Waveney District Council Local Plan Review Final Draft Local Plan Consultation Representations on Behalf of the Sotterley Estate

May 2018

Opus House

01359 233663

Waveney District Council Local Plan Review Final Draft Local Plan Consultation

Representations on Behalf of the Sotterley Estate

Reference: E422.C1.Rep05

Page 2 E422.C1.Rep05 May 2018

Contents:

1.0 Introduction 2.0 Policy WLP1.1 Scale and Location of Growth 3.0 Policy WLP7.1 Rural Settlement Hierarchy and Housing Growth 4.0 Policy WLP7.16 Land East of Woodfield Close 5.0 Conclusion

Page 3 E422.C1.Rep05 May 2018

1.0 Introduction

1.1 Waveney District Council is in the process of preparing a new local plan which will determine the number and location of new housing and employment sites in the District for the period up to 2036.

1.2 The local plan has reached the final draft stage. Evolution Town Planning has been instructed by the Sotterley Estate to make representations to this public consultation on ‘soundness’.

1.3 This report conveys the Sotterley Estate’s support in principle for the Council’s rural development strategy and the allocation of land in Willingham for housing. However, this report also conveys the Estate’s objection to the change to the Council’s ‘Rural Strategy’ since the Preferred Options consultation that has seen the proportion of rural housing across the district reduced and subsequent reduction in the quantum of housing allocated to the village of Willingham. The Sotterley Estate, therefore, object to this aspect of the final draft plan.

1.4 The Sotterley Estate has engaged positively at all stages of the local plan preparation. At the Call for Sites stage we provided background information on potential development sites in Willingham and , plus some early ideas on how the sites could be developed; whether solely for housing or as part of a more comprehensive approach to deliver community facilities. These proposals were reiterated at the Issues and Options stage. At the Preferred Options stage the Estate supported the proposed rural strategy, the proposal to direct 12% of the district’s housing supply to rural communities to support rural sustainability and the draft site specific planning policies which had passed sustainability appraisal and allocated a total of 40 dwellings to Willingham.

1.5 These representations are a continuation of our earlier submissions and the Sotterley Estate will continue to engage with the community of Willingham as the local plan and neighbourhood plan processes continue.

Page 4 E422.C1.Rep05 May 2018

2.0 Policy WLP1.1 Scale and Location of Growth

Summary 2.1 The Sotterley Estate support the principle of identifying a proportion of the district’s housing growth to rural areas but objects to the reduction to 10% from 12% of the total minimum 8223 dwellings between the Preferred Options consultation and this Final Draft consultation for the reasons set out below.

2.2 This change has meant the local plan is now unsound because:

 It will not have been positively prepared (when compared to the ‘Preferred Option’)

 The reduction from 12% to 10% not having been properly justified

 The rural strategy effectiveness being impaired as a result and

 The reduction (in comparison to the Preferred Option which was sustainable) runs contrary to national policy on supporting the provision of rural services and facilities through housing growth and delivery.

Rationale

2.3 At the Preferred Options stage Policy WLP1.1 stated that 12% of the housing growth (a minimum of 8223 dwellings) for the district would be distributed to the Rural Areas. The Council termed this the ‘Strategy for Rural Areas’ and was intended to support rural communities and to address the limited development there has been in rural areas in recent years and the resultant decline in services and facilities.

2.4 In this final draft local plan the rural strategy has been altered and the proportion of the district’s housing being directed to rural areas has been reduced to 10% from 12%. This has meant a lot of villages have seen reductions in their draft allocations, some around 50% of numbers of dwellings (see Appendix). In the case of Willingham this has meant a 75% reduction in proposed housing numbers. The final draft local plan does not

Page 5 E422.C1.Rep05 May 2018

explain this reduction.

2.5 A report to the Council’s Full Committee in March 2018 provides some explanation and stated that:

“The distribution is slightly different from that which was consulted on last year. The percentage has gone down 2% in the rural areas and up a single percentage point in and . This is down to minor changes to the sites proposed to be allocated.”

2.6 More recent correspondence we have had with Council officers indicates that local pressure in the form of objections received to the Preferred Options consultation played a part.

2.7 The adverse impact on the principles underpinning the rural strategy (supporting rural services and facilities) could be profound. Whereas the relatively minor increase in dwelling numbers redirected to the large towns of Beccles and Lowestoft will be imperceptible.

2.8 The thrust of the Estate’s responses, and support to the earlier stage local plan consultations, has been that a strong rural strategy is required to deliver homes in rural areas to not only provide for the services and facilities required now, but to also seek to reverse years of decline in growth and the well‐known issues which accompany this; including rural housing affordability, loss of services and facilities, loss of public transport services and imbalances in demographics with younger people and families unable to afford to live in villages.

2.9 The Estate is concerned that this reduction in the proportion of housing being directed to rural areas dilutes the plan’s earlier compliance with the NPPF policies detailed below and may have the unintended result of providing only housing and not the additional infrastructure, services and facilities the higher proportion of 12% would have more easily afforded:

 Paragraph 17 and the final bullet point which cites the delivery of “sufficient community and cultural facilities and services to meet local needs” as a Core Planning Principle.

 Paragraph 28 which states that “Planning policies should support economic growth in rural areas […] to promote a strong rural

Page 6 E422.C1.Rep05 May 2018

economy, local and neighbourhood plans should […] promote the retention and development of local services and community facilities in villages, such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship”.

 Paragraph 156 which states that “local planning authorities should set out strategic priorities for the areas in the local plan. This should include strategic policies to deliver […] the provision of health, security, community and cultural infrastructure and other local facilities”.

2.10 The draft review of the NPPF also places an emphasis on the contribution to housing delivery that small sites can make because they are “often built out quickly”. This applies to small rural housing sites.

Changes necessary to make the plan sound

2.11 The Sotterley Estate wish to see the 12% figure which was considered justifiable and sustainable in the first draft local plan reintroduced and the resultant re‐distribution of dwelling numbers put back to at least the figures/sites in the first draft local plan; namely 40 dwellings in Willingham; 10 dwellings on site WLP7.16 (Woodfield Close) and the return of 30 dwellings on site ‘WLP7.20’ (as referred to in the first draft plan aka Land North of Sotterley Road, Willingham).

Page 7 E422.C1.Rep05 May 2018

3.0 Policy WLP7.1 Rural Settlement Hierarchy and Housing Growth

Summary and Rationale

3.1 Following our comments above in respect of policy WLP1.1; policy WLP7.1 makes reference to the same 10% figure for the proportion of the district’s growth proposed for rural areas. This is down from the 12% figure in the first draft local plan.

Changes necessary to make the plan sound

3.2 The Estate would wish to see the 12% figure which was considered justifiable in the first draft local plan policy WLP7.1, and which would have been through rigorous sustainability appraisal, reintroduced in policy WLP7.1 and the resultant re‐distribution of dwelling numbers put back to at least the figures/sites in the first draft local plan; namely 40 dwellings in Willingham.

3.3 This change would need to be reflected in paragraph 7.1 and Figure 25.

Page 8 E422.C1.Rep05 May 2018

4.0 Policy WLP7.16 Land East of Woodfield Close, Willingham

Summary and Rationale

4.1 The Sotterley Estate support the principle and detail of policy WLP7.16.

Changes necessary to make the plan sound

4.2 None required.

Page 9 E422.C1.Rep05 May 2018

5.0 Conclusion

5.1 The Sotterley Estate support the principle of the ‘Strategy for Rural Areas’ as this has the potential to halt decades of decline of services and facilities in rural areas.

5.2 However, the Sotterley Estate is concerned at the reduction in the proportion of housing being directed to the rural areas and the unintended consequences this may have on rural sustainability and the provision of services and facilities as set out in national policy. Therefore, the Estate objects to policy WLP1.1 as set out above.

5.3 The Sotterley Estate supports the allocation of land for a total of 10 dwellings in Willingham on site WLP7.16. The Estate will deliver the housing allocated to this site.

5.4 The Sotterley Estate consider that for the local plan to be sound the proportion of housing to the rural areas needs to be returned to the previous 12% figure with the resultant amendment made to policy WLP7.1 and the return of the first draft local plan site ‘WLP7.20 ‐ Land North of Sotterley Road, Willingham’ for 30 dwellings.

Page 10 E422.C1.Rep05 May 2018

Appendix 1: Reduction in Villages’ Draft Allocations

Page 11 E422.C1.Rep05 May 2018 Village First Final Difference Approx. % draft draft difference plan plan Larger Barnby 53 58 +3 6% villages 216 216 0 0 Corton 10 0 -10 -100 187 187 0 0 55 45 -10 -20% 41 19 -22 -50% Wrentham 116 94 -22 -20% Smaller Brampton 65 71 +6 10% villages 0 0 0 0 Ilketshall 27 27 0 0 Lound 14 14 0 0 16 8 -8 -50% 44 34 -10 -25% 12 10 -2 -15% Willingham 40 10 -30 -75% 15 19 +4 25% 3 3 0 0 914 815 101