Regulation 18 draft Local Plan

Object

Representation ID: 7705

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

Policy H4 needs to allow the decision maker to have regard to range of factors alongside the up to date evidence of local housing needs. This should include housing market evidence, economic conditions, viability and site-specific circumstances, all of which may affect the most appropriate mix for a site.
A more flexible approach would support the deliverability of development and uses the evidence in relation to housing mix to guide development over the course of the plan period. There are also site specific circumstances where a mix of homes based on the County wide or local need would not be appropriate from a design point of view, for example in a street where one size of property dominates.
The requirement for all major sites of over 10 dwellings to make provision for specialist housing across all tenures including extra care and other forms of supported housing is unrealistic and impractical. This type of provision will only be viable to run by providers at a certain scale, this part of the policy needs to be revisited.

Policy H4 provides for the up-to-date provision of housing needs information, alongside the latest HMA. Criterion (b) also allows for demand to be taken into account. Policies H3 and SC3 allow for site-specific factors. There may be scope to make clearer when specialist housing for older people, especially extra care housing which needs a larger development, is required.

Object

Representation ID: 7706

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

The accessibility standard of buildings is a Building Regulation matter and should not be addressed through Local Plan planning policies. The government is reviewing the Building Regulations and this is the appropriate route for introducing new standards.

As stated in the supporting text for Policy H5, the policy is needed to secure the provision of M4(2) dwellings before the proposed introduction of the revised Building Regulations and to ensure that provision is made for M4(3) dwellings on large sites. The Council is required to demonstrate the need for M4(3) dwellings through its Local Plan.

Object

Representation ID: 7707

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

It is unclear from consultation document why the Council is proposing a 15% net gain policy in the context of the national mandatory requirement for 10% which is due to be implemented in January 2024. This is likely to create a further hurdle to the delivery of brownfield sites and impact on the provision of affordable housing on sites where there are viability issues.
This policy is not necessary, a single ecology policy should be prepared and this should cross reference to the national mandatory requirement for 10% net gain.

Comments 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: 7708

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

Policy EN6 is not necessary, it repeats national policy set out in the National Planning Policy Framework.
The second bullet point includes the requirement to clearly demonstrated that there are no other more suitable and sustainably located sites available, this is impractical to address on an individual site application in a scenario where, for example, additional housing land is needed to meet the five year supply requirements.
This policy should be deleted.

Comments noted. Disagree. Policy EN6 aligns with government guidance set out in para 180 of the NPPF and also refers back to Policy CC8. It is similarly worded to a number of recently adopted Local Plan policies on protecting agricultural land, such as in the Central Lincs Local Plan. In assessing housing applications outside of allocated sites, weight would be given to housing supply requirements in addition to the policy.

Object

Representation ID: 7709

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

the draft policies set out in the Preferred Options consultation document are considered to be too detailed, in some cases unclear and with a significant amount of unnecessary repetition of both national policy and between the draft local plan policies themselves. The policies need to be simplified and consolidated to ensure the aims of the policies are clear to applicants and the decision makers. It would be useful to undertake a benchmarking exercise with other local authorities to help highlight how policies can be made more focused and concise to support the objectives of the plan.
An example is the ecology policies. There are three ecology policies proposed (EN1, 2, & 3) when it is possible to cover the same range of issues in a single more concise policy. There is further overlap with Policy EN7.

Comments noted. Where specific policies are highlighted in the representation this will be covered under the policy. Following the Reg 18 Plan consultation process detailed scrutiny of the wording of the policies will take place and any repetition between them, or where repetition of national guidance is noted, amendments will be made prior to the publication of the Reg 19 Plan. Regarding the Environment policies: EN1 is a standalone policy covering the protection of sites, habitats and species whereas EN2 and EN3 deal specifically with the Local Nature Recovery Strategy and biodiversity net gain. Biodiversity net gain is a relatively complex issue and so it is appropriate to have a single policy dealing with it. Policy EN7 is based on the evidence set out in the GBI Study (2023) however it has been reviewed alongside policy SC7 to ensure consistency and avoid repetition.

Object

Representation ID: 7714

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

It is essential that the all the climate change requirements in the emerging local plan are considered in the final viability assessment of the plan, to avoid policies which impact on the deliverability of the homes and jobs needed.
The viability assessment highlights that this is an area of policy that the Council is currently developing and notes that the evidence being prepared to inform the local plan policy is at a relatively early stage. The viability assessment will need to be updated as the emerging local plan is refined.
It is unclear from the conclusions of the viability report whether the emerging climate changes policies are considered viable by the viability consultants. This needs to be clarified to inform the final draft of the Local Plan.

Comments regarding updating of viability assessment noted. The Plan acknowledges 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 climate change will be consulted on through the Reg 19 consultation.

Object

Representation ID: 7720

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

Reserve site H1a - Land At Mill Lane, Cottesmore has recently been refused planning permission in April 2023 for 93 dwellings (reference: 2022/0604/MAF). There were a large number of refusal reasons including that the location is prominent within views on the approach to the village from the northwest and the combination of the proposed details of the scheme and its location would have a detrimental impact on the character of the village when approaching it from this direction. Whilst it is accepted that many of the reasons for refusal could be overcome through the allocation of the site and improvements to the design and layout, this reason will be harder to address and potentially raises questions about the suitability of the site for allocation.

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

Object

Representation ID: 7721

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

An application for an agricultural building to store forage for animals grazing the adjacent pasture and storage of agricultural machinery was refused permission at reserve site H1h - Land South of Glebe Road, North Luffenham on 21 December 2021 (reference: 2021/1378/AGP). The application was refused due to its scale, materials and location in such a prominent location which would impact adversely on the appreciation of the adjacent conservation area and be visible from vantage points from within the village and from the adjacent public footpath, to the detriment of the character and appearance of the open countryside.

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

Object

Representation ID: 7723

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

Reserve site H1d – Land at Manor Farm, Essendine is accessed from a single track country lane, development here would require an upgrade to significant stretch of road and it is unclear if this has been considered and found to be viable.

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