Regulation 18 draft Local Plan

Object

Representation ID: 5545

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

Whilst the level of housing growth is framed as "at least", the baseline figure for the number of dwellings to be built per year is still very low at 123. This is substantially lower than the current Local Plan minimum figure, and is remarkable in the context of the economic development objectives of the plan and Economic Strategy (economic growth means jobs, and jobs need people, who need houses) and during a national housing crisis. Throttling back the housing figure will only constrain the housing market (keeping prices high and access to housing difficult) and undermining economic objective.

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

Support

Representation ID: 5547

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

On behalf of Francis Jackson Homes Ltd. and the landowners we strongly support the allocation of the land to the north of Pennine Drive, Edith Weston as being suitable for housing. It represents natural infilling of land between 2 existing blocks of residential development either side, thus limiting any visual or wider landscape impact. The site is available, achievable and deliverable, and can be brought forward for housing in the short - medium term, thus aiding to boost the Council's supply of deliverable housing land at the start of the Plan period before any SuE's or large allocations come forward.

Noted.

Object

Representation ID: 5551

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

Is this really necessary or relevant as a policy of the development plan? Are these not simply validation requirements?

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

Support

Representation ID: 5563

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

We support the allocation of the site for housing;
It is well related to existing development on 3 sides have very limited wider visual, landscape and countryside impact;
No access constraints;
Under Option and so is immediately available for housing - the site is available, deliverable and achievable;
The site can come forward much sooner than the Officers Mess site (H1.4), and is better well related to existing development;
A previous application confirmed no technical issues at all but suggested the site come forward through the call for sites and new local plan process - as it now is.

Support noted.

Object

Representation ID: 5587

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

15% BNG will adversely impact on the viability, and deliverability of schemes;
Landowners will be dis-incentivised to bring land forward, and will wait out policy change;
There is no empirical evidence of the consequences of a 15% BNG requirement yet - however, from experience of 10% BNG schemes, it will reduce all of the densities by at least a third thus there will be significant knock-on implications for the quantum of housing delivered on all of the housing figures and allocations in the emerging Local Plan - more sites will be needed, including at least all the current Reserve Sites.

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: 5588

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

The wording of this policy is not positively prepared. Surely the presumption is always planning permission will be granted unless there is a negative impact, not "will only be permitted if...."

Where does the evidence for the 3-for-1 replacement of trees come from? Surely these matters would be covered by the BNG calculations in the Metric anyway and are not really for policy to prescribe at this juncture?

The hedgerow requirements are very prescriptive and leave little/no scope for flexibility or practical alternatives to be considered or site specific circumstances to be taken account of.

Comments noted. Regarding replacement trees amend policy text to "In such cases the council will require new trees to replace the value of the trees that were removed. In most cases, this will be a higher number of new trees as trees significantly increase in value as their grow and mature. A value of the trees lost should be obtained by using appropriate formats, (e.g. CAVAT, Helliwell or iTree). Replacement trees should be of a similar species and capable of attaining a similar size to that which are being lost and will be required to be planted on-site."

Disagree that replacement trees should be left to the BNG calculations as s197 TCPA sets out a statutory duty for LPAs to ensure, where appropriate, for the planting of trees.
Disagree regarding hedgerows. This part of the policy states that development ‘will not be supported…unless’ and is similar in wording to other adopted Local Plan policies.

Object

Representation ID: 6355

Received: 08/01/2024

Respondent: Francis Jackson Homes Ltd

Higher than nationally set levels of BNG will adversely impact on the capacity of sites allocated in the plan.
Has the evidence base looked at the impact of this policy on the NDA of allocated sites to ensure the quantum in each instance is still deliverable with this very high policy aspiration.

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.