Regulation 18 draft Local Plan

Object

Representation ID: 4981

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

WDH's response to Policies SS1 and H1 highlight that the spatial strategy should be refined to strengthen the plan's robustness. Given the need to support the County’s rural communities and address the existing affordability issues, the overall housing requirement should be at least 3,905 dwellings. Therefore, additional allocation sites should be identified, particularly within the larger villages to support their ongoing vitality. WDH's site at Land North of Mill Lane, Cottesmore (Reserve Site H1.a) is a suitable development site in the most sustainable 'larger village' settlement, and should therefore be allocated for development in this plan period.

Comments noted. Detailed responses are provided under representations for policies SS1 and H1.

Support

Representation ID: 4982

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

WDH welcomes the reference to the delivery of “a wide range of high-quality housing to meet the County’s minimum housing need and which meets the needs of all sections of the community.” As set out in response to Policies SS1 and H1, RCC must identify additional housing allocations to ensure that the County's needs are fully met, with an appropriate buffer. Principally, that should be focused on the larger villages such as Cottesmore, which play a critical role in delivering the services and facilities that support the residents both of the villages themselves and the wider rural hinterland.

Support noted

Object

Representation ID: 4983

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

WDH suggests that Policies CC2 and CC4 are removed, and that the RLP takes a more flexible approach to requiring developments to meet national sustainability standards; which would future proof the policy.

Disagree that CC2 should be deleted. LPAs have the power under the Planning and Energy Act 2008 to adopt planning policies that set higher targets for energy performance standards for development in their area than the national baseline providing that they are reasonable, comply with the usual plan-making requirements and do not affect the viability of new development to an unreasonable extent. A number of development plan documents have passed examination which have successfully included energy efficiency and/or other emissions reduction requirements beyond those of the Building Regulations. Such policies allow LPAs to meet the obligation on them to ensure development plan documents include policies designed to secure that development of land in the local authority’s area ‘contribute to the mitigation of, and adaption to, climate change’. The Future Homes and Buildings Standards (which aims to improve the energy efficiency and carbon emissions of new homes and non-residential buildings through the Building Regulations system) should take effect in 2025. With such regulations still being debated and no legal guarantee that they will come into effect in 2025, and recognising that buildings are the UK’s second-highest emitting sector, the Local Plan sets out a positive strategy through the Climate Change policies for carbon reduction and to mitigate against the impact of climate change. The Plan does, however, acknowledge that a key consideration for Policy CC2: Design Principles for Energy Efficient Buildings is its impact on the viability of new developments. It is intended that further work to update the cost evidence for a number of options for the wording of CC2 will be undertaken to inform the next stage of the local plan. This will build on the Whole Plan Viability Assessment (2023). Any changes to the draft policies arising from consultation responses and/or new evidence on viability in relation to the climate change policies will be consulted on through the Reg 19 consultation.

Object

Representation ID: 4984

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

The requirements of Policy CC6 are particularly specific in some regards, for example in requiring outside hard surfacing to be permeable unless there are technical and unavoidable reasons for not doing so in certain areas, and in requiring all flat roofs to be green roofs unless they are being used for photovoltaic or thermal solar panels.

It is suggested that the wording within this policy is softened somewhat to encourage the use of such measures where technically feasible, appropriate to the local context, and viable.

Comments noted. Para 158 of the NPPF states that ‘Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk,…..water supply….' The Water Management criteria in CC6 are justified as they meet these requirements set out in the NPPF with flexibility built into the wording of first bullet point ‘(unless there are technical or unavoidable reasons for not doing so in certain areas)’ and is in the interests of sustainable water management. Agree the second bullet point on drought resistant planting schemes is perhaps too prescriptive and may conflict with policies in the Local Plan that seek to ensure enhancements for biodiversity through landscaping (eg Policies EN3, EN4 and EN7). Agree third bullet point is too prescriptive and should be more flexible. Disagree fourth bullet point too prescriptive as even such small measures can reduce demands on water supply, and thereby carbon emissions, in new residential development.

Object

Representation ID: 4985

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

WDH's response to Policies SS1 and H1 highlight that the spatial strategy should be refined to strengthen the plan's robustness. Given the need to support the County’s rural communities and address the existing affordability issues, the overall housing requirement should be at least 3,905 dwellings. Therefore, additional allocation sites should be identified, particularly within the larger villages to support their ongoing vitality. WDH's site at Land North of Mill Lane, Cottesmore (Reserve Site H1.a) is a suitable development site in the most sustainable 'larger village' settlement, and should therefore be allocated for development in this plan period.

Comments noted. The matter of housing need and requirement is considered in detail under Policy H1

Object

Representation ID: 4986

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

Policy SS2 simply repeats the provisions of the NPPF, which is contrary to the Government’s guidance in relation to plan making. The policy should, therefore, be deleted.

Agree the policy as written does not provide criteria against which a planning application can be assessed and largely reflects national guidance.
However it is useful for the local plan to clearly set out what is expected for the submission of planning applications and it is therefore suggested that the policy becomes supporting text within the plan

Object

Representation ID: 4987

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

WDH's response to Policies SS1 and H1 highlight that the spatial strategy should be refined to strengthen the plan's robustness. Given the need to support the County’s rural communities and address the existing affordability issues, the overall housing requirement should be at least 3,905 dwellings. Therefore, additional allocation sites should be identified, particularly within the larger villages to support their ongoing vitality. WDH's site at Land North of Mill Lane, Cottesmore (Reserve Site H1.a) is a suitable development site in the most sustainable 'larger village' settlement, and should therefore be allocated for development in this plan period.

Noted. Site suitability considered under policy H1.

Object

Representation ID: 4988

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

It is unclear what status this policy will give to the St George’s Barracks Opportunity Area and how / when RCC envisages that the site will come forward, although the approach to not include it in Policy H1 as a proposed allocation is welcomed. In that regard, WDH query how the position in relation to the deliverability of this site has altered since the previous RLP was ultimately withdrawn due to fundamental questions specifically in that regard.

Comments noted. The aim of Policy SS5 9now SS4) is to provide a framework for the development of SGB in the likely event that it becomes vacated during the life of the local plan. In not including it in Policy H1, the plan still identifies sufficient housing land to meet housing needs thus removing the reliance on SGB for housing land. The Council took the decision for SGB and Woolfox alike to be identified as Future Opportunity Areas and for their development to be considered in a separate DPD.

Object

Representation ID: 4990

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

WDH's response to Policies SS1 and H1 highlight that the spatial strategy should be refined to strengthen the plan's robustness. Given the need to support the County’s rural communities and address the existing affordability issues, the overall housing requirement should be at least 3,905 dwellings. Therefore, additional allocation sites should be identified, particularly within the larger villages to support their ongoing vitality. WDH's site at Land North of Mill Lane, Cottesmore (Reserve Site H1.a) is a suitable development site in the most sustainable 'larger village' settlement, and should therefore be allocated for development in this plan period.

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.

Support

Representation ID: 4991

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

Additional allocation sites should be identified, particularly within the larger villages to support their ongoing vitality. WDH's site at Land North of Mill Lane, Cottesmore (Reserve Site H1.a) is a suitable development site in the most sustainable 'larger village' settlement, and should therefore be allocated for development in this plan period.
As set out in response to Policies SS1 and SS3, RCC should allocate the most suitable of the reserve sites within the larger settlements that have been identified in the LPPO. That includes Land North of Mill Lane, Cottesmore (Reserve Site H1.a), which is a suitable development site in the most sustainable larger village settlement, as reflected in RCC’s proposal to reserve the site for future development. WDH would appreciate the opportunity to work with RCC to discuss the opportunities for the residential development of the site in the forthcoming plan period to address the need for additional housing.

Support noted.