The local plan should both allocate non-strategic sites and define settlement boundaries around the District if it is to meet its role and purpose under the NPPF.

The settlement boundary fails to include the Land South West of Willetts Way which was found in the Housing Economic Land Availability Assessment (HELAA) to be suitable, available and achievable for up to 10 units (HLX0006).

As with Policy S1, we are in agreement with the Draft Local Plan defining Loxwood as a ‘Service Village’ in terms of settlement hierarchy with a need to direct growth to the most accessible and best-connected locations, including villages with good public transport options.
We seek to acknowledge the policy discussion on settlement boundaries, and support the presumption in favour of sustainable development within the settlement boundary of service villages.
However, we consider the Draft Local Plan to be ‘ineffective’ and ‘unjustified' in this respect by giving the power to define the Settlement Boundaries to Neighbourhood Plans. The Draft Local Plan cannot be ‘positively prepared’ when suitable, available and achievable sites are left fragmented and overlooked by Parish Councils creating piecemeal plots outside of the settlement boundary for often unjustified reasons, the Neighbourhood Plan process being subject to lesser scrutiny (having only to meet basic conditions) than local plans.
In line with our comments on Policy S1 – Spatial Development Strategy, the local plan should both allocate non-strategic sites and define settlement boundaries around the District if it is to meet its role and purpose under the NPPF.
In relation to Loxwood for example, the settlement boundary as defined by the Neighbourhood Plan is not representative of the current village and its settlement, or suitably reflective of the levels of housing growth and allocations required. The current settlement boundary is shown below in the Settlement Boundary (Loxwood Neighbourhood Plan Reg 15) (Figure 4). The settlement boundary fails to include the Land South West of Willetts Way which was found in the Housing Economic Land Availability Assessment (HELAA) to be suitable, available and achievable for up to 10 units (HLX0006). The site is clearly sustainable, being close to the village centre, and associated services but was excluded for unjustified reasons through the previous Neighbourhood Plan process.
Furthermore, the settlement boundary also excludes the High Street and associated residential properties to the south of the village centre which are historically and currently part of the village. The historic map shown below (Historical Ordnance survey map dated 1912) shows the small settlement of Loxwood at that time with the junction of Station Road and the High Street and only a small number of properties but the residential dwellings on the High Street were central to the evolution of the village and close to services, facilities, surgeries and the school which grew around them. To exclude the High Street and land to the rear including Land South West of Willetts Way is illogical and unjustified.
Figure 6 indicates where the logical and justified settlement boundary should be to the south of Loxwood (represented by the red line). The inclusion of this area is both a sustainable allocation of 10 new homes at Land South West of Willetts Way, but also a more accurate reflection of the actual settlement boundary of the village, through the inclusion of the historic ‘High Street’.
In order for the Draft Local Plan to be ‘justified’ and ‘effective’ in delivering housing through small scale sites, the Local Plan needs to specify the settlement boundaries and allocate sites, and not delegate to Neighbourhood Plans.