Regulation 18 Draft Local Plan
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Regulation 18 Draft Local Plan
SP1: Spatial Strategy
Representation ID: 1609
Received: 18/04/2024
Respondent: Pegasus Planning Group
Agent: Andrew Hodgson
The proposed spatial strategy is supported as being in accordance with the requirement in national policy for new development plans to meet local housing needs as a minimum. The spatial strategy is also supported by appropriate evidence, with the Local Housing Needs Assessment. The proposed strategy of directing the majority of new growth towards Grantham and the market towns (which includes Bourne) is supported as being in accordance with the aim stated in the NPPF for new development plans to achieve sustainable development. The Settlement Hierarchy Review (February 2024) thus takes the correct approach in not re-appraising the market towns.
Object
Regulation 18 Draft Local Plan
SP4: New Residential Development on the Edge of Settlements
Representation ID: 1610
Received: 18/04/2024
Respondent: Pegasus Planning Group
Agent: Andrew Hodgson
This policy should be amended to clarify that the criteria set out in this policy are only required to be met by sites that are not allocated in the Local Plan and are therefore coming forward outside of the plan-making process. This will ensure the policy meets the soundness test set out at paragraph 16 c) of the NPPF. The final paragraph of Policy SP4 contains a typographical error, stating ‘application’ rather than ‘applicant’.
Object
Regulation 18 Draft Local Plan
H2: Affordable Housing Contributions
Representation ID: 1611
Received: 18/04/2024
Respondent: Pegasus Planning Group
Agent: Andrew Hodgson
Supports the aim in Policy H2 for affordable housing figure to be informed by the Whole Plan Viability Assessment, although disappointed not taken a view in this consultation given it was completed in January 2024. The Council is encouraged to have due regard to representations from the developer industry on the Viability Assessment, to ensure an accurate view is taken on matters that are likely to affect viability, such as BNG. The policy begins with an explicit statement that such assessments will only be considered for brownfield sites and allocations in Grantham, but the policy then goes on to state when viability assessments will be considered on other sites. Clarity is required as to when site specific viability assessments will be considered, and policy amended to accept viability assessments on all development sites.
The policy title is incongruous, ‘Contributions’ should be deleted or replaced with a more consistent term such as ‘Provision’.
Support
Regulation 18 Draft Local Plan
NEW POLICY 4: Biodiversity Opportunity and Delivering Measurable Net Gains
Representation ID: 1612
Received: 18/04/2024
Respondent: Pegasus Planning Group
Agent: Andrew Hodgson
The policy as drafted is supported, with it being consistent with the legislative requirement for all eligible development sites to deliver at least 10% Biodiversity Net Gain. It is noted that the Whole Plan Viability Assessment has tested the viability of increasing the requirement above 10%. Although commentary is not provided on whether a higher requirement is likely to be set out in policy, the Council is cautioned that such an increase will not only have viability implications but also other impacts which will need to be carefully considered. This includes impacts on the number of homes that sites are able to deliver, which would mean additional allocations may be needed to deliver the target growth requirement.
Object
Regulation 18 Draft Local Plan
SB1: Sustainable Building
Representation ID: 1613
Received: 18/04/2024
Respondent: Pegasus Planning Group
Agent: Andrew Hodgson
This policy requires further clarification. The policy should only encourage the inclusion of energy efficiency measures and use of renewable energy sources which go beyond Building Regulation requirements. Regard needs to be had of the Housing Minister’s Written Ministerial Statement of January 2024 which clearly set out that the Government does ‘not expect plan makers to set local energy efficiency standards that go beyond current or planned building regulations’. In accordance with the Planning Practice Guidance, the Council will also be expected to provide evidence supporting the inclusion of optional water efficiency target of 110 litres per house per day.
Support
Regulation 18 Draft Local Plan
SKPR-53 – Land at Mill Drove
Representation ID: 1614
Received: 18/04/2024
Respondent: Pegasus Planning Group
Agent: Andrew Hodgson
The inclusion of this site as an allocation for residential development is fully supported by our clients, who are the landowners for the northern field parcel adjacent to Mill Drove. The development principles are considered to be appropriately specific and relevant to this site, and have been well-informed by the supporting site assessments. Regarding criterion d - It should be recognised that direct improvements to Carr Dyke may not be possible but appropriate integration as a landscape is a positive development principle. Criterion f is supported but reference to high flood risk should be changed to ‘medium flood risk’ as site falls within Flood Zone 2. Supportive of 285 units as an indicative capacity but notes further masterplanning will confirm appropriate site capacity.