UPSVLP 0435
Stepped housing requirement under policy DEV1 is not justified or evidenced and is not sound.
Evidence should be presented to justify the requirement for 100% of new homes built to meet M4 (2) standard. If this is not possible then a requirement that matches the evidenced need should be used. More clarity should be provided in terms of what is meant by housing for older people and how this can be accommodated within developments of 10 or more homes.
Additional land should be allocated, or safeguarded, to meet the needs within and beyond the Plan period. The wording of provision 11 should be changed to the following: Where development proposals result in land being removed from the Green Belt, or are part of an allocation on land formerly in the Green Belt, a scheme of compensatory improvements to the environmental quality and accessibility of land remaining in the Green Belt will be required to be provided. Financial contributions will be considered where this would help to ensure that the benefits of compensatory improvements can be maximised by providing them in the most appropriate location.
Part 1.g) of the policy changes to the following: Ensure traffic generated by development is appropriate to the type and nature of the routes available and that [delete: 'there is no adverse impact on the local community'] the cumulative residual impact associated with it is not severe.
The current wording of part 1.g) of Policy INV1 is not aligned with the NPPF and thus as currently worded would be unsound owing to a conflict with national policy. Paragraph 111 of the NPPF is clear that development should only be prevented or refused on highways grounds if the residual cumulative impacts on the road network would be severe.
Remove repetition between provisions 10, 11, 12 and 13 of the policy and replace with a single paragraph instructing that development should follow the drainage hierarchy.
Unnecessary level of repetition in the policy.
Remove sections of the policy requiring reductions to carbon emissions beyond Building Regulation (Part L) requirements because this is already covered by the new Building Regulations that will be in place by the time the WLP is adopted.
Remove sections of the policy requiring reductions to carbon emissions beyond Building Regulation (Part L) requirements because this is already covered by the new Building Regulations that will be in place by the time the WLP is adopted.
Amend Policy OS6 to allocate Hollins Lane, Winwick instead of the current allocation.
OS6 should be amended to allocate Hollins Lane, Winwick as the evidence available shows that it is a better option for Green Belt release. As the site is free of significant constraints and does not require significant infrastructure in order to facilitate delivery, it is anticipated that delivery would follow a similar trajectory to the current allocation.
Land owned by Miller at Smithy Brow, Croft; Hatton Lane, Stretton and Cherry Lane, Lymm should be allocated to provide much needed homes in sustainable locations.
Consider that the urban capacity relied upon is too optimistic and minimum delivery needed from SHLAA sites greatly exceeds that which has been achieved in last 5 years. Policy DEV1 therefore does not meet the Borough's objectively assessed need for housing and is not deliverable over the plan period. Also heavy reliance on town centre sites which are only deliverable in the medium to long term which leaves significant uncertainty. In addition there are clear viability concerns over town centre sites. The plan is therefore not deliverable. The number of allocated greenfield sites should be increased to ensure delivery. The Council has not provided clear justification for the stepped housing requirement. Given the contraints on dellivery of larger sites, more small and medium sites should be identifed. Land supply beyond the plan period has been underestimated.