Regulation 18 Draft Local Plan

Support

Representation ID: 1764

Received: 25/04/2024

Respondent: Home Builders Federation

HBF welcomes the Council’s efforts to ensure that they have an up to Local Plan. Plan-making is a fundamental part of a Local Authority’s role and is essential to support the delivery new homes and jobs. HBF agree support the need for a review of the South Kesteven. HBF welcome the Council’s proactive plan making and pro-growth approach. In the midst of a housing crisis, it is important that housing need are met in full.

Support

Representation ID: 1765

Received: 25/04/2024

Respondent: Home Builders Federation

HBF note that this is consultation characterises the Reg 18 Local Plan consultation as part of a Review and update of the Local Plan rather than a new plan.
HBF also welcomes the Local Plan public consultation events and the ability for these to be watched on-line. This was particularly helpful in explaining the Council’s approach to the Plan Review and we welcome the recognition of the tensions and policy choices that will need to be made, and the policy balance that will need to be struck to ensure development is sustainable and viable.

Object

Representation ID: 1766

Received: 25/04/2024

Respondent: Home Builders Federation

BNG should be a significant factor in emerging Plans such providing clear advice and guidance for certainty. BNG should be fully considered in relation to site allocations, to understand requirements for a site to be allocated and impact on viability and other policy requirements and considerations. Consider the impact on what level of housing densities are achievable and number of new homes needed. Importance to understand the BNG costs and impacts on the viability of the site and ability to delivery against other policy requirements such as affordable housing or S106.

Support

Representation ID: 1767

Received: 25/04/2024

Respondent: Home Builders Federation

HBF welcomes the Council’s attempts to clearly set out policies where significant changes are being made, new policies and chapter minor changes to policies, policies removed and policies to be reviewed once emerging evidence in finalised. This is helpful characterisation.

Object

Representation ID: 1768

Received: 25/04/2024

Respondent: Home Builders Federation

HBF note that it is proposed to that the Plan Review will cover the period of 1st April 2021 through to 1st April 2041. The NPPF requires that a 15-year period is provided post adoption of the Plan, is it not ‘desirable’ as stated in the consultation, but a requirement. HBF suggest the Council should considering extending the Plan period.
It can take a long of time for Plans to progress through Reg 18 through to Reg 19, Submission and Examination, Inspector’s Report and Adoption. In light of the amount of time it can take to progress through the multiple stages of plan-making, a longer end date for the plan may be a more realistic. Whatever plan period is chosen there is a need for evidence to cover the whole plan period, it would therefore be sensible to ensure the evidence covers a longer time frame as well.

Object

Representation ID: 1769

Received: 25/04/2024

Respondent: Home Builders Federation

HBF welcomes the Council’s early review of the Local Plan and its recognition of the need to plan for housing growth across the district. We welcome the Council’s starting point for setting the housing requirement for South Kesteven as the standard method plus a 20% buffer. However, HBF would also support more housing than the standard method housing requirement in order to support economic growth, provide a range and type of sites, deliver increased affordable housing and to support small and medium house builders. There remains a need to provide a range and choice of sites, a need for flexibility and viability considerations to be taken into account and a need for the Council to consider whether higher levels of open-market housing are required in order to secure the delivery of affordable housing and/or support economic growth. HBF suggest that each of these reasons on its own could justify an increase in the housing requirement for South Kesteven and the Council should consider planning for an additional amount of housing to address each reason in turn.

Object

Representation ID: 1770

Received: 25/04/2024

Respondent: Home Builders Federation

HBF would also flag that increased economic growth can lead to an increased need for additional housing.

Object

Representation ID: 1771

Received: 25/04/2024

Respondent: Home Builders Federation

Wish to see the Plan set out a logical settlement hierarchy which meets all the housing needs and addresses all areas of the housing market, with a range of sites proposed for allocation. The spatial strategy of the Plan should also recognise that there may be clusters of villages that provide a range of services for that area within reasonable travelling distance of each other, so villages may need to be grouped together. These areas might be able to sustainably support a substantial level of development but may not have all the services within one particular village. The Local Plan should recognise that settlements that currently do not have services could expand to include those services if new development is allocated in those areas. The current range of village services should not be used as a basis for only locating development close to existing services, it could in fact also identify where services could be improved through new development. Allocating housing sites in rural areas can also provide opportunities for small sites which are particularly helpful for SME builders.

Object

Representation ID: 1772

Received: 25/04/2024

Respondent: Home Builders Federation

HBF support the need for policy to deliver a mix and range of housing types suitable for a variety of needs, including the need for affordable and local-need housing within the District. It is also important to recognise the need for open market, and not just affordable dwellings.

Object

Representation ID: 1773

Received: 25/04/2024

Respondent: Home Builders Federation

Note that the Council’s recognition of the 13 December 2023, Written Ministerial Statement. The HBF is concerned that the Council is adding to the complexity of policy, regulations and standards that housebuilders are already expected to comply with. To be consistent with national policy, HBF request the Council rely on the Building Regulations process as the way to manage improving energy efficiency standards and as such no policy on this issue is needed in the Local Plan.