Answers to common questions regarding the Neighbourhood Plan (The Plan).
1. QUESTION: Why isn’t the Steering Group allocating the Ifold Brownfield for development? Surely brownfield should be developed before greenfield sites?
ANSWER: The Steering Group and Parish Council would agree that Brownfield should be developed before greenfield. It was the original intention to allocate the Brownfield in The Plan, however, this is not possible for two reasons:
- A Site Options and Assessment carried out by independent planning consultancy, AECOM, judged that insufficient regard had been given to the refusal of residential development at Appeal on the brownfield; that it is not in a sustainable location; and if the Parish Council proceeded with allocating it in the plan it would likely be rejected by the Inspector at examination. This conclusion was also supported in an opinion provided by Colin Smith Planning (engaged to assist in developing The Plan).
- The Plan must meet the identified Parish housing need and that includes an element of affordable housing. Sites of 10 houses or fewer are not required to deliver affordable housing, therefore the plan as drafted will deliver 11 houses on one site to ensure this need is met. The Brownfield is not large enough to deliver 11 houses and the AECOM Site Options and Assessment concludes the Brownfield to be in an unsustainable location.
2. QUESTION: Why don’t you extend the Ifold Settlement Boundary and put the houses there?
ANSWER: There are no facilities in Ifold that fulfil the criteria of sustainable development, which is necessary to meet national and local planning policies. Plaistow has a shop, school, church, many recreation areas and pub, so is considered more sustainable.
- Also, through a 2016 survey conducted with all Parish residents, an extension to the Settlement Boundary was rejected by a majority and there is no mandate to make this provision in The Plan. Nor is it being considered by Chichester District Council (CDC).
3. QUESTION: Little Springfield Farm Brownfield site was rejected in part as the site is too small. If the brownfield site is too small to meet our housing need, I can only presume The Dairy site is too?
ANSWER: The Brownfield was discounted because of it being unsustainably located, not because of its size. However, if sustainability had not been an issue its size would have ultimately discounted it because the Parish needs one site for 11 units. The Brownfield was originally identified for 6 small units only. The site is not 0.6ha of ‘all’ developable land – the area alongside the stream is flood zone 2 & 3 and a buffer was included next to the Ancient Woodland – so the actual building development area is considerably less. This land was originally included to ensure sufficient green space was allocated around the site and lessen the impact on the countryside.
The Dairy site is 0.6ha and has two green space buffer areas to mitigate loss of amenity to surrounding properties (0.014ha and 0.022ha respectively), the Conservation Area section (0.05ha) is proposed to be retained for green space (but with a cross-over through), this allows for approx. 0.513ha developable space which is sufficient for the small units proposed (1, 2 or 3 bed) in an appropriately designed scheme.
4. QUESTION: Why don’t you allocate 2 or 3 smaller sites instead of having all the houses in one place?
ANSWER: The Steering Group considered allocating 6 units each on two sites, one in Ifold and one in Plaistow. However, The Plan must meet the identified Parish housing need and that includes an element of affordable housing. Sites of 10 houses or less are not required to deliver affordable housing, therefore The Plan as drafted will deliver 11 houses on one site to ensure the identified need for affordable housing can be met.
5. QUESTION: Why doesn’t Plaistow have a Settlement Boundary?
ANSWER: Historically, none was provided.
6. QUESTION: New houses are being built all the time in Ifold – why don’t they count towards the number that CDC have told us we must have?
ANSWER: Small developments of fewer than six houses are classified as ‘windfall’ development, which is different to the housing allocation in the Local Plan. Within the Ifold Settlement Boundary there is a presumption in favour of unlimited windfall development. The sustainability criteria for windfall development is on a case by case basis, resulting in minimal requirements being enforced. In the long term the incremental development has caused the Ifold settlement to suffer a significant shortfall in its infrastructure, rendering it more and more unsustainable, unlike planned development. CDC considers Windfall numbers when determining how many houses need to be built in the District and when allocating to the parishes. This explains why this Parish has a relatively small number of houses allocated (about 10 units) compared to neighbouring Parishes.
7. QUESTION: Does sustainability criteria mean all future planned development will only be in Plaistow?
ANSWER: No. The Plan is based on CDC’s current Local Plan (2014-2029) and dictates an allocation of about 10 units for this Parish. Plaistow has no Settlement Boundary therefore no presumption in favour of development, and countryside policies apply. In the future for any other allocations of housing, CDC will again base the numbers on local needs; and local and national planning policies at the time. There is also different criteria to consider for a site of, say, 100 houses compared to a site of 10.
8. QUESTION: Won’t the extra traffic generated by 11 new houses behind the site Land adjacent to The Dairy make the road even more dangerous than it is now, particularly as the access is near the bend?
ANSWER: According to national planning policy, a development can only be unacceptable in transport terms if the effects of the development are judged by the Highways authority to be severe. It is unlikely that 11 houses will have a severe impact on traffic and transport. Any development would have to go through a full planning application, at which point the Highway Authority would determine whether safe access can be provided. It should also be noted that one of the positive aspects in the choice of this site and the greater need for an increased element of sustainability, is the ability to walk to the services and facilities in the village, reducing the need to use a car.
9. QUESTION: If there must be a development site in Plaistow, why don’t you put it behind Nell Ball where it won’t affect the Conservation Area?
ANSWER: The Steering Group originally considered Land adjacent to Todhurst, which is distanced from the Conservation Area. However, following further investigations it was found that there were unresolvable issues due to the location of a sewage pumping station and electricity sub-station (both inhibiting access) and that stayed electricity transformer poles and sewer alignments would also need to be relocated. The Hyde Group (housing association) who own part of the land advised that they did not wish to develop the site and their opinion was that the technical constraints made it unviable. Moreover, parking and traffic issues in the Nell Ball housing area were identified, and additional housing would exacerbate this problem. It was also noted that development on the site would impact on far more properties than the site currently proposed Land adjacent to The Dairy.
10. QUESTION: Why doesn’t the Steering Group concur with the CDC Draft Site Allocations DPD in regard to the site Land to the North of Little Springfield Farm, Ifold and put 11 houses there?
ANSWER: This site was noted in the CDC Draft Site Allocations DPD because at that time the Parish had not reached a stage of allocating a site in the Neighbourhood Plan. However, this site due to its location, has since been found through consultation with Parish residents and technical advisors – AECOM and Colin Smith Planning – to be the most unsustainable out of all that were considered. It is outside the Settlement Boundary separated by the physical barrier of Plaistow Road (40MPH speed zone) and is remote from Plaistow services. Therefore, it does not meet the current requirements for sustainable development as set out in the NPPF and the Local Plan and was discounted. [N.B. For the avoidance of doubt: This site, identified as ‘Land to the North of Little Springfield Farm’, is not Little Springfield Farm itself, nor does it relate to the Little Springfield Farm brownfield.]