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Policy 7.5 Small Scale Windfall Housing Development
Representation ID: 24175
Received: 22/03/2021
Respondent: Christchurch Holland
Number of people: 2
Agent: Sequence (UK) Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Sequence broadly supports the purpose of draft Policy 7.5 Small Scale Windfall Housing Development to permit small-scale residential development adjacent to Settlement Boundaries or within or adjacent to a recognised group of dwellings.
However Sequence consider that the policy as currently worded is not sound as it is not justified as an appropriate strategy (National Planning Policy Framework (NPPF) paragraph 39b) or effective (paragraph 39c). Bullet point 1 of draft Policy 7.5 restricts cumulative development to 3 or 5 dwellings (dependent on the size of the Parish), over the plan period.
Sequence are concerned that this will raise significant challenges with the implementation of Policy 7.5. By limiting the amount of development over the plan period, this creates a 'first past the post' system for windfall development in a Parish, which will artificially restrict the ability for sustainable development to come forward.
On the one hand, the policy establishes that the Settlement Boundaries are not immutable. However on the other hand, in effect, once the limit of 3-5 dwellings has been met within a Parish; development that is otherwise in accordance with Policy 7.5 and sustainable in all other respects, would be refused due to previous small-scale development having already been consented. This also takes no account of the comparative merits of development proposals and sites - simply once the artificial limit has been met, any subsequent applications would be contrary to the policy as currently drafted.
Sequence are also concerned that Policy 7.5 as currently drafted will have unintended consequences whereby a number of competing schemes may be submitted in any one Parish creating challenges for Development Management and comparisons made between sites rather than judging each site on its merits and in accordance with the Local Plan.
Sequence therefore contend that this is not an appropriate strategy, and accordingly, it is not justified, nor effective, and is not sound.
The main revision should be to bullet point 1 of Policy 7.5 so that the restriction on development over the plan period is lifted. However Sequence recognise that the aspiration of the policy is for small-scale windfall development and, therefore, that each development is restricted to 3 or 5 new homes dependant on the size of the Parish.
In addition it is noted that Policy 7.5 uses the reference 'Development Boundary' rather than 'Settlement Boundary', inconsistent with its use elsewhere within the Draft Strategy and the Part 2 Pre-Submission Draft Sites Plan.
Sequence therefore respectfully suggest that the wording of the policy is updated as follows:-
'POLICY 7.5 – SMALL SCALE WINDFALL HOUSING DEVELOPMENT
Small scale residential development will be permitted adjacent to a settlement boundary or on sites within or adjacent to a recognisable group of dwellings where:
• Development permitted under this policy will be no more than 3
dwellings in small parishes or 5 dwellings in larger parishes (as defined in appendix
7); and
• The proposal respects the form and character of the settlement; and
• The proposal would result in no adverse impact on the landscape and natural
environment; and
• The proposal accords with other relevant Local Plan policies
Positive consideration will be given to self and custom build.'
The revision from Development Boundary to Settlement Boundary will resolve this inconsistency and prevent any confusion.
The revision to bullet point 1 will see an appropriate strategy for windfall sites to be delivered and accordingly a justified and sound approach with planning applications brought forward under this policy considered on their merits and not artificially restricted due to previous or competing proposals. This will also allow for quicker delivery of small sites to meet housing need in accordance with Policy 68 of the NPPF.
The submissions comprise the following:-
- Response to Part 1 Policy 7.5;
- Response to Part 2, Redenhall with Harleston Sites Plan;
- Continuation sheet with regard to question 5 of the Part 2 response;
- Site Location Plan;
- Suggested amendment to the Settlement Boundary for the Redenhall with Harleston Sites Plan – Option 1; and
- Suggested amendment to the Settlement Boundary for the Redenhall with Harleston Sites Plan – Option 2.
Object
Publication
Settlement Map
Representation ID: 24176
Received: 22/03/2021
Respondent: Christchurch Holland
Number of people: 2
Agent: Sequence (UK) Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Sequence consider that the Draft Sites Plan for Redenhall with Harleston is not 'sound ' as the approach is not justified or effective under paragraph 35, part b of the National Planning Policy Framework (NPPF).
Specifically Sequence consider that the position of the Settlement Boundary is not an appropriate strategy taking into account the reasonable alternatives.
The Redenhall with Harleston proposals map demonstrates an inconsistent approach to the inclusion of land within the Settlement Boundary. Employment allocation HAR7 is included within the Settlement Boundary, notwithstanding that it is an undeveloped site. However, by contrast housing allocation GNLP 2106 and mixed use allocation GN2136 are not included within the Settlement Boundary.
Sequence consider that this inconsistent approach is not sound as it not justified as an appropriate strategy. Sequence contend that the reasonable alternative is to include all proposed allocations within the Settlement Boundary as a consistent approach.
A suggested alternative to the Settlement Boundary is shown on the enclosed plan (drawing reference: 2021.02.12.Settlement_Boundary_Option1).
(continued..... see continuation sheet)
Sequence consider that the Settlement Boundary for the Redenhall with Harleston Policy Map should be redrawn to include draft allocations GNLP2108 and GNLP2136 to provide a robust and defendable boundary to the A143 that will endure over the plan period as well as a more coherent connection to the Settlement Boundary to the west of GNLP2108. These suggested revisions are shown on the enclosed drawing reference 2021.02.12.Settlement_Boundary_Option1.
This revision will ensure a sound and justified approach. The current approach is not justified, as it is not an appropriate strategy given the inconsistent treatment of the draft allocations in terms of their location within the Settlement Boundary and the contrived nature of the current drafting. The revisions shown on drawing reference 2021.02.12.Settlement_Boundary_Option1 will deliver an appropriate strategy.
The revisions shown on drawing reference 2021.02.12.Settlement_Boundary_Option1 will deliver an appropriate strategy with respect to the Redenhall with Harleston Draft Sites Plan but similar revisions will need to be made to other Part 2 Draft Sites Plans to ensure the plan is sound overall given the current inconsistencies throughout.
An alternative proposal has also been put forward on drawing reference 2021.02.12.Settlement_Boundary_Option2. This will specifically address the drafting of the Settlement Boundary to the west of GNLP2108, which is illogical and therefore not an appropriate strategy. Redrafting the Settlement Boundary as shown on drawing ref: 2021.02.12.Settlement_Boundary_Option2 will see a sound and justified approach.
The submissions comprise the following:-
- Response to Part 1 Policy 7.5;
- Response to Part 2, Redenhall with Harleston Sites Plan;
- Continuation sheet with regard to question 5 of the Part 2 response;
- Site Location Plan;
- Suggested amendment to the Settlement Boundary for the Redenhall with Harleston Sites Plan – Option 1; and
- Suggested amendment to the Settlement Boundary for the Redenhall with Harleston Sites Plan – Option 2.
