Question 24 relates to the proposed policy on comprehensive development. The policy states that comprehensive proposals for the development of sites will normally be required, including where sites are in multiple ownerships.

The policy goes on to state:

In exceptional circumstances, proposals for part of a site may be permitted, but only where it demonstrably has regard to, and facilitates, an integrated scheme for development of the entire site. This will include the provision of appropriate uses, affordable housing, green space/open space and other infrastructure (including
sustainable drainage), taking account of the site as a whole.

The requirement for 'comprehensive proposals' for the development of sites that are in multiple ownerships is considered to be unduly restrictive, and potentially unachievable. Notably, sites in multiple ownerships, including 'Land at Blackfriars, Battle' (in which TWSE has land interest) will need to be subject to a number of separate planning applications. It will therefore be necessary to approve proposals "for part of a site" and exceptional circumstances should not be required to allow this.

It is acknowledged that each individual application should not hinder the deliverability of wider land parcels, and should be developed in a comprehensive manner whereby the proposals have regard to each other. In order to achieve this, the appropriate planning policy mechanism (whether it be the Dasa or Neighbourhood Plan) can set out criteria for each site allocation. Individual planning submissions can then be required to demonstrate, through a design statement or alternative document, how the criteria are met. This approach will provide suitable 'flexibility', in accordance with the NPPF.