Local Plan Reg 18 Comments

SPS3.4: Southern Manydown is a new policy allocation. It seeks to complement and extend the key principles of Northern Manydown, which is generally supported.  The policy requires a Masterplan to be appended within the Local Plan. This is not yet available for review and TMCL therefore reserve comment.

Limb p requires on-site provision for four primary schools (three 3 form of entry and one 2 forms of entry), a special educational school, and reserve land for two secondary schools. The supporting evidence should clearly set out the level of educational needs relative to the proposed 7,500 home allocation. The Infrastructure Delivery Plan (Jan 2024) only identifies a need for 1 x 11FE secondary school to mitigate this amount of development and the policy should be clearer on this.  

If additional secondary school land is to be provided at Southern Manydown to mitigate impacts from other proposed allocations, this must be clearly referenced within the local plan and the relevant policies for both site allocations to ensure that suitable compensatory measures are secured at through the development management process and future planning applications. 

Suggested Change: change the 2 secondary school sites to 1 site within the Southern Manydown policy limb ‘p’ or include clear reference within the policy that a second site may be required to include compensatory provision for Popham Garden Village.

Make a corresponding change to Policy SPS5.5 Popham Garden Village to specifically refer to secondary school provision arising from this development being made at Southern Manydown and that planning obligations (i.e. financial contributions) will be sought towards the cost of providing additional school places and additional school land to achieve this. 

Policy SPS1: Scale and Distribution of Development

The policy seeks to control land within defined Settlement Policy Boundaries (SPB).  Where an SPB is not defined, countryside policies (i.e. restraint policies) will automatically apply.

The policy on its own is not unusual and it is generally accepted that this type of policy will be included and supported within Local Plans.  However, the corresponding policy maps that define those settlements with SPB’s are limited in number.  The revised plan seeks to increase the number of settlements with SPB’s but only for three additional settlements.  In many similar rural areas, it is widely recognised that small villages can successfully support settlement boundaries to facilitate some organic growth to sustain their rural communities.  The built-up areas of more ‘smaller villages’ should be considered for SPB’s to enable some sensitive infilling or regeneration to occur.

The evidence base to support the continued approach of using SPB’s and the justification for including the 3 additional settlements is not comprehensive.  The Settlement Study (Jan 2024) limits the number of small villages beyond which the remaining settlements are ‘not considered suitable for planned growth’ (paragraph 9).  This is the wrong approach.  Planned growth to meet the identified growth requirements can occur and be identified through the spatial strategy and key policies including providing a housing requirement figure where appropriate.  However, it is also important that other villages can evolve where they are sustainably located or have access to facilities or form a group of villages which collectively form a larger community for education and economic support for local shops and services.

Settlement Policy Boundaries can be a useful tool to delineate between the built-up part of a village and the undeveloped edges where countryside restraint policies may apply.  The villages where SPB’s are to be defined reflect changes made through the Neighbourhood Plan process.  Settlements where a Neighbourhood Plan is not being progressed should not automatically be prejudiced by the emerging plan. Settlements where a made Neighbourhood Plan is in place, and which has local policies supporting some limited infilling (such as Wootton St Lawrence and Ramsdell Neighbourhood Plan 2019 “WSL NP”), should either benefit from a defined SPB, or Draft Policy HGG1 requires extending to allow for development within the built-up areas of villages.  Otherwise, the draft Local Plan policies for the countryside would have the effect of deleting any conflicting locally derived policies once adopted (where there is a conflict between policies in different parts of the Development Plan, the most recently adopted policy takes precedence). 

In the WSL NP example, only Ramsdell has an SPB, Wootton St Lawrence does not, despite the two villages being linked by the joint Neighbourhood Plan policies.  TMCL supports the general selection criteria for SPB villages as being those with at least 150 residents.   However, the 2020 sieving exercise did not include Wootton St Lawrence which has a population of around 200 at (2011 census) and has a number of local business within it employing at least 50 people (according to the NP survey).  

Accordingly, draft Policy HSG1: New Housing in the Countryside would have the effect of overriding the WSL NP Policy WSL5 and would not allow the infilling of undeveloped gaps in the built-up area.  Under limb 14, the criteria sets an upper limit of 4 (net) new dwellings in specific circumstances, whereas the WSL NP does not set an upper threshold, instead setting out specific ‘character’ criteria to be met.

The supporting text (para 10.4) recognises the large number of smaller settlements in the rural area, but the suggested flexibility is not included in the corresponding draft policy HSG1.  Instead, HSG1 seeks to restrict housing in these smaller villages in a similar manner as if they were in an open countryside location. This does not reflect the locally derived policies in WSL NP and other NP areas and overall, Policy HSG1 is also not supported.

TMCL also notes that draft Policy HSG1 has limb 1, 11 -16 inclusive. Limbs 2-10 inclusive are missing. 

Change required:

Policy SPS1 should include more smaller villages (including Wootton St Lawrence) and define Settlement Policy Boundaries or, in the alternative, Policy HSG1 requires updating to facilitate limited infilling where appropriate within built-up areas of smaller settlements where no SPB is identified.

Policy HSG1 text/subsection numbering needs checking.

HSG6: Specialist Accommodation for Older People and those with Specialised Needs

TMCL supports the principle of a specific policy for older persons housing. It is likely that additional windfall sites will be required to meet the identified needs for older persons housing/specialist housing in addition to any provision within strategic sites.  The 2020 Housing Market Assessment confirms that the over 65 population is predicted to increase by circa 15,000 by 2040.  The different household groups and needs cannot be met solely through the new housing stock providing accessible and adaptable homes on the allocated sites. 

TMCL consider that the policy, as currently drafted, is too restrictive.   Whilst it is appropriate to support such development within SPB’s, any qualifying sites will be competing with other developments for market and self-build housing.  It is important to acknowledge there may be limited supply for other forms of specialist housing within SPB’s as a result.  Other windfall development adjacent to SPB’s are limited by draft Policy HSG6 to care uses (predominantly class C2) in exceptional circumstances and only where it can be proven there are no more suitable and deliverable sites within SPB’s in which the need arises. This is too restrictive and places undue pressure on applicants with suitable edge sites to prove that any available urban land within SPB’s is not readily available. 

There is no policy provision to deliver purpose-built retirement accommodation in other suitable locations without an element of care in non SPB settlements or in suitable locations that are sustainable, perhaps having access to public transport, established leisure facilities or other local shops and services.  The factors used to define an SPB are based upon key factors (such as primary schools) that do not fully relate to older persons requirements.  Villages that support healthcare services and recreation sports/leisure facilities and local shops and/or have a regular (daily) bus service were not selected for SPB’s as all those criteria were not considered to be ‘Key Services’ or indicators of a village’s sustainability for planned growth.  This has the effect of ruling out the very locations and settlements that may be wholly suitable for retirement living.  HSG6 should include other criteria for development to ensure that it is not overly restrictive and the plan, when taken as a whole, will deliver sufficient specialist housing for this important group.

Notwithstanding this there will always be requirements that it will not be possible to fully plan for and therefore flexibility should be built into the plan to allow a dynamic and proactive approach to be taken.  A criteria-based policy which provides information on defining suitable locations/areas that would be considered acceptable through a planning application would help deliver specific housing products. This would help guide development that is ‘non-standard’ in a fair and proactive way.

The need to accommodate specialised housing including Older Persons homes, assisted living and care facilities should be positively addressed through policy.

The retirement living industry has many facets from home ownership through to rented accommodation with varying levels of care needs.  The current consultation is very much focused on general growth requirements across all housing types and how to spatially distribute the housing numbers rather than any delve further down into specific needs and how these might be accommodated.  This spatial approach does not necessarily lend itself to the proper consideration of meeting identified specialist housing needs, such as for older persons in suitable, accessible locations close to existing main centres (i.e. to avoid people having to relocate to another settlement) and create a policy environment where sufficient places are available but also to offer choice on the type of home. 

The demand for this sector of the community is evidenced through the relevant HMA study.  The authority conducted the older persons survey and reported the results in 2020.  The most substantial increases of older persons in Basingstoke and Deane between 2020 and 2040 is predicted to be across the varying tenures and types (sheltered, extra care, supported living).  The study concludes a need for circa 700 sheltered housing spaces; 452 people will be in need of registered care which is not being met through the planned growth and is confirmed as additional requirements to the local housing need.

The scale of growth currently planned for will not therefore meet identified or predicted demand for this sector of the community. The spatial options relate to general growth requirements and are not predicated on the particular needs of this sector.

Alongside any spatial strategy for general growth, the Council should consider a criteria-based strategy for meeting these additional needs.  For example, this need will not properly be met through a basic policy requiring [x]% of any housing site to be set aside for retirement living.  The strategy should recognise the nuanced components required to deliver suitable homes to meet varying needs and the fact that this growth would be better supported by specific allocations or a site-based policy criterion.   

The plan should consider including dedicated policy areas in the emerging plan for meeting specialist housing schemes such as housing for older people in the form of an integrated retirement community (IRC) facility providing retirement homes, extra care housing, care home with a range of on-site facilities such as café/restaurants, leisure facilities, hairdressers, libraries, lounges, permanent staff presence etc.  providing clear choice for older people/households to relocate could release other family homes into the market.   The current consultation evidence base identifies the acute need, but the proposed allocations do not offer any specific strategies to deliver it.

In the alternative, any site-based policy to support the provision of dedicated schemes for this sector should be sufficiently flexible to allow larger purpose-built schemes to come forward beyond settlement boundaries where certain criteria are met. This can include edge locations where schemes are genuinely capable of accessing relevant services and facilities in close proximity, or relatively self-contained sites where those day-to-day amenities are provided on site.