Regulation 18 draft Local Plan

Object

Representation ID: 6921

Received: 08/01/2024

Respondent: Avant Homes

It is noted that the Consultation was prepared and released in advance of the recent (December 2023) changes to the NPPF. The Council, therefore, need to consider whether any information contained within that guidance has any impact on the emerging Plan. If so, it is likely that further consultation will be required.

Object

Representation ID: 7313

Received: 08/01/2024

Respondent: Avant Homes

Avant welcome acknowledgement in the Vision to provide a range of high-quality housing that meets the County’s housing need. However, it is considered that the inclusion of ‘minimum’ implies that the Council will seek to limit the amount of housing at this level. The Council should be aspiring to reach a position above this figure in recognition of the connection between housing and future economic growth of the County and to ensure that there is adequate flexibility in the delivery of sites.

Object

Representation ID: 7314

Received: 08/01/2024

Respondent: Avant Homes

Whilst Avant supports the national intentions to set standards for energy efficiency through the Building Regulations, it is important that the Council do not seek to deviate from the Government policy position - either in terms of bringing additional enhancements in earlier than National Policy, or to a level that exceeds the National requirements. To do so, could lead to unnecessary delays to delivery of housing, and undermine the delivery of wider environmental objectives. As a principle, therefore, Avant would object to any policy which seeks to set higher benchmarks and standards when considered against National requirements.

Object

Representation ID: 7315

Received: 08/01/2024

Respondent: Avant Homes

This policy is ambiguous and does not provide enough detail as to how it can be proven that that all residential proposals provide the maximum generation of renewable energy that is viable on site. This implies that developers will need to submit a scheme viability with every application, which is not considered achievable or realistic and will cause unnecessary delays during the application process. This policy should be deleted and simply dealt with via Building Regulations.

Object

Representation ID: 7316

Received: 08/01/2024

Respondent: Avant Homes

The Council should not be seeking to establish policies which go above and beyond the national policy position. This can cause unnecessary delays when this matter is already dealt with via Building Regulations. This policy should be deleted.

Object

Representation ID: 7317

Received: 08/01/2024

Respondent: Avant Homes

The NPPG is clear that Standard Method is a ‘starting point’ for a district’s housing requirement and there are a few factors which should be taken into account when considering whether this figure should be increased - including the need to provide a range of choice of sites, the need for flexibility, viability considerations and whether higher levels of open market housing are required in order to secure increased delivery of affordable housing.

If the Council are to meet the Vision for providing the ‘minimum’ amount of affordable and market housing, then at least the higher position from the 2019 SHMA should be taken, which is 190 dwellings, with a 10% contingency.
Council also needs to set out clear intentions and guidance on how housing delivery is to be effectively monitored so that if there is a delay to delivery can address any shortfall as soon as possible.

Object

Representation ID: 7318

Received: 08/01/2024

Respondent: Avant Homes

Avant welcome the specific reference to ‘Land west of Ashwell Road, Oakham’ within Policy H1 for future delivery of 286 dwellings and can confirm our formal legal interest and desire to develop the land.

In light of earlier comments made regarding housing requirement and delivery, Avant consider that the site should be upgraded from being a Reserved Site (H1,g) to a formal residential allocation and be contained within the PLD area boundary. This would ensure that the site can be brought forward by Avant as easily and quickly as possible.
Avant note that a number of the proposed allocations may be delayed in deliver as they are brownfield with uses on site, may have viability issues and sites such as Stamford North likely to take some time.

Support

Representation ID: 7319

Received: 08/01/2024

Respondent: Avant Homes

Avant support the requirement for the Plan to deliver a mix of house types/sizes. Avant would be unsupportive of the introduction of more prescriptive policies and welcome the flexibility provided for in the current drafting i.e to enable local needs at any specific time period to be provided for.

Object

Representation ID: 7320

Received: 08/01/2024

Respondent: Avant Homes

Avant consider that it is important that the Council do not seek to deviate from the Government policy position in advance of the latest policy and guidance being finalised, and that any benchmark should not be set above the 10% biodiversity net gain position, as set out in the Environment Act. Developers and landowners incur significant costs with meeting the 10% provision and it is important to ensure that BNG does not prevent, delay or reduce housing delivery.

In addition, it should be noted that large and complex sites where the development is phased, should not be obligated to deliver 10% BNG on each phase, as the guidance is clear that the 10% BNG requirement must be delivered at the end of the development.