Comment

Representation ID: 19828

Received: 12/03/2018

Respondent: Clearbrook Group Plc

Agent: Strutt & Parker LLP

Land at land at Hillcrest Nurseries, Ingrave (site 146) is considered sustainable and deliverable to provide retirement flats to help meet an identified need within the Borough. Allocation of the site for retirement housing would be justified, effective, consistent with national policy and would help ensure the Local Plan is positively prepared.

Comment

Representation ID: 19829

Received: 12/03/2018

Respondent: Clearbrook Group Plc

Agent: Strutt & Parker LLP

Need for Retirement Accommodation: Enabling people to downsize through the provision of appropriate accommodation would of course have a positive impact on the housing market, as larger homes become available to those who require them. Significant amount of evidence submitted by Clearbrook Group PLC, as part of a previous planning application, demonstrated a need for private sector retirement housing.

Comment

Representation ID: 19830

Received: 12/03/2018

Respondent: Clearbrook Group Plc

Agent: Strutt & Parker LLP

The NPPF requires that the Local Plan seek to meet retirement accommodation need. The Preferred Site Allocations document is silent on retirement housing; although it does seek to address specialist accommodation needs, including residential care / nursing care (C2). However, as the NPPF recognises, older people's housing needs are not restricted to residential care / nursing care. Therefore the Local Plan should look to address retirement accommodation.
Not only is it a requirement of the NPPF, but provision of retirement accommodation has potential significant benefits to the Borough's housing stock, as older people will be able to downsize.

Comment

Representation ID: 19832

Received: 12/03/2018

Respondent: Clearbrook Group Plc

Agent: Strutt & Parker LLP

Dunton Hills Garden Village is intended to be a new settlement. As such, focussing C2 development there - and failing to provide a greater amount within existing settlements - will potentially deprive existing residents of the Borough an opportunity to continue living within their home town and community, in the event they require extra care accommodation. The Local Plan should seek to ensure a proportionate provision of C2 facilities and retirement accommodation for the Borough's various settlements.

Object

Representation ID: 19837

Received: 12/03/2018

Respondent: Clearbrook Group Plc

Agent: Strutt & Parker LLP

The Preferred Site Allocations document currently proposes no growth be directed to Ingrave over the entirety of the plan period. The current proposed spatial strategy fails to ensure the sustainable growth of Ingrave. The proposal to direct none of the Borough's housing need to Ingrave is inconsistent with national policy, and the approach is not justified.

Comment

Representation ID: 19838

Received: 12/03/2018

Respondent: Clearbrook Group Plc

Agent: Strutt & Parker LLP

Land at Hillcrest Nurseries, Ingrave (site 146) is located immediately adjacent to the existing settlement of Ingrave and should be allocated. Site was discounted; however, in respect of the concerns relating to harm to the character of area and lack of affordable housing, these are functions of the details of the specific proposal that was subject to appeal; as opposed to potential fundamental concerns as to whether the site could be suitable for development. In respect of the development being inappropriate development in the Green Belt, the Green Belt
assessment doesn't provide robust justification for the rejection of the site.

Object

Representation ID: 19839

Received: 12/03/2018

Respondent: Clearbrook Group Plc

Agent: Strutt & Parker LLP

Green Belt assessment: Site 146 is within Parcel 19 which was assessed as making a high overall contribution to the Green Belt. However, Parcel 19 is 682.28 ha whilst site 146 is 0.74 ha or 0.1% of the Parcel. Impact of the development of Parcel 14 would have a very different impact on the Green Belt than development of site 146. Impact of development within Parcel 14 would have varying impacts on the Green Belt depending on its location and scale. As such, the Green Belt assessment does not provide robust justification for the rejection of the site.

Object

Representation ID: 19840

Received: 12/03/2018

Respondent: Clearbrook Group Plc

Agent: Strutt & Parker LLP

The Sustainability Appraisal (SA) takes a very simplistic approach to assessing the sustainability of potential development sites. The Interim SA Report focuses on physical distance between sites and various designations / facilities. The Interim SA Report also fails to acknowledge the social and economic benefits of providing additional homes for the village, in terms of the helping to sustain local facilities
and services, and its vitality. The Interim SA Report should be updated to
ensure these are given due consideration, particularly for site 146.

Object

Representation ID: 19841

Received: 12/03/2018

Respondent: Clearbrook Group Plc

Agent: Strutt & Parker LLP

The Preferred Site Allocations document fails to direct a proportionate level of growth to settlements such as Ingrave, failing to ensuring the growth of such village is sustainably managed, and failing to seek to assist in retaining or enhancing the vitality of such communities. The Local Plan should direct a greater number of homes to villages such as Ingrave than currently proposed.