Extracted: page 36 from Independent Examiner's report on Winchcombe Neighourhood Plan

(full version is available below for download)

Policy 3.5: Meeting the needs for new homes for those of retirement age
Policy 3.5 seeks to allocate land at Almsbury Farm for new homes for those of
retirement age. However, whilst Paragraph 50 of the Framework supports the
provision of housing for older people, the Policy itself does not provide a decision
maker with a clear indication of how to respond to a development proposal. This is
because, over the course of nearly one and a half pages, it includes numerous
ambiguous references. These include the following:

Retirement age is not defined. People retire at all ages.

Meeting the needs is not based on an assessment of need, whereby the
allocation demonstrates that it meets such a need.
modest individual dwellings is an ambiguous, undefined phrase.
a degree of common site management is an ambiguous, undefined
phrase.
one or more central service buildings could allow for two, twenty, or any
number of such buildings. Further, it is unclear why a care home
comprises a central service building.
It is not clear for whose catering requirements a central service building (or
buildings) would be provided. Further, health treatments is undefined.

The above are taken from just the first five lines of the Policy. There are many other
ambiguous references in the fifty plus lines that follow. Taken as a whole, the Policy
doe not provide a decision maker with a clear indication of how to respond to a
development proposal. It does not meet the basic conditions.
The proposed site is located within the Winchcombe Conservation Area and is
adjacent to a Listed Building. The vague and ambiguous nature of Policy 3.5 means
that it does not have regard to the need to ensure that irreplaceable heritage assets
will be conserved in a manner appropriate to their significance. I note that this
results in conflict within the Policy itself.
Policy 3.5 is neither precise nor concise, as required by Planning Practice Guidance8.
It does not meet the basic conditions. I recommend:

Delete Policy 3.5 and supporting text

Delete reference to Policy 3.5 from Map

Ref: Planning Practice Guidance 41-041020140306.

36 Winchcombe and Sudeley Examiners Report

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