Core Strategy Consultation on Strategy Directions 2008

Object

Representation ID: 19905

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

The Core Strategy should ensures that there is flexibility to enable the delivery of housing across the District at a sustainable rate in line with the South East Plan annual requirement.

The Council's continual reliance on a single large-scale development is wholly dependent on the delivery of major infrastructure. The Core Strategy should contain sufficient flexibility to enable the delivery of other development sites to meet any shortfall against the minimum housing requirement. Need for the Core Strategy to enable delivery from other short / medium term sites.

The availability of brownfield sites, will likely to reduce in the short term. Small scale greenfield sites should be promoted, which generally have lower development costs, in the early part of the plan period.

Object

Representation ID: 19906

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

Disappointing that SHLAA not made available at the level of development which it projects will occur. Without sight of the SHLAA, assumptions made by the Council cannot be commented on, and the robustness of the Strategy cannot be accurately assessed.

Preferred Option 2 is supported in principle, however does not take account of the constraints.It is doubtful that the projected housing numbers at the four locations as set out in the table are realistic.
Option 3 provides the clear indication of where development is likely to continue as this represents where development has recently been delivered. In all therefore, it is considered that a more realistic approach would be a hybrid of Options 2 and 3.

Object

Representation ID: 19907

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

Subsection (a) refers to a dwelling range of between 5,600 - 5,850 to be provided. It is misleading as this could be interpreted as a minimum and maximum requirement. The imposition of a maximum requirement would be in conflict with the South East Plan It should be clearly noted that both figures are minimum figures.
subsection (b), the Core Strategy should not seek to unduly restrict the delivery of development.

Whilst the principle behind subsection (c) is supported, greenfield land is not supported which represents a very important source of housing land supply. Objection to the wording in paragraph 5.65 which suggests that Greenfield development should be considered as the last option. (c) should acknowledge the contribution that greenfield development can provide in meeting the District's housing requirement.

Object

Representation ID: 19908

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

Subsection (g) is generally supported, although, the use of the term "limited growth" is objected to. It would be more appropriate to remove the term "limited growth" and replace with an acknowledgement that growth in the rural villages should be in line with the South East Plan's housing requirement for the rest of District area.
It is clear that the Council, in exercising Policy ST5 (and not Policy ST2 as referred to in paragraph 5.70) of the South East Plan, is seeking to adopt a development strategy that falls below the "Rest of District" housing requirement set out by the South East Plan due to reason of sustainability. It is not entirely clear whether the Council can demonstrate this.

Object

Representation ID: 19909

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

iii) Future Allocations and Windfall Sites
Object/Comment

The information referred to in paragraph 5.72, which is set out in Appendix 3, is based on a number of assumptions regarding the deliverability of both large and small committed sites, which together amount to around 1,330 dwellings.
It is highly likely that the remaining housing requirement will increase based on an initial assessment of those committed sites relied upon.
Appendix 3 is reliant on all current allocated sites being carried forward into the LDF. Many have not been subject to planning applications since adoption of the Local Plan and as such casts doubt over the deliverability of those sites.

Support

Representation ID: 19910

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

Croudace wholly supports the Council's acknowledgement that the release of allocations should not be withheld arbitrarily. This supports the need for greater flexibility to allow the release of development sites in order to respond to any shortfalls.

Object

Representation ID: 19911

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

Croudace welcomes the Council's acceptance of the implications associated with the delivery of the Link Road on the overall development strategy. Whilst Croudace supports the release of sites phased later in the Plan to address any potential shortfall arising from further delays in the Link Road, the Council continues to be to restrictive by stating that allocations in higher order service centres will be prioritised. This goes against the Council's acceptance that 'Distribution Option 2' should not be seen in isolation and that the other options have their own credentials. In the event of a shortfall, the most deliverable site(s) should be released in order to address the shortfall as soon as possible.

Support

Representation ID: 19912

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

v) Development Boundaries
Support

The preferred option is supported in that it maintains the principle of development boundaries whilst also allowing for the review of existing development boundaries through the Site Allocations DPD.

Object

Representation ID: 19913

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

Paragraph 9.15 Croudace does not support the reliance placed on the Council's approximate estimates of development. It is not clear how this was calculated and, as required by Policy ST5 of the South East Plan, is not supported by a clear justification that a lower housing requirement is necessary to deliver the overall housing requirement for the District. Notwithstanding this concern, the level referred to in paragraph 9.15 is not reflective of the number of dwellings identified in the table on page 30, i.e. 1,300 dwellings which more accurately reflects the Council's preferred option towards Spatial Development.

Support

Representation ID: 19914

Received: 27/01/2009

Respondent: Croudace Strategic Ltd

Agent: Charles Planning Associates Limited

Paragraph 9.18
Support

The hybrid of preferred options is supported, and is considered to provide an appropriate development strategy for the villages which primarily concentrates development in the service centres but also has consideration for other criteria.