Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24443

Received: 07/12/2018

Respondent: Stapylton-Smith Family

Agent: Mr Geoff Megarity

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

While the development boundaries have been adopted under Core Strategy Policy OSS2, the policy within the DaSA does not provide scope for any alteration to development boundaries.

The process of preparing the DaSA which addresses the strategic policies of an out-of-date Core Strategy is unsound. The development boundaries, which are based on this evidence, should be reviewed as they currently limit the scope of the LPA to provide enough land to provide the significant increase in housing numbers required. The development boundaries are already out of date as the housing number has increased. Failure to review them will lead to confusion and inconsistency through the development management process.

As the Council's level of supply is below that required by the standard methodology, any policies relating to the delivery of housing and locations of development will be out of date.

Decision making must be based in line with the presumption in favour of sustainable development in line with the NPPF. Where there are policies that restrict development, but which are not highlighted in footnote 7 of paragraph 11 then these should be ignored.

Development boundaries across the whole district should be reviewed as the current policy and proposed DaSA is unsound.

Full text:

POLICY DIM2: DEVELOPMENT BOUNDARIES

4.9 While the development boundaries have been adopted under Core Strategy Policy OSS2, the policy within the DaSA does not provide scope for any alteration to development boundaries.

4.10 It is considered that the process of preparing the DaSA as a Local Plan document which addresses the strategic policies of an out-of-date Core Strategy is clearly unsound and is not a justified approach. It is considered that the development boundaries, which are based on this evidence, should be reviewed as they currently limit the scope of the LPA to provide enough land to provide the significant increase in housing number which is clearly required. The development boundaries are already out of date as the housing number has increased. Unless they are reviewed at this stage of the process, this is going to lead to confusion and inconsistency through the development management process.

4.11 Given that the Council's current level of supply is below that required using the standard methodology any policies relating to the delivery of housing and locations of development will be out of date.

4.12 Decision making on applications must be based in line with the presumption in favour of sustainable development in line with the NPPF. The PPG states that this is undertaken to "enable the development of alternative sites to meet the policy requirement". This suggests that where there are policies that restrict development, but which are not highlighted in foot note 7 of paragraph 11 then these should be ignored.

4.13 It is therefore considered that the development boundaries across the whole district should be reviewed as the current policy and proposed DaSA is unsound based on the plan has not been positively prepared, has not been justified, is not effective, and is inconsistent with National Policy. It therefore fails to meet the tests of soundness set out in paragraph 35 of the NPPF.