Part (8) in respect of Washed Over Settlements duplicates National Policy and other policies of the Local Plan and it is unclear how this part of the Policy relates to Part (12) in respect of other forms of development. The Council seeks to arbitrarily restrict national Green Belt planning policy such that paragraph 149(e) only applies to certain locations of the Borough. Again, there is no explanation or justification for the Council?s approach from the evidence base available for the draft local plan. The reality is that the settlement boundary has been drawn so tightly around Broomedge that no limited infill development could take place. The pattern of built development within the settlement boundary is such that no infill opportunities exist. Furthermore, it is unclear how other forms of development would be assessed within Broomedge through Draft Policy GB1 such as rural exception sites that can provided much-needed affordable housing in villages such as Broomedge, the redevelopment of brownfield land and replacement dwellings. Whether it is intention or not, the Council?s approach will effectively prevent development coming forward that may otherwise comply with national planning policy guidance. This blanket restriction would serve to deprive those identified settlements from new housing development and would likely to undermine the vitality and viability of such villages (e.g. new households typically support the services available within villages, and support new services, such as public houses, bus services and village shops). The Council?s arbitrary blanket approach is contrary to paragraph 67-009 of the National Planning Practice Guidance (PPG) and contrary to the provisions of the Framework including paragraphs 78 and 79. There is no justification for arbitrarily restricting development proposals that may otherwise comply with national Green Belt planning policy guidance.

There is no justification provided within the evidence base for the draft local plan as to why the 'Washed Over' settlements have been identified and why other villages have been discounted. Notwithstanding our firm view that it is unnecessary to identify such settlements through the local plan, one would expect the Council to have carried out a background paper on all ?washed over? villages across the Borough and applied a justified methodology as to identification of certain ones with a scoring matrix applied. This may have included considerations related to spatial form of settlements and service provision. It appears that the Council seeks to ?roll over? settlement boundaries identified for a previous iteration of the local plan. It is not sufficient to simply roll forward designations from a previous local plan without any consideration as to whether it is sound and meets up-to-date national planning policy guidance. There is no justification provided within the evidence base for the draft local plan why the settlement boundary has been drawn in this way. One would expect the Council to have issued a background paper explaining a methodology as to the way in which settlement boundaries are drawn and what factors are considered. This may have included considerations such as planning permissions granted and physical features and the relationship to the built-up area. The reality is that the settlement boundary has been drawn so tightly around Broomedge that no limited infill development opportunities exist.

Barnes Walker, landscape architects, have produced a Technical Note at Appendix EP2 of these representations and this considers whether our client?s land should be included in any settlement boundary. They have visited the site and used a range of data sources, including historic mapping and various photographic viewpoints are provided. We summarise the points below: Top Farm has clearly been historically associated with the settlement of Broomedge and physically connected since the mid-20th Century; The identified settlement boundary identifies the access drive into Top Farm but excludes Top Farm itself, which is unusual given that the driveway only serves Top Farm; Top Farm is closely linked to the other built form in the village and is very well connected to amenities by a section of pavement; The site is strongly visually connected to the village and various photographic viewpoints and detailed analysis is provided; and There is a clear and appreciable visual connection between Top farm and the buildings within the identified settlement boundary of Broomedge. Top Farm is experienced as a visual part of the settlement.