Regulation 18 draft Local Plan

Object

Representation ID: 4992

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

Whilst the importance of responding to the findings of the latest HMA is recognised, Policy H4 should be revised to provide additional flexibility for housing mixes to take account of evidence of market demand, site and settlement specific considerations, and viability.

Policy H4 allows for "other up-to-date evidence of local housing need". Also, density is covered by Policy H3.

Object

Representation ID: 4993

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

Further evidence is required to justify the requirement of standards that go over and above national guidance. That should be carefully considered within an update to the Whole Plan Viability Assessment, which should be underpinned by up-to-date evidence regarding building and labour costs.

With that said, WDH welcome that Policy H5 allows for flexibility in the delivery of Part M4(2) Category 2 housing to take account of feasibility-related issues, but consider that it should also allow for additional flexibility to take account of site and settlement specific considerations and viability in light of the above considerations.

The Government has announced that M4(2) is to become the default accessibility level, with M4(1) on an exceptional basis when M4(2) is impractical. M4(3) can be required in the local plan when need is evidenced, which it is. Paragraph 8.42 of the Whole Plan Viability Assessment states: "In the base appraisals, it is assumed that all new homes are to be designed to be Accessible and Adaptable (M4(2)) and on sites of 100 and larger, 1% of homes (being 3% of affordable
homes) will meet Wheelchair Adaptability (M4(3)a)."

Object

Representation ID: 4994

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

A more effective approach is to identify specific sites for the delivery of wholly SCB development, because:
- Entries to SCB registers are not means tested and do not provide an accurate position on the number of people who could feasibly and viably build out an SCB plot, and often relate to a desire for SCB in specific locations rather than on market housing sites.
- Delivering SCB housing within market housing schemes can be practically challenging and has the potential to undermine the realisation of consistent design principles across a scheme, and can also negatively impact on delivery timescales.

Policy H6 and its supporting text provide a balanced approach that takes account of the problems that can sometimes occur when integrating SCB within a larger site. It is accepted that the data on SCB registers have certain limitations, but a large number of SCB consents are granted annually in Rutland and it is not believed that this meets all need or demand, which is evidenced in the HMA. Further provision is required, which this policy aims to address. As stated in the supporting text, allocation of sites solely for SCB was considered, but is not considered appropriate or necessary at this time.

Support

Representation ID: 4995

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

WDH supports the delivery of affordable housing and, as set out in response to Policies SS1, SS3 and H1, consider that additional development should be facilitated to address the affordability issues arising in the County. In particular, suitable medium-sized sites within larger villages (including Land at Mill Lane, Cottesmore) should be brought forward for development within this plan period, which would deliver an increased quantum of affordable housing.

The support of Policy H7 is noted. Other policies cover the spatial strategy and site-specific allocations.

Support

Representation ID: 4996

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

As an East Midlands-based family-run housebuilder, WDH are committed to enhancing the skills of local tradespeople and providing employment opportunities within their residential developments. Therefore, the intention of Policy E6 is welcomed. WDH would, however, appreciate clarification as to the stage at which Employment and Skills Plans are required, and ordinarily would expect this to be a condition of a detailed planning approval, by which stage information on the sourcing of labour will be fixed.

Support noted. Agree, there is a need to set out the stage at which Employment Skills Plans are required.

Support

Representation ID: 4997

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

As a champion of high quality design, WDH supports the intention of Policy SC3. It is noted, however, that the use of the word “compact development” within requirement 2a of the policy is unusual and perhaps would be better phrased as “development at an appropriate density.”

Moreover, requirement 6 states that all major development should demonstrate compliance with Manual for Streets, Building for a Healthy Life and Streets for a Healthy Life. There are quite significant overlaps between those documents and, therefore, RCC should consider whether such requirements would unduly burden the potential delivery of development.

‘Compact development’ term aligns with the National Design Guide (B1 Compact form of development).

Manual for Streets is the guidance for street design that should be followed, Building for a Healthy Life is referenced in the NPPF and Streets for a Healthy Life is a companion guide to Building for a Healthy Life and so reference to these documents is justified in the pursuit of development that is well designed as required by the NPPF.

Support

Representation ID: 4998

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

It is recognised that Policy SC7 seeks to require on-site Public Open Space (POS) provision only from sites of 10 dwellings or more. The provision of high-quality and accessible POS is, however, an integral part of supporting healthy communities and, therefore, it is important that RCC ensures there is a greater mix of sites within sustainable villages to ensure that such benefits are delivered. That is discussed in further detail in WDH’s response to Policy SS3.

noted

Object

Representation ID: 4999

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

The requirement for developments to achieve a 15% BNG exceeds the requirements of the Environment Act without justification.

Even if justified, RCC must consider other implications. Many sites would be unable to deliver this on-site without a significant reduction to their capacity, or alternatively, credits would need to be purchased. RCC should consider whether there is infrastructure in place to support that, or whether such requirements would render development proposals unviable. In that regard, the position within the Whole Plan Viability Assessment that the delivery of a 15% BNG is a “modest” cost is unjustified.

Comment noted. Change from 15% to 10% as a higher percentage than the statutory objective of biodiversity net gain needs to be evidenced. In order for the Local Plan to be deemed sound this uplift above the mandatory level must be robustly evidenced.

Object

Representation ID: 5000

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

The purpose of this policy is unclear, as it does not differentiate from earlier policies relating to drainage or POS provision.

The purpose of Policy EN7 is to conserve the existing GBI and promote the opportunity to create new high quality GBI. It is designed to ensure no new development has an adverse impact on existing GBI.

Support

Representation ID: 5001

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

WDH is committed to funding and delivering the infrastructure required to support development, and in that regard WDH’s response to Policy SS3 highlights how an increased level of growth in the large villages will support existing and new services and facilities.

Policy INF1 makes reference to CIL. However, the plan is likely to be subject to the forthcoming planning policy reforms, which have made reference to a new Infrastructure Levy, which the RLP will need to consider. Notwithstanding that, WDH note the importance of ensuring that CIL Schedules (or their replacement) are kept up to date throughout the plan period.

Comment Noted. Section 106 agreements, the Community Infrastructure Levy (CIL) and the proposed Infrastructure Levy are all similar in that they impose additional conditions on the developer, linked to planning permission. Section 106 is bespoke and negotiated and Section 106 contributions can be used for a number of purposes, including schools, clinics, or affordable housing. The Community Infrastructure Levy is a financial obligation, based on a published tariff schedule and based on the square meterage of a development. The advantage of this for both developers and local authorities is that it gives more cost certainty and reduces ambiguity. It is proposed that IL will replace CIL and potentially accommodate all financial contributions currently dealt with by way of section 106 agreements and CIL. IL would be “values based” (including consideration of increase in land value) whereas CIL is a fixed charge broadly based on net additional floor space. However, IL may not be taken forward.