Crofts Developments Ltd 1092848 Agent Marrons Planning 988787
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Crofts Developments Ltd 1092848 agent Marrons Planning 988787 From: Ravi Karir Sent: 28 June 2018 15:54 To: Localdevelopment Cc: Jenny Keen Subject: RE: LP2 Representation on behalf of Crofts Developments Limited Attachments: Revised.compressed.pdf Dear Local Development, Please ignore the previously attached representation and proceed with the attached one. Apologies for any inconvenience that may have been caused. Kind regards, Ravi Ravi Karir Planning Technician Marrons Planning Planning Consultancy of the Year and Young Planner of the Year (Jenny Keen) – find out more FRAUD PREVENTION Please do not reply to or act upon any email you might receive purporting to advise you that our bank account details have changed. Please always speak to the lawyer acting for you to check any changes to payment arrangements. We will also require independent verification of changes to any bank account to which we are asked to send money. From:RaviKarir Sent:28June201815:37 To:'[email protected]'<[email protected]> Cc:JennyKeen Subject:LP2RepresentationonbehalfofCroftsDevelopmentsLimited Dear Local Development, 1 Please find attached our representation on behalf of our client, Crofts Developments Limited, in respect of their land interests at land at Simkins Farm, Adbolton Lane, West Bridgford. We would be grateful for your confirmation of receipt. Kind regards, Ravi Ravi Karir Planning Technician Marrons Planning Planning Consultancy of the Year and Young Planner of the Year (Jenny Keen) – find out more FRAUD PREVENTION Please do not reply to or act upon any email you might receive purporting to advise you that our bank account details have changed. Please always speak to the lawyer acting for you to check any changes to payment arrangements. We will also require independent verification of changes to any bank account to which we are asked to send money. 2 REPRESENTATIONS IN RESPECT OF THE RUSHCLIFFE LOCAL PLAN PART 2: LAND AND PLANNING POLICIES (PUBLICATION VERSION) MAY 2018 On Behalf of Crofts Developments Limited www.marrons-planning.co.uk Crofts Developments Limited Representations on Rushcliffe Local Plan Part 2 CONTENTS Page No 1. Introduction 3 2. Background and Context 4 3. Land at Simkins Farm, Adbolton Lane, West Bridgford 6 4. Specific Representations in Respect of the Rushcliffe Local 7 Plan Part 2 Appendices Appendix 1 – Site Location Plan for land north of Adbolton Lane, West Bridgford Appendix 2 – Heritage Note by Lanpro Services Appendix 3 – Archaeological Desk Based Assessment from Lanpro Services and accompanying Geophysical Survey prepared by SUMO Survey June 2018 2 Crofts Developments Limited Representations on Rushcliffe Local Plan Part 2 1. INTRODUCTION 1.1 These representations are made in respect of the Rushcliffe Local Plan Part 2: Land and Planning Policies (Publication Version) May 2018 consultation, on behalf of our client, Crofts Developments Limited, in respect of their land interests at land at Simkins Farm, Adbolton Lane, West Bridgford. The County Council also owns part of the site and are promoting the land for development alongside Crofts Developments Limited. The site is identified at Appendix 1. 1.2 Representations have also previously been made by Marrons Planning at earlier stages of the Local Plan preparation process. 1.3 In summary, these representations seek to argue that amendments should be made to the Rushcliffe Local Plan Part 2 (LP2) moving forward to allow for a level of growth adjacent to the Main Urban Area of West Bridgford, in the form of the reallocation of land at Simkins Farm for the residential development of circa 40 dwellings. The inclusion of land at Simkins Farm will represent development within a sustainable location and will assist the Council in addressing its current 5 year housing land supply shortfall. 1.4 Local Plan Part 2 in its current form fails to identify sufficient housing to meet Rushcliffe’s housing need; it fails to identify a deliverable housing allocation for the Main Urban Area; and a number of changes to the Plan have resulted in the identification of undeliverable draft housing allocations. June 2018 3 Crofts Developments Limited Representations on Rushcliffe Local Plan Part 2 2. BACKGROUND AND CONTEXT 2.1 For a plan to be adopted it must pass an examination and be found to be ‘sound’. 2.2 Paragraph 14 of the National Planning Policy Framework (NPPF) refers to the presumption in favour of sustainable development and makes specific reference to plan making stating that: Local Planning Authorities should positively seek opportunities to meet the development needs of their area; Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless: – any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or – specific policies in this Framework indicate development should be restricted. 2.3 Paragraphs 154 and 157 of the NPPF identify (amongst other criteria) that Local Plans should be aspirational but realistic and should plan positively for development to meet the objectives, principles and policies of the NPPF. 2.4 The NPPF at paragraph 182 also sets out that the plans will need to be prepared in accordance with the duty to cooperate, legal and procedural requirements and that they must be ‘sound’. There are four tests of ‘soundness’, which are that each plan must be: Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development; June 2018 4 Crofts Developments Limited Representations on Rushcliffe Local Plan Part 2 Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence; Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework (NPPF). June 2018 5 Crofts Developments Limited Representations on Rushcliffe Local Plan Part 2 3. LAND AT SIMKINS FARM, ADBOLTON LANE, WEST BRIDGFORD 3.1 The site is wholly greenfield land and equates to approximately 1.9 hectares in size. The site has capacity for approximately 40 homes. Whilst the main built up area of West Bridgford is located further to the west, the site directly adjoins built development to both the east and west. 3.2 The site is in a wholly sustainable location with an abundance of facilities and amenities within a reasonable walking distance of the site. The site is also highly accessible by public transport with a frequent bus service accessed by a bus stop located south west of the site on Adbolton Lane. 3.3 Simkins Farm, the farm house (Grade II Listed Building), farm buildings converted to residential use and new build residential dwellings are located to the southeast of the study site, these are bounded by a mix of post and rail fencing and high, solid wooden fencing surrounding the gardens. There is a single extant structure within the study site, a small brick building to the north of the former farm complex. This building is not an original farm building but was constructed as a replacement wildlife habitat following the conversion of the outbuildings at Simkins Farm to residential use. 3.4 Further information and context in relation to the heritage impact of development of the site is included in full commentary prepared by LanPro attached at Appendix 2. Further information with regards to the archaeology onsite is provided in the Archaeological Desk Based Assessment and Geophysical Survey both attached at Appendix 3 and further commentary in respect of archaeological concerns is provided below. 3.5 The site is not located in an area at high risk of flooding and benefits from flood defences to the north of the site boundary. The land within the study site is relatively flat, lying at approximately 24mAOD. June 2018 6 Crofts Developments Limited Representations on Rushcliffe Local Plan Part 2 3.6 The site is designated as Green Belt land and commentary in respect of the site’s suitability to be removed from the Greenbelt has previously been made during the consultation process for Rushcliffe Green Belt Review Part 2 (a) (Detailed Review of the Nottingham-Derby Green Belt within Rushcliffe Adjoining the Main Urban Area of Nottingham). This is also explored in more detail below. June 2018 7 Crofts Developments Limited Representations on Rushcliffe Local Plan Part 2 4. SPECIFIC REPRESENTATIONS IN RESPECT OF THE RUSHCLIFFE LOCAL PLAN PART 2: LAND AND PLANNING POLICIES CONSULTATION (PUBLICATION VERSION) 4.1 This section of the representations contains our detailed responses, prepared on behalf of our client, Crofts Development Ltd, in relation to the Rushcliffe Local Plan Part 2: Land and Planning Policies (Publication Version). 4.2 In principle, we wholly agree that the Council needs to allocate land for further development over and above that originally envisaged for the Local Plan Part 2, including a suitable buffer to guard against the risks of future under-delivery. 4.3 The Council indicates that around 2,000 additional dwellings will need to be provided through the Local Plan Part 2, yet that a further 700 dwellings will be identified to ensure sufficient delivery in the Plan Period, should the Core Strategy’s Sustainable Urban Extensions (SUEs) continue to fail to deliver. 4.4 However, we have serious concerns that the extent of the buffer proposed by the Council will be inadequate and that if adopted in its current form, the Local Plan Part 2 will not adequately guard against further under-delivery in the near future.