Response from Mr Tom Whitehead, Brookhouse Group
1. Mr Tom Whitehead, Brookhouse Group : 22 Feb 2018 15:55:00
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RE: Grange-Over-Sands Parish Neighbourhood Plan, Submission Version September 2017
The Brookhouse Group is a north-west based property developer, with a series of active developments in Cumbria and nationwide. We have a development agreement in place with the landowners of the Kents Bank allocated site, and have held pre-application meetings with both SLDC & CCC (as LPA and infrastructure consultee) and the Neighbourhood Plan (NP) Steering Group (GOSNPSG) in respect of the Kents Bank site. It is in this regard that we submit the following comments to the consultation on the above.
Representations were submitted by Garner Planning in June 2016 on behalf of the landowner, and we are disappointed that points therein have not been responded to this latest draft. As such, and in the interests of keeping Inquiry submission documents to a minimum, we would iterate that that representation remains valid.
In addition to this however, we would make the following broad observations:
• Housing need & mix: we recognise the GOSNPSG’s informed opinions on these very complex issues, and in meetings with their representatives, including the Chair, we have agreed to work with these issues. But we must re-assert the very serious issues that arise from overly prescriptive policy on these matters: need and mix are very complex, and regularly changing issues. The NP is already based on data that is 7/8 years old (the Core Strategy and the Census), as well as data that is not officially recognised in the formulation of housing needs assessments (local surveys). The NP is due to be valid for another 9 years (at which point it would be relying on 17 year old data). Instead, the plan must be able to respond to changing circumstances. Being overly prescriptive could undermine the delivery of any housing at all, let alone the housing the NP seeks. Instead, the NP’s aspirations should be explicitly set out as aspirations, and the NP policy should instead explicitly defer to the most up to date data available at the time development is proposed: be that SLDC data, or robust data presented by the developer, etc. The NP aspirations would then become a material consideration to inform the LPA. Government is quite clear that town planning (including neighbourhood planning) must be Development Plan led.
• Employment: we recognise and applaud the aspirations to bring meaningful additional employment to the area. We have discussed this at length with the GOSNPSG, and understand that that group recognises and supports the provision of employment across a range of different types, including within retail, and within care facilities; such uses can provide the employment that the GOSNPSG seek, including roles from skilled to unskilled, part and full time, etc. The need for retail and care facilities is clearly recognised by the GOSNPSG, and the NP should explicitly state that employment can be generated by a number of sources, including retail and care home facilities.
• Extra-Care Housing: there is strong evidence to suggest that there is a market for the delivery of extra care housing in the NP area, and that the demand is likely to increase. The NP however should be careful however not to preclude its delivery in the NP area by explicitly prioritising one site, as per policy 9. We have no concerns the GOSNPSG expressing a desire to see this site come forward for this use, but this aspiration should not be at the expense of other sites where this growing need could be met. The NP should explicitly recognise that care facilities can be delivered elsewhere in the NP area.
• Design Guide: enclosed with this representation are specific comments on the Guide by our architect. In addition, we enclose the Urban Design Framework that has been worked up for the Kents Bank site, and presented to GOSNPSG (and to the LPA) at our most recent meetings: it would be helpful if this graphic were included within the NP, as a meaningful response to the Development Brief and the NP.
We would be grateful for the consideration of these representations, and we would record now our intention to appear before the NP inspector, in due course.
Kind regards,
Tom Whitehead MRTPI MCIPR
Brookhouse Group
Group Town Planning Manager
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