Local Plan 2011-2031 Proposed Submission Draft

We write on behalf of our client Chapter Housing, to make representations on the emerging 'Pre-Submission Publication Stage', which was published for consultation on 19th October 2016. In particular, we consider that the designation of site HE3 for employment use within the Local Plan and the Supporting Evidence which states that it 'does not meet the tests in the SHLAA' are both unsound. Please see document references and explanation below:

Local Plan 2011-2031 Proposed Submission October 2016
Paragraph 13.127
Policy ETC1
Site HE3

Strategic Housing Land Availability Assessment: 2016 Update
SHLAA ref: 363

The site is characterised by a group of poor quality light industrial units (please see images attached) and collectively, only 40 people are currently working throughout a 1.4ha combined area of land, reflecting a very low employment density. The site comprises 4 individual land titles, occupied both by owners and tenants. Due to these circumstances and low commercial demand, there is little incentive or scope for it to be redeveloped comprehensively for alternative employment uses which are fit for purpose. Some commercial uses, such as B8, would clearly be unsuitable on account of the location.

Our client believes that there is an opportunity for sustainable residential-led development due to its proximity to the railway station and is aware that NHDC has supported previous plans for this during the previous ten years. Please see paragraphs 7.2 to 7.5 of the Annual Monitoring Review. This indicates that over the plan period (2011-2031) the housing target is for 14,200 homes, equivalent to 710 homes per year and last year, only 180 homes were built. In order to reach these targets, the National Planning Policy Framework encourages the use of brownfield land over the greenbelt as reflected in paragraphs 17, 39,47, 89,111

In response to the points raised in the SHLAA, the site is serviced by an existing road, for vehicular access and an established pathway through the station car park for pedestrians. In addition, there would be scope to provide stepped access at the south of the site to Benslow Lane, offering an efficient pedestrian route connecting to the town centre. The site is large and setback from the railway line, with the station car park acting as a buffer to noise generated from this source.

Whilst our client recognises that the Council seeks to protect a proportion of employment land, this designation only serves to prevent the regeneration of the area. A removal of this allocation would reduce the risks associated with a comprehensive redevelopment proposal for the site, allowing it to be assessed on its own merits.

Next Steps

We trust that our representations will be given full consideration through the Pre-Submission consultation process and that our details will be included on the Council's database to ensure we are notified of all future stages of this document. We would be pleased to provide further information and elaborate upon any point as required.