Revised Development Strategy. These submissions need to be read in the context of Bloor Homes submissions in respect of paragraph 4.10.
1.2 Bloor Homes do not support the Council's Preferred Option for the village. The land north of Birmingham Road is not considered the most appropriate site for allocation when considered against the alternative discounted Option 2 (land between Hatton Park and Canal Road).
1.3 Having regard to the Council's evidence, the land north of Birmingham Road is considered to be of higher environmental and amenity value compared to Option 2. The land is acknowledged within the Council's evidence as being within a highly visible area, and that its development would negatively impact on the visual amenity of the Green Belt. This is a prominent site when viewed from within and outside of the village, and would extend built development along Birmingham Road into open countryside in what might be described as a more sensitive gap locally between the settlement and the town of Warwick.
1.4 The land north of Birmingham Road is also of significant environmental value in the role it plays in contributing to the integrity of the Ancient Woodland and potential Local Wildlife Site (Smith's Covert) to the immediate north of the site. The land represents the only physical link between the Ancient Woodland and open countryside.
1.5 The eastern boundary of the land north of Birmingham Road is also formed by the original 'drive' to the former King Edward VII Memorial Sanatorium. The existing avenue of trees along this 'drive' is of historical significance to the area, and as such is a heritage asset.
1.6 The land to the north of Birmingham Road is therefore of significant visual, ecological and historic value. Moreover, its development is only assessed as potentially suitable by the Council with 'substantial buffering'. No information is provided as to how large the buffering would need to be to retain the integrity of these assets, however, they would clearly require a significant proportion of the land to be kept open.
1.7 Given the need also to provide adequate distance separation from the adjoining residential properties within Hatton Park and an appropriate environmental buffer from the Birmingham Road, a significant proportion of the land on all four sides is acknowledged as not suitable for development due to its environmental and amenity value.
1.8 In comparison, the value of Option 2 is not considered of such significance. Whilst the canal towpath to the south of the site has some ecological value as a corridor for wildlife (although it is not formally designated), a substantial tree belt already exists along this boundary which would be retained, enhanced and managed as part of any development.
1.9 The Council's evidence acknowledges that this tree belt provides 'good tree cover' and forms an 'important setting for the canal and its flight of locks', separating the locks physically and visually from the site. The extent to which Option 2 therefore contributes to the integrity of the ecological value of the canal towpath, or the amenity value of the locks themselves is considered very limited. Moreover, as a general principle, it is noted that the Council have identified preferred options on other greenfield sites alongside the canal at Lapworth and Radford Semele in similar circumstances.
1.10 Having regard to the Council's evidence of the wider landscape and ecological value of the site, particularly its role as a green link or buffer, an assessment has been undertaken of the extent of harm that might be caused by the development of the site on the character and value of the wider area. This concludes that the site is considered to be appropriate for development in landscape and visual terms due to its visual containment (particularly with the retention of the belt of vegetation alongside the canal), its ability to retain important green functions and key visual links as part of any development layout, and its opportunity to consolidate the surrounding built form.
1.11 Paragraphs 17 and 110 of the National Planning Policy Framework require plans to allocate land of the least environmental or amenity value. Having regard to the evidence, the land north of Birmingham Road is not considered to be of lesser environmental value when compared to Option 2.
1.12 Paragraphs 17 and 110 also require consideration to be given to whether the development of the site would be consistent with other policies of the Framework. In this context, particular regard must be given to the requirement of paragraph 28 of the Framework for plans to support a prosperous rural economy.
1.13 The development of Option 2 is considered more consistent with the policies of the Framework than the Preferred Option for the following reasons.
1.14 Option 2 is better located in terms of its proximity to village services and facilities, such as the village shop, village halls, pubs, church, Hatton Locks and visitor facilities, and primary school (as shown on the plan submitted separately of the facilities within the area). Furthermore, the ability of the development to provide a safe means of pedestrian access across the Birmingham Road will ensure that walking or cycling are attractive options for residents of the development to access the shop and village hall within Hatton Park.
1.15 Development of Option 2 is therefore more likely than the Preferred Option to enhance and maintain the vitality of village services as required by paragraph 28 of the Framework, and also noted as a key requirement for the Council in allocating development to the rural area. Moreover, its location will ensure the need to travel will be minimised and opportunities for sustainable transport modes maximised as required by paragraphs 34 and 55 of the Framework.
1.16 The development of Option 2 is also able to add to the built form of the village in a way that improves the way it functions, as required by paragraph 64 of the Framework. The development can deliver improved access for pedestrians and cyclists to the canal locks facilities from Hatton Park by providing a more direct and safer link across the Birmingham Road and through the new development (as shown on the layout plan submitted separately). In addition, the provision of a new junction for Brownley Green Lane with Birmingham Road will improve road safety and reduce speeds of vehicles travelling through the village.
1.17 These proposals will improve the safety and convenience for residents and visitors going between Hatton Park and the canal locks facilities and footpaths beyond which will improve the way the settlement functions. Furthermore, these proposals will successfully integrate the development with the village as required by paragraphs 61 and 70 of the Framework.
1.18 The development of Option 2 also has the potential to incorporate an area of car parking to serve visitors to the canal network as well as a an alternative vehicular access to the locks complex. This would provide additional parking and means of access to the canal which could reduce or even potentially remove all visitor traffic from using Canal Road and its existing junction with the Birmingham Road. The Council will be aware that it is recognised within the Parish Plan that this is a junction requiring improvements to address safety issues. Again, therefore, the development of Option 2 has the potential to make a significant contribution to safety within the village and the way in which it functions.
1.19 Furthermore, the above proposals for improved linkages and access that would form part of the development of Option 2 will have a significant positive impact on rural tourism and leisure facilities which will be of benefit to local businesses and communities. The allocation of this site would therefore be entirely in accordance with paragraph 28 of the Framework, in so far as supporting rural economic growth.
1.20 In comparison, there is little detail provided in the consultation report as to how the Preferred Option will improve the way Hatton Park functions or how it will be integrated with the settlement. The development of the Preferred Option with its primary access onto Birmingham Road to the south east of the village has the potential to 'turn its back' on the village and encourage its residents to travel to Warwick or Hampton Magna for their day-to-day needs. Moreover, the requirement for a 'substantial buffer' to the north of the site adjoining the Ancient Woodland will limit the extent to which the development can integrate with the existing village.
1.21 Its development is therefore unlikely to improve the way the village functions, and is less likely to enhance or maintain village services, or contribute towards economic growth in the area. The development of the Preferred Option would therefore result in adverse impacts when assessed against the policies of the Framework.
1.22 Bloor Homes do not therefore consider the Preferred Option represents the most appropriate when considered against the alternative, Option 2.
1.23 Furthermore, Bloor Homes do not consider that there are any adverse impacts of the development of Option 2 which would significantly and demonstrably outweigh the benefits when assessed against the policies of the Framework as a whole.
1.24 Option 2 is within the control of Bloor Homes and is deliverable as defined in the Framework (footnote 11 of page 12). The land is available for development now, technically developable (a site assessment report is submitted separately identifying the ability of the land to be developed), viable, and is in a suitable location for the reasons set out above. Initial master planning demonstrates that the quantum of development (70 to 90 dwellings) and associated land uses, including suitable open spaces, buffers, and a new access road and parking can be provided on the site. An illustrative masterplan is submitted with these representations to demonstrate how the site might be developed. Further details will be shared with the Council as the master planning work progresses and prior to the publication of the draft Plan.
1.25 Bloor Homes therefore respectfully request the Council identify Option 2 as an allocation within their Draft Local Plan recognising that the site is of lesser environmental value, and that its development would meet a number of objectives of the Framework.

1.1 These submissions relate to the proposals for meeting the housing provision for Bishop's Tachbrook of 100-150 dwellings as set out within the Revised Development Strategy. These submissions need to be read in the context of Bloor Homes submissions in respect of paragraph 4.10.
1.2 Bloor Homes support the Council's Preferred Option for the village as the land to the south of school. The land is within the control of Bloor Homes and is deliverable as defined in the Framework (footnote 11 of page 12). The land is available for development now, technically developable, viable, and is in a suitable location in that it is:
* of lesser environmental value, having regard to the evidence, compared to other options in accordance with paragraph 17 of the Framework;
* well located in relation to the village school, social club, recreation facilities, and shop, such that it can enhance and maintain their vitality, as well as ensuring the need to travel will be minimised and opportunities for sustainable transport modes maximised as required by paragraphs 34 and 55 of the Framework;
* able to add to the built form of the village in a way that improves the way it functions as required by paragraph 64 of the Framework, by providing opportunities for improved access to the school, allotments, social club and playing fields; and,
* capable of successfully integrating with the village through the creation of a number of vehicular or pedestrian access points as required by paragraphs 61 and 70 of the Framework.
1.3 Bloor Homes therefore consider this allocation represents the most appropriate when considered against the alternative options. Moreover, the development of this site has the potential to deliver a number of community aspirations as expressed by the Parish Council in relation to improving the environment and access both within and outside of the village.
1.4 The exact boundary of the allocation and the quantum of housing development that can be accommodated should be informed by more detailed master planning as noted in the consultation report. This work has commenced and initial plans shared with the Council. These suggest that the boundary as shown on the plan within the consultation report should be revised to create a more cohesive and suitable development.
1.5 The revised boundary would also offer the potential to accommodate a greater number of dwellings (up to 175 dwellings) without causing any adverse impacts when assessed against the policies of the Framework. An initial sketch plan is submitted demonstrating how this could be accommodated along with suitable environmental screening and a new access road. Further details will be shared with the Council as the master planning work progresses and prior to the publication of the draft Plan.
1.6 Bloor Homes therefore support the principle of the allocation of the land to the south of the school, and will continue to engage with the Council and Neighbourhood Plan Group as they prepare their respective draft Plans.

1.1 These submissions relate to the proposals for meeting the housing provision for Leek Wootton of 70 to 90 dwellings as set out within the Revised Development Strategy. These submissions need to be read in the context of Bloor Homes submissions in respect of paragraph 4.10.
1.2 Bloor Homes do not support the Council's Preferred Options for the village, and do not consider the strategy is deliverable or that the sites identified are the most appropriate for allocation when considered against the alternative options north and south of Hill Wootton Road.
1.3 The land at Woodcote House (Preferred Options sites 1 to 4) comprises of a Grade II listed building and its setting, as well as containing a significant number of protected trees and being designated a locally important historic park included in the Warwick District Local Register. Preferred Option 2 also adjoins the Leek Wootton Conservation Area.
1.4 The land at Woodcote House is clearly a heritage asset and of high environmental value. In accordance with paragraph 129 of the National Planning Policy Framework, the Council must identify and assess the particular significance of the asset before considering the impact of its proposals. No such assessment has been published by the Council in order to inform the consultation report, and the identification of the land at Woodcote House as a Preferred Option. The reference within the Council's evidence to requiring 'comprehensive master planning' and a 'sensitive approach' to development suggests that no assessment has yet to take place.
1.5 In this context and in accordance with paragraph 14 of the Framework, there is considerable uncertainty as to whether all of the land at Woodcote House can be developed due to the potential harm to a designated heritage asset. Moreover, there is also considerable uncertainty as to whether the land can deliver the number of dwellings proposed (75 in total). By way of example, Preferred Option 2 is identified for 10 dwellings and yet is bounded on two sides by public highway making the number of properties difficult to achieve given the need for development to enhance the character of the area and maintain appropriate distance separation standards.
1.6 It is considered therefore that the land at Woodcote House is unlikely to be able to satisfactorily accommodate 75 dwellings of an appropriate housing mix to meet the needs of the village without causing significant adverse impacts in respect of the historic environment and failing to achieve good design.
1.7 It is also noted the land is not currently available for development, although the landowner has indicated their intention to release some or all of the land for development. Notwithstanding the previous marketing exercise, it remains currently as operational land required by the Police Authority and as such there is a degree of uncertainty as to the timing and extent of release of land for development.
1.8 In this context, Bloor Homes do not therefore consider that a strategy within the draft Local Plan that places reliance on the housing provision for Leek Wootton being almost entirely met at Woodcote House would be found sound. There are significant doubts as to whether the plan would be effective in demonstrating it is deliverable in respect of development at Woodcote House. In accordance with paragraph 14 of the Framework, flexibility is required to ensure the assessed housing need and provision for Leek Wootton is met.
1.9 A further Preferred Option is identified (site 5) to the south of the village to accommodate 5 dwellings. Development of this site would extend a 'finger' of development away from the village, and its location would not satisfactorily integrate with the built form of the village as required by paragraph 61 of the Framework. This site would not therefore be a suitable location for development, and it would not represent sustainable development.
1.10 Paragraphs 17 and 110 of the National Planning Policy Framework require plans to allocate land of the least environmental or amenity value. Bloor Homes consider the land to the north and south of Hill Wootton Road is of lesser environmental value, and its development would not result in any significant adverse impacts.
1.11 The land has no environmental or historic designations, and is acknowledged by the Council as being of only medium landscape value recognising it is bounded on three sides by residential development, Hill Wootton Road and the A46. The land has also been surveyed and is considered of limited ecological value (see a technical appraisal of the land north of Hill Wootton Road submitted separately).
1.12 The Council's evidence refers to the land acting as an 'environmental buffer' to the A46, although this is not a designation within the adopted Local Plan and no justification is given as to why a buffer is required for the village. It is noted that similar land between the edge of Warwick and the A46 has been allocated for development previously (South West Warwick), and land between the edge of Kenilworth and the A46 is now proposed for development and not retained as an 'environmental buffer'.
1.13 Having regard to the evidence, the land north and south of Hill Wootton Road is therefore considered to be of lesser environmental value when compared to the Preferred Options.
1.14 The land (both north and south of Hill Wootton Road) is within the control of Bloor Homes and is deliverable as defined in the Framework (footnote 11 of page 12). In order to provide evidence to the Council on this matter, Bloor Homes have received a technical appraisal of the land to the north of Hill Wootton for a development of circa 40 homes. Its findings are also relevant to the land to the south and this appraisal is submitted separately to the Council.
1.15 The land is therefore available for development now, technically developable, viable, and is in a suitable location in that it is:
* well located in relation to village services and facilities, such that it can enhance and maintain their vitality, as well as ensuring the need to travel will be minimised and opportunities for sustainable transport modes maximised as required by paragraphs 34 and 55 of the Framework; and,
* capable of successfully integrating with the village in accordance with paragraph 61 of the Framework through extending built development along Hill Wootton Road up to a defensible boundary (the A46) and thereby avoiding harm to the wider countryside and setting of the village.
1.16 Bloor Homes acknowledge that development of the land will need to have regard to the impact of road noise as recognised within the Council's evidence. Noise monitoring and an assessment of the findings have been undertaken to inform these representations within the technical appraisal. This concludes that road noise is not considered likely to cause significant adverse impact, subject to satisfactory mitigation through consideration of an appropriate layout of development, internal layout, and acoustic glazing.
1.17 Bloor Homes have also assessed the highway implications of development of this area for up to 40 dwellings. Traffic generated from the development would not 'materially' increase levels on the road network, and could be safely and adequately accommodated by the existing footpath and road network and junctions. Furthermore, accommodating some of the housing provision for Leek Wootton in this location would have the benefit of spreading the impact of additional traffic on the junctions along Warwick Road. The Preferred Options at present will load the majority of additional traffic movements on an acknowledged sub-standard junction of Woodcote Lane with Warwick Road, and with poor pedestrian footways along Woodcote Lane.
1.18 The exact boundary of the land to be allocated and the quantum of housing development that can be accommodated needs to be informed by detailed master planning. This has commenced and will be shared with the Council as the master planning work progresses and prior to the publication of the draft Plan.
1.19 Bloor Homes do not therefore consider the Preferred Options represents the most appropriate allocation when considered against the alternative options, north and south of Hill Wootton Road.
1.20 Furthermore, Bloor Homes do not consider that there are any adverse impacts of the development of the land north and south of Hill Wootton Road which would significantly and demonstrably outweigh the benefits when assessed against the policies of the Framework as a whole.
1.21 Bloor Homes therefore respectfully request the Council identify land north and south of Hill Wootton Road as an allocation within their Draft Local Plan recognising that the land is of lesser environmental value, and is consistent with the policies of the Framework.

1.1 These submissions relate to the proposals for meeting the housing provision for Hatton Park of 70 to 90 dwellings as set out within the Revised Development Strategy. These submissions need to be read in the context of Bloor Homes submissions in respect of paragraph 4.10.
1.2 Bloor Homes do not support the Council's Preferred Option for the village. The land north of Birmingham Road is not considered the most appropriate site for allocation when considered against the alternative discounted Option 2 (land between Hatton Park and Canal Road).
1.3 Having regard to the Council's evidence, the land north of Birmingham Road is considered to be of higher environmental and amenity value compared to Option 2. The land is acknowledged within the Council's evidence as being within a highly visible area, and that its development would negatively impact on the visual amenity of the Green Belt. This is a prominent site when viewed from within and outside of the village, and would extend built development along Birmingham Road into open countryside in what might be described as a more sensitive gap locally between the settlement and the town of Warwick.
1.4 The land north of Birmingham Road is also of significant environmental value in the role it plays in contributing to the integrity of the Ancient Woodland and potential Local Wildlife Site (Smith's Covert) to the immediate north of the site. The land represents the only physical link between the Ancient Woodland and open countryside.
1.5 The eastern boundary of the land north of Birmingham Road is also formed by the original 'drive' to the former King Edward VII Memorial Sanatorium. The existing avenue of trees along this 'drive' is of historical significance to the area, and as such is a heritage asset.
1.6 The land to the north of Birmingham Road is therefore of significant visual, ecological and historic value. Moreover, its development is only assessed as potentially suitable by the Council with 'substantial buffering'. No information is provided as to how large the buffering would need to be to retain the integrity of these assets, however, they would clearly require a significant proportion of the land to be kept open.
1.7 Given the need also to provide adequate distance separation from the adjoining residential properties within Hatton Park and an appropriate environmental buffer from the Birmingham Road, a significant proportion of the land on all four sides is acknowledged as not suitable for development due to its environmental and amenity value.
1.8 In comparison, the value of Option 2 is not considered of such significance. Whilst the canal towpath to the south of the site has some ecological value as a corridor for wildlife (although it is not formally designated), a substantial tree belt already exists along this boundary which would be retained, enhanced and managed as part of any development.
1.9 The Council's evidence acknowledges that this tree belt provides 'good tree cover' and forms an 'important setting for the canal and its flight of locks', separating the locks physically and visually from the site. The extent to which Option 2 therefore contributes to the integrity of the ecological value of the canal towpath, or the amenity value of the locks themselves is considered very limited. Moreover, as a general principle, it is noted that the Council have identified preferred options on other greenfield sites alongside the canal at Lapworth and Radford Semele in similar circumstances.
1.10 Having regard to the Council's evidence of the wider landscape and ecological value of the site, particularly its role as a green link or buffer, an assessment has been undertaken of the extent of harm that might be caused by the development of the site on the character and value of the wider area. This concludes that the site is considered to be appropriate for development in landscape and visual terms due to its visual containment (particularly with the retention of the belt of vegetation alongside the canal), its ability to retain important green functions and key visual links as part of any development layout, and its opportunity to consolidate the surrounding built form.
1.11 Paragraphs 17 and 110 of the National Planning Policy Framework require plans to allocate land of the least environmental or amenity value. Having regard to the evidence, the land north of Birmingham Road is not considered to be of lesser environmental value when compared to Option 2.
1.12 Paragraphs 17 and 110 also require consideration to be given to whether the development of the site would be consistent with other policies of the Framework. In this context, particular regard must be given to the requirement of paragraph 28 of the Framework for plans to support a prosperous rural economy.
1.13 The development of Option 2 is considered more consistent with the policies of the Framework than the Preferred Option for the following reasons.
1.14 Option 2 is better located in terms of its proximity to village services and facilities, such as the village shop, village halls, pubs, church, Hatton Locks and visitor facilities, and primary school (as shown on the plan submitted separately of the facilities within the area). Furthermore, the ability of the development to provide a safe means of pedestrian access across the Birmingham Road will ensure that walking or cycling are attractive options for residents of the development to access the shop and village hall within Hatton Park.
1.15 Development of Option 2 is therefore more likely than the Preferred Option to enhance and maintain the vitality of village services as required by paragraph 28 of the Framework, and also noted as a key requirement for the Council in allocating development to the rural area. Moreover, its location will ensure the need to travel will be minimised and opportunities for sustainable transport modes maximised as required by paragraphs 34 and 55 of the Framework.
1.16 The development of Option 2 is also able to add to the built form of the village in a way that improves the way it functions, as required by paragraph 64 of the Framework. The development can deliver improved access for pedestrians and cyclists to the canal locks facilities from Hatton Park by providing a more direct and safer link across the Birmingham Road and through the new development (as shown on the layout plan submitted separately). In addition, the provision of a new junction for Brownley Green Lane with Birmingham Road will improve road safety and reduce speeds of vehicles travelling through the village.
1.17 These proposals will improve the safety and convenience for residents and visitors going between Hatton Park and the canal locks facilities and footpaths beyond which will improve the way the settlement functions. Furthermore, these proposals will successfully integrate the development with the village as required by paragraphs 61 and 70 of the Framework.
1.18 The development of Option 2 also has the potential to incorporate an area of car parking to serve visitors to the canal network as well as a an alternative vehicular access to the locks complex. This would provide additional parking and means of access to the canal which could reduce or even potentially remove all visitor traffic from using Canal Road and its existing junction with the Birmingham Road. The Council will be aware that it is recognised within the Parish Plan that this is a junction requiring improvements to address safety issues. Again, therefore, the development of Option 2 has the potential to make a significant contribution to safety within the village and the way in which it functions.
1.19 Furthermore, the above proposals for improved linkages and access that would form part of the development of Option 2 will have a significant positive impact on rural tourism and leisure facilities which will be of benefit to local businesses and communities. The allocation of this site would therefore be entirely in accordance with paragraph 28 of the Framework, in so far as supporting rural economic growth.
1.20 In comparison, there is little detail provided in the consultation report as to how the Preferred Option will improve the way Hatton Park functions or how it will be integrated with the settlement. The development of the Preferred Option with its primary access onto Birmingham Road to the south east of the village has the potential to 'turn its back' on the village and encourage its residents to travel to Warwick or Hampton Magna for their day-to-day needs. Moreover, the requirement for a 'substantial buffer' to the north of the site adjoining the Ancient Woodland will limit the extent to which the development can integrate with the existing village.
1.21 Its development is therefore unlikely to improve the way the village functions, and is less likely to enhance or maintain village services, or contribute towards economic growth in the area. The development of the Preferred Option would therefore result in adverse impacts when assessed against the policies of the Framework.
1.22 Bloor Homes do not therefore consider the Preferred Option represents the most appropriate when considered against the alternative, Option 2.
1.23 Furthermore, Bloor Homes do not consider that there are any adverse impacts of the development of Option 2 which would significantly and demonstrably outweigh the benefits when assessed against the policies of the Framework as a whole.
1.24 Option 2 is within the control of Bloor Homes and is deliverable as defined in the Framework (footnote 11 of page 12). The land is available for development now, technically developable (a site assessment report is submitted separately identifying the ability of the land to be developed), viable, and is in a suitable location for the reasons set out above. Initial master planning demonstrates that the quantum of development (70 to 90 dwellings) and associated land uses, including suitable open spaces, buffers, and a new access road and parking can be provided on the site. An illustrative masterplan is submitted with these representations to demonstrate how the site might be developed. Further details will be shared with the Council as the master planning work progresses and prior to the publication of the draft Plan.
1.25 Bloor Homes therefore respectfully request the Council identify Option 2 as an allocation within their Draft Local Plan recognising that the site is of lesser environmental value, and that its development would meet a number of objectives of the Framework.

PARAGRAPH 4.10 LEVEL OF HOUSING GROWTH
1.1 These submissions relate to the proposed level of housing provision to be accommodated within the District's most sustainable village locations.
1.2 The Council acknowledge at paragraph 2.13 of its consultation report that its interim level of growth of 683 dwellings per annum set out within the Revised Development Strategy (June 2013) may be revised pending the findings of the Joint Strategic Housing Market Assessment (SHMA). This SHMA has now been published and, whilst its findings have yet to be tested, it concludes that the assessed housing need for the District is 720 dwellings per annum.
1.3 Over a plan period to 2031, the interim level of growth is therefore some 740 dwellings less than the most up-to-date evidence of assessed need. The SHMA also provides up-to-date evidence as to affordability, the numbers of newly forming households in need of affordable housing, as well as market signals.
1.4 The Council will therefore need to reconsider its future housing requirement figure in light of this evidence and the possible need to accommodate housing requirements from other authorities under the Duty to Co-operate. Furthermore, it will also need to test the implications of higher housing figures than that indicated in the Revised Development Strategy, and reconsider the level of growth proposed for the most sustainable villages. Bloor Homes have made submissions to the Council previously as to the need and potential for the rural area to accommodate higher levels of growth than envisaged within the Revised Development Strategy.
1.5 In this context, it is of concern that the Preferred Options set out within this consultation report have failed to even achieve the housing provisions made to the most sustainable villages (1,000 dwellings in total) as part of the interim level of growth within the Revised Development Strategy. The statement within paragraph 4.10 of this consultation report that the lower figure now proposed of 835 dwellings reflects environmental and access restrictions will need to be robustly demonstrated if this is to be taken forward into the Draft Local Plan and found 'sound'.
1.6 The Council will be aware of the relevant test within paragraph 14 of the National Planning Policy Framework (referred to as the 'Framework'). This requires that objectively assessed needs are met unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies of the Framework taken as a whole.
1.7 In respect of its land interests not allocated as Preferred Options, Bloor Homes do not consider the Council has demonstrated within its evidence base that the adverse impacts of their development would significantly and demonstrably outweigh the benefits. Moreover, having regard to paragraphs 17 and 70 of the Framework and the requirement to allocate land of lesser environmental or amenity value where consistent with other policies of the Framework, Bloor Homes do not consider the Preferred Options identified in some of the villages represent the most appropriate when assessed against their alternative land interests which are more consistent with the policies of the Framework. The evidence to support these statements is set out in within separate submissions.