VALP Main Modifications
Representation ID: 2742
Respondent: Hollins Strategic Land
Legally compliant? No
Policy D2, as proposed with main modifications, would be ineffective in positively responding to potential failures in housing delivery by not making allowances for sustainable sites located outside and adjacent to settlement boundaries in made neighbourhood plans.
Removal of last part of criteria c under D2 (Proposals for non-allocated sites at strategic settlements, larger villages and medium villages), i.e. REMOVE "except where there is a made neighbourhood plan which defines a settlement or development boundary, where the site should be located entirely within that settlement boundary".
Policy D2 (Proposals for non-allocated sites at strategic settlements, larger villages and medium villages) is partly aimed to be a positive response in circumstances when the VALP fails to be delivering housing as anticipated and instances where allocated sites do not come forward at all or at the rate expected in the housing trajectory.
However, the modification as proposed is not positively prepared, nor justified, and would result in conflicts with made Neighbourhood Plans which define settlement boundaries in a less rigid way and restrictive way. Some neighbourhood plans define settlement boundaries to simply delineate between built form and open countryside, whilst others are silent on what decision makers do with proposed development outside of settlement boundaries. Where housing delivery across the district shows that allocated sites are not being delivered at the anticipated rate, Policy D2 would result in an unnecessary further hurdle in bringing sustainable development forward to compensate, particularly as it would be much more restrictive than many existing neighbourhood plans. Criteria C fails to recognise the different interpretation and policy wording of settlement boundaries in various neighbourhood plans in the district.
In order for Policy D2 to be effective Criteria C should be amended to ensure sustainable development located within or adjacent to existing settlement boundaries in made neighbourhood plan areas is supported. Given the development plan as a whole would be the VALP and neighbourhood plans read together, if there is a failure in meeting the required needs during the life of the plan period, it would require a more flexible and positive approach to Policy D2 than what is being proposed, particularly in light of many sustainable large and medium villages either preparing or having made a neighbourhood plan.
Policy D2, as proposed with main modifications, would therefore be ineffective in positively responding to potential failures in housing delivery.