Local Plan 2036: Issues and Options Stage

Comment ID 21235265//1
Document Section 1. North Somerset Local Plan 2036: Issues and Options Document Potential new policy areas Q49. Do you have any views on our intended approach to development on previously developed land in the countryside? What type of sites may be suitable for residential redevelopment? View all on this section
Respondent Christian Leigh View all by this respondent
Response Date 10 Dec 2018

The NPPF 2018 does not display a hierarchy for land uses when considering the redevelopment of previously developed land outside settlements.  Paragraph 117 supports the ‘effective use of land in meeting the need for homes and other uses’, and states that policies should make ‘as much use as possible of previously-developed or ‘brownfield’ land’. Paragraph 118 encourages benefits equally on both urban and rural land, and gives substantial weight to using suitable brownfield land within settlements, but also promotes and supports the development of under-utilised land and buildings – without definition of any location.

Paragraph 120 recognises that there are changes in the demand for land, and so new uses may come forward. Again, this is not location-specific, and it is clear that such demand will vary in urban and in rural areas.

Paragraph 121 states that ‘Local planning authorities should also take a positive approach to applications for alternative uses of land which is currently developed but not allocated for a specific purpose in plans, where this would help to meet identified development needs.’ There is no requirement in rural areas for this only to be for employment purposes: if there is a need for housing in a rural area, then that is supported by this policy. Indeed, part a) of the paragraph recognises that housing may be a new use, and that it should only be specific key employment sites that are to be protected.

The Option put forward by the Council to seek employment or community use runs counter to all the above. It proposes a blanket presumption that previously developed land in rural areas will remain employment, regardless of any consideration of alternative use. The NPPF does not state this: it is only where there are specific key employment sites that there should be a presumption of employment use continuing.

The Government supports all development as new uses in the rural area. Housing as a use on rural previously developed land seen equally to employment use. The proposed option for this new policy approach would therefore be contrary to Government policy, and there is no special justification for it. The Policy approach should be to accept redevelopment of previously developed land for all alternative uses, subject to the normal development control criteria.

The proposed option for previously developed land in rural areas is inconsistent with Government guidance.