4.1 Planning considerations applied to all site opportunity assessments
Significant planning considerations
4.1.1. National planning policy, and existing local planning policies, include policies relating to specific environmental land use considerations which can significantly restrict or limit the opportunity to deliver development. We have called these ‘significant planning considerations’, and where these relate to a site opportunity and are likely to frustrate delivery of either homes or employment uses, we have discounted that site from consideration.
4.1.2. Our selections have been based upon the latest planning policy and guidance, and published information on these considerations (including data presented by Natural England and the Environment Agency) and any local evidence which was available at the time the assessments were undertaken. (Where new policy, guidance or evidence is published following the assessments we may need to review selection at subsequent stages of the plan making process).
4.1.3. These ‘significant planning considerations’ relate to environmental land use issues including flood risk, coastal change and European and internationally protected habitat sites (also including Sites of Special Scientific Interest).
Flood risk
4.1.4. The thrust of national planning policy is to avoid flood risk whilst preparing development strategies for local plans through the application of the sequential test. We have evidence which shows ‘flood extents’ for different sources of flood risk, but the evidence does not define risks in the same way and in some instances more detailed site-specific assessment may be needed to accurately understand the nature of the risks.
4.1.5. For this reason, we have initially relied upon the ‘moderate’ (Flood Risk Zone 2) and ‘high’ (Flood Risk Zone 3) Flood Risk Zones which present fluvial and coastal flood risks when screening potential site opportunities for flood risk.
4.1.6. We have only discounted site opportunities from further consideration where the extent of the Flood Risk Zone would inhibit delivery of development. Some sites may be subject to moderate and/or high risks and still be presented in the site opportunities where we think there is a possibility of applying a sequential approach to the site’s redevelopment in accordance with paragraph 175 of the NPPF, December 2024.
4.1.7. Where a site could also be affected by other sources of flood risk (e.g. surface water flood risk or groundwater flood risk) we have noted this and outlined the steps that need to be followed to explore and properly understand the nature of any risks to inform preparation of the local plan. In these circumstances, and subject to exploration of this issue, there is a possibility that a site opportunity may need to be discounted from consideration at a later stage in the plan making process.
Coastal change
4.1.8. Coastal erosion is defined in the Flood and Water Management Act 2010 as ‘the erosion of the coast of any part of England or Wales.’ (Section 1 (4)). ‘Coastal change’ is a wider term that is used in national planning policy which is defined as ‘…an area identified in plans as likely to be affected by physical changes to the coast. Such changes include erosion, coastal landslip, permanent inundation or accretion.’
4.1.9. The thrust of national planning policy is to reduce the risks from coastal change by avoiding inappropriate development in vulnerable areas. National policy also states that Coastal Change Management Areas (CCMA) should be defined to identify land subject to coastal change and to clarify the types of development that will be appropriate in these areas.
4.1.10. We have not defined CCMA for all of Dorset’s coastline however the Purbeck Local Plan 2018-2035 does define CCMA for the section of coastline that was within the former Purbeck District.
4.1.11. We have used the areas shown as CCMA in the Purbeck Local Plan, the evidence of ‘indicative erosion’ presented in Shoreline Management Plans (SMP) and National Coastal Erosion Risk Mapping to define those areas where coastal change is likely to inhibit the delivery of development.
4.1.12. Where the evidence indicates that a site is likely to be subject to coastal change during the development’s lifetime, we have generally discounted the site from consideration. Following Planning Practice Guidance , we have also discounted all site opportunities being considered for homes where they overlap with an area that is likely to be subject to coastal change.
Habitat sites
4.1.13. The law relating to European and internationally protected habitat sites is set out in the Conservation of Habitats and Species Regulations 2017. Before we grant consent for plans (including the local plan) or projects (including decisions on individual planning applications) which are likely to have significant effects on a habitat site we must complete an appropriate assessment. Consent should only be given following the appropriate assessment for plans or projects that will not adversely affect the integrity of the habitat site.
4.1.14. The nature of the process set out in the regulations around avoiding adverse impacts, means that we think it is unlikely that development could be delivered on a site where a significant proportion of the same site is also designated as a habitat site and this would inhibit the delivery of development i.e. the development would adversely affect the integrity of the habitat site.
4.1.15. Local evidence gathered for the Dorset Heathlands Special Protection Area (SPA) and Dorset Heaths Special Area of Conservation (SAC) also indicates that residential development within an area close to the site‘s boundary (400 metres) is likely to adversely affect the integrity of these sites. The local evidence suggests that residential development in this area should also be restricted because of the limited opportunities to effectively mitigate adverse effects.
4.1.16. We think it is unlikely that residential development could be delivered on a site where a significant proportion of the same site is also defined as part of 400 metre area around a Dorset Heaths SAC, or Dorset Heathlands SPA habitat site, as this would inhibit the delivery of development. For this reason, sites that are affected in this way have been discounted from consideration.
4.1.17. Sites of Special Scientific Interest (SSSI) are notified and protected under the Wildlife and Countryside Act 1981. There are restrictions as to what can be done on SSSI land, and each SSSI will have a list of operations that require consent from Natural England. National planning policy advises that planning permission should not be given for development on land within, or adjacent to, an SSSI that is likely to have an adverse effect on it, either individually or cumulatively.
4.1.18. We have assumed that new homes and employment uses on SSSI are likely to have adverse effects. We think it is unlikely that residential development and employment uses could be delivered on a site where a significant proportion of the same site is also defined as SSSI as this would be likely to inhibit the delivery of development. For this reason, sites that are affected in this way have been discounted from consideration. See Appendix 1 ‘Generic’ for ‘Site Opportunities Selection Criterion A’.
Other planning considerations
Applying criterion relating to other planning considerations
4.1.19. In addition to considering ‘significant planning considerations’ when reaching a decision on whether a site was suitable for selection, we have also taken account of a broader range of ‘other planning considerations’. Each of these planning considerations is broadly described in more detail in the following section of the report, and the criterion relating to these considerations are presented in Appendix 1. The list presented in this report is not necessarily exhaustive as depending on the site’s characteristics and context, other considerations may also be relevant when assessing suitability.
4.1.20. Many of the site opportunities we have assessed as part of the selection process were affected by one or more ‘other planning considerations. In these circumstances as part of the assessment, we have needed to determine the significance of the issue, alone or in combination, in restricting or limiting development and the opportunities for the impacts to be mitigated.
4.1.21. The assessment process has involved the application of professional discretion based on available information, a consideration of in combination impacts, the opportunities to mitigate impacts and any other relevant factors.
4.1.22. Rather than apply a rigid approach to scoring individual sites, we have arrived at balanced judgments about whether a site was suitable for selection as an opportunity. The weight given to each of the matter’s rests on the specific circumstances of each site and the specific nature of the planning issues. In some instances, we have discounted sites from consideration where we judged that there would be in-combination impacts from a number of planning issues.
4.1.23. In order that all reasonable alternatives to meet Dorset’s development needs were examined, where we considered that more information was needed, or that suitable mitigation could be achieved, sites have been shortlisted for this consultation and ongoing consideration through the next stages of the plan making process.
4.1.24. As with significant planning considerations, our selections have been based upon the best available published evidence, policy and guidance at the time the assessments were made.
Other areas around habitat sites
4.1.25. We have not discounted site opportunities around habitat sites where development is likely to have significant effects, but where there are opportunities to mitigate adverse impacts on the site’s integrity. For example depending on the circumstances it may be possible to include infrastructure projects to mitigate nutrient pollution, infrastructure projects to mitigate recreational impacts, infrastructure projects to mitigate air pollution or measures to manage recreational activity linked with the development.
4.1.26. We have identified areas around a number of habitat sites in Dorset where certain types of development are likely to have significant effects and where mitigation will need to be provided alongside their development. These significant effects relate to the following issues:
- Recreational impacts - Dorset Heathlands (specifically areas outside the 400 metre area up to 5 kilometres), Poole Harbour, Chesil and the Fleet and New Forest
- Water quality impacts – Nutrient sensitive catchments
- Air quality impacts – Dorset Heathlands
4.1.27. There is a broad understanding between us and developers of these potential impacts, and effective approaches to mitigation. In some instances, we take responsibility for delivery of strategic mitigation to avoid adverse effects from the development, and in others, developers have the responsibility for delivering mitigation with our guidance and support. We may need to review and update the strategic approaches to mitigation as the plan progresses and we gain a clearer understanding on the requirement for development.
Green Belt
4.1.28. We have not discounted site opportunities that are also defined as part of the Green Belt. Green Belt boundaries can be changed as part of the Local Plan making process where there are exceptional circumstances, and the changes have been fully evidenced and justified.
4.1.29. In accordance with national policy, we will be exploring the opportunities for changes to boundaries as part of a review of the Green Belt through the next stages in the plan making process. Where relevant we have acknowledged when a site opportunity forms part of the Green Belt and explained that this issue will need to be explored further through the processes set out in national policy.
Designated landscapes (including National Landscapes and Heritage Coast)
4.1.30. We recognise our responsibilities under the Countryside and Rights of Way Act 2000 in respect of National Landscapes (Areas of Outstanding Natural Beauty), alongside national planning policies. In most cases we have not discounted site opportunities within National Landscapes, or where development on a site could affect the setting of National Landscapes. Despite this the issue is likely to require further consideration through the next stages of the plan making processes.
4.1.31. Similarly in most instances we have not discounted site opportunities within, or close to, the Heritage Coast but we recognise that the issue is likely to require further consideration through the next stages of the plan making processes.
4.1.32. Where relevant we have acknowledged when a site opportunity forms part of the National Landscape or Heritage Coast, or when development on site could affect the setting of landscapes and explained that this issue will need to be explored further.
Irreplaceable habitats
4.1.33. We acknowledge national planning policy relating to irreplaceable habitats (including ancient woodland). We have recognised in our assessments that where the whole of a site opportunity is also defined as an irreplaceable habitat it may be challenging to find ‘wholly exceptional reasons’ that clearly outweigh the loss of the habitat. In these instances for the most part we have discounted the site opportunity from consideration.
4.1.34. In those instances where development of a site opportunity could lead to the deterioration of an irreplaceable habitat we have acknowledged this issue and explained that it will need to be explored further in the next stages of the plan making process to fully assess impacts.
Heritage assets
4.1.35. We acknowledge that development on some site opportunities may have direct, and indirect impacts, on both designated and non-designated heritage assets. Our screening assessment of individual sites takes specific account of:
- Conservation Areas
- Listed Buildings
- Scheduled Monuments
- Historic Parks and Gardens
- Registered Battlefields
- World Heritage Sites
4.1.36. When screening sites we have also recognised the potential for non-designated heritage assets within and around sites.
4.1.37. In most instances and subject to the asset in question, we have not discounted site opportunities within or close to designated heritage assets, or where there is potential for non-designated heritage assets within a site. Despite this we note that issues relating to the impacts of development on assets may require further consideration through the next stages of the plan making processes.
4.1.38. In some instances, for example where a site is designated as a highly significant heritage asset, we have discounted site opportunities on the basis of this issue.
Transport, access and movement
4.1.39. We have considered whether it would be possible to achieve suitable access into a site opportunity, with or without works to the site or over adjoining land. Where we have found that it would not be possible to form a suitable access we have discounted site options from consideration.
4.1.40. We also recognise that development of different scales has impacts on the existing road network, and that location of development and relationship with existing transport infrastructure have impacts on the opportunity to encourage sustainable and active travel. Where appropriate we have made recommendations around the need for further consideration of these issues through ‘transport assessments’, ‘transport statements’ or ‘travel plans’, but have not discounted on the grounds of these issues alone.
Infrastructure
4.1.41. We have not discounted site opportunities because of inadequate provision of infrastructure alone. In those instances where we consider that investments in infrastructure may be needed to support delivery of the development, we have noted this and outlined the types of infrastructure that may be required. We acknowledge that issues around provision of infrastructure will need to be explored further in the next stages of the plan making process through the infrastructure delivery plan and when considering whether there are any site-specific requirements.
Amenity
4.1.42. In this context we have taken amenity to include planning considerations like potential overshadowing, overlooking/loss of privacy, noise and smells. Amenity considerations will vary according to the nature of development and the specific characteristics of the site and its setting. Amenity considerations do not include the protection of purely private interests such as value of neighbouring properties or loss of private rights to light. In most instances we have not discounted sites from consideration because of impacts on amenity, but we acknowledge that potential impacts may need to be more thoroughly explored as work on a site opportunity develops through the subsequent stages in the plan making process. In some instances, we may suggest that further assessments may need to be undertaken (for example noise impact assessments where a site is positioned close to a noise source) to guide subsequent selection processes.
4.1.43. Where we have judged that the nature of development being considered on a site opportunity would be fundamentally incompatible with an existing nearby use, we have discounted the site from further consideration.
Other relevant land use planning issues
4.1.44. We have also considered other planning matters that could affect the delivery of development on a site when assessing site opportunities. These include, but are not necessarily limited to:
- Existing land use – we have considered and taken account of any existing land uses where we think that they could impact on delivery of development
- Local matters – these can include any locally specific issues including specific issues relating to a particular site which we consider to be relevant to the delivery of development
- Tree Preservation Orders – we have noted when existing trees growing on a site are protected by a preservation order, and suggested that where appropriate they should be retained and protected during any development
- Contamination – we have noted where a site may be affected by contamination and indicated further steps to investigate this matter, as well as remediation
- Planning history – we have noted any relevant planning history. Where an earlier planning decision highlights a planning issue that might be equally applicable to development being considered through site opportunities we may discount a site from further consideration.
4.1.45. See Appendix 1 ‘Generic’ for ‘Site Opportunities Selection Criterion B’.
4.2 General distribution of growth
4.2.1. At this stage in the plan making process, we have sought to fully explore all reasonable opportunities for meeting locally assessed needs for development in Dorset. Our search has focused on the areas around existing towns and villages where services and facilities are concentrated and also taken account of planning considerations relating to broad areas and specific sites. Our approach to site selection will be refined and finalised during the next stages of the plan making process taking account of the strategic priorities in the Dorset Council Plan and giving an emphasis of providing high quality and affordable homes. This is translated into the Local Plan priority of meeting Dorset’s housing needs.
Homes for the settled community
4.2.2. We have used the settlement hierarchy, and established settlement boundaries to focus the search for site opportunities.
4.2.3. The settlements at Tier 1, Tier 2 and Tier 3 of our settlement hierarchy have been the focus for development opportunities. In broad terms sites within around 1 kilometre of these existing settlements have been considered and therefore site opportunities that are more than 1 kilometre away have been discounted. (See Appendix 2 for ‘Site Opportunities Selection Criterion 1’ for the settled community). An element of flexibility has also been used in instances where part of a site that is more than 1 kilometre away from a settlement has been retained if other parts of the site are within the rough 1 kilometre area.
Homes for the Traveller community
4.2.4. We think that the underlying principles relating to the selection of site opportunities for homes for the settled community are equally applicable when screening and reviewing Traveller site opportunities that do not relate to existing established sites (including those sites with and without planning permission).
4.2.5. We have therefore applied them when assessing Traveller site opportunities that relate to new sites.
4.2.6. There are also existing Traveller sites spread across the Dorset Council area. Some of these sites have planning permission, and some do not. Many of these existing sites are in rural areas outside the 1 kilometre search area around Tier 1, Tier 2 and Tier 3 settlements in our settlement hierarchy.
4.2.7. The 2022 GTAA provides a breakdown of need according to a baseline of existing sites and yards. In many instances the GTAA shows that there is a relatively modest need connected with existing sites and yards that arises from the natural growth of existing Traveller families. Other need arises from those sites without planning permission. National planning policy relating to Travellers states that as part of the plan making process we should aim to reduce the numbers of unauthorised developments and to increase the numbers of Traveller sites in appropriate locations with planning permission.
4.2.8. We have adopted a more flexible approach when selecting site opportunities connected to existing Traveller sites for their expansion, intensification or authorisation (for those sites which do not have planning permission). This approach takes account of national policy relating to Travellers, and the specific needs of existing Traveller families. For these reasons we have not ruled out Traveller site opportunities that relate to the expansion or intensification or authorisation of an existing Traveller site with or without planning permission that are location away from a Tier 1, Tier 2 or Tier 3 settlement. See Appendix 3 for ‘Site and Yard Opportunities Selection Criterion 1’ for the Traveller community.
Employment land
4.2.9. The larger settlements have a key role to play in the delivery of new employment opportunities because of their accessibility to labour, support services and infrastructure.
4.2.10. When selecting site opportunities for employment development, the role of existing settlements has been a key consideration. As with the identification of opportunities for homes, we have used the settlement hierarchy and existing ‘settlement boundaries’ to develop selection criteria.
4.2.11. While we have sought to focus new development close to the more sustainable settlements, there are existing employment sites across the Dorset Council area in more rural locations. These sites may be located outside the 1-kilometre search area identified around Tier 1, Tier 2 and Tier 3 settlements but they bring about economic activity and provide job opportunities.
4.2.12. To allow for the growth of these existing rural sites and businesses we have taken a more flexible approach in selecting site opportunities that are well connected to existing employment premises. Development opportunities in more rural locations that could make provision for the expansion of an established employment site have not been ruled out. See Appendix 4 for ‘Site Opportunities Selection Criterion 1’ for employment.