Regulation 18 Draft Local Plan

Support

Representation ID: 1919

Received: 24/04/2024

Respondent: Bettinson Trust

Agent: Savills

We support draft Policy SP1 and the proposed allocation SKPR-53 (Land at Mill Dove). Bettinson Trust, who own part of the site, fully support the inclusion of its land in a wider allocation. Following the release of the draft plan, a meeting between many of the other land owners was convened and all were in agreement that a joint approach to a comprehensive site promotion should be taken forward. However, due to the time allowed it has not been possible to prepare joint evidence and a combined masterplan for the Reg18 stage. However, it is proposed that technical work and a concept plan will be provided to the Council going forward.

Support

Representation ID: 1920

Received: 24/04/2024

Respondent: Bettinson Trust

Agent: Savills

We support draft policy SP2 and the recognition that in order to address the District’s housing growth needs the majority of new development will be focused in Grantham and that development which supports the role of the three market towns, including Bourne, will be allowed, provided that it does not compromise its nature and character. Bettinson Trust and the other landowners of allocation SKPR-53 propose to undertake a raft of technical work to support the draft allocation and comprehensive masterplan and this will include landscape and master planning inputs which will seek to assimilate a scheme that is appropriate to its context.

Object

Representation ID: 1921

Received: 24/04/2024

Respondent: Bettinson Trust

Agent: Savills

As currently drafted, Bettinson Trust object to the proposed affordable housing contributions policy H2 which requires ‘all development comprising 10 or more dwellings (or an area of 0.5ha or more) should make provision for 27-57% depending on the outcome of the Whole Plan Viability Assessment’. Para 8.7 of the viability assessment states ‘it is informed by the Local Housing Needs Assessment (LHNA)’. The LHNA confirms the policy AH range and Para 8.65 also says ‘it is not the housing requirements for the district.’ However, Para 10.33 Whole Plan Viability assessment proposes the requirement of 10% AH for brownfield sites, 20% for greenfield and 30% for strategic sites. H2 policy should align with the Whole Plan Viability Assessment and each site should be considered on its own merits where an affordable housing target cannot be met. A further concern we have, and we wish to object to, it the assumption regarding the split of social rented and affordable ownership which is assumed to be 60%:40%. We consider that the plan should first factor in the 25% First Homes, as required under Annex 2 of the NPPF which would then leave the remaining 75% affordable homes to be split between social rented and affordable ownership.

Support

Representation ID: 1922

Received: 24/04/2024

Respondent: Bettinson Trust

Agent: Savills

We support the ‘indicative mix’ of housing and that a standard or fixed housing on all sites is not required. This allows for residential schemes to adapt to changing market conditions throughout the plan period. We do however suggest there should be clarity on the mix of affordable housing sought. We are not are not objecting to the proposed requirement for at least 10% of dwellings on schemes of over 10 dwellings to be M4(2) compliant, requirements for M4(2) standard dwellings should only be included when justified by evidence (PPG Paragraph: 009 Reference ID: 63-009-20190626) and should be agreed on a site by site basis. The PPG states ‘local plan policies should also take into account site specific factors such as vulnerability to flooding, site topography, and other circumstances which may make a specific site less suitable for M4(2)… compliant dwellings, particularly where step free access cannot be achieved or is not viable. Where step-free access is not viable, neither of the Optional Requirements in Part M should be applied’ (PPG: Paragraph: 008 Reference ID: 56-008-20160519). We suggest the requirement for 10% M4(2) properties needs to be evidenced and balance to make use of the land and viability.

Support

Representation ID: 1923

Received: 24/04/2024

Respondent: Bettinson Trust

Agent: Savills

We support this policy as written, a review of the Points of Compass Assessment (Bou2) states the site sits within the Fen Margin and the edge of the Fens Landscape character area and this is also supported by Bourne Character assessment (November 2023). The Points of Compass Assessment considers the Fen Margin and Fens Landscape as low-medium sensitivity residential developments. Bettinson Trust are working up proposals for draft allocation SKPR-53, which will sensitively address existing green infrastructure (Car Dyke) and introduce landscape and biodiversity enhancements as part of the proposed development in accordance with paragraph 180 of the NPPF.

Support

Representation ID: 1924

Received: 24/04/2024

Respondent: Bettinson Trust

Agent: Savills

We support draft policy EN3 as proposed. Bettinson Trust are working up proposals for draft allocation SKPR- 53, which will sensitively address existing green infrastructure (Carr Dyke) and introduce landscape and biodiversity enhancements as part of the proposed development. A range of technical work is to be undertaken including landscape, drainage, ecology and masterplanning which will take account of the Green Infrastructure Mapping prepared by the GLNP.

Support

Representation ID: 1925

Received: 24/04/2024

Respondent: Bettinson Trust

Agent: Savills

We support draft policy EN5 as written.

Object

Representation ID: 1926

Received: 24/04/2024

Respondent: Bettinson Trust

Agent: Savills

We object to Policy SB1 Sustainable Building, the Council should provide a suitable evidence base to ensure it is justified in line with paragraph 35 of the NPPF, and include suitably detailed guidance of how it expects such requirements to be complied with by applicants.
Any requirements related to local energy efficiency standards for residential uses, should consider the recent (13 December 2023) statement by the minster for Minister of State for Housing which states that: “…the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations.” Significantly, the Statement goes on to state “The proliferation of multiple, local standards by local authority area can add further costs to building new homes by adding complexity and undermining economies of scale. Any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned buildings regulation should be rejected at examination if they do not have a well-reasoned and robustly costed rationale”.

Support

Representation ID: 1927

Received: 24/04/2024

Respondent: Bettinson Trust

Agent: Savills

We support draft allocation SKPR-53 for 285 dwellings. The landowners are in agreement to work together to prepare joint technical work and a comprehensive concept masterplan and this will be prepared for the Regulation 19 stage of the plan. Given that the site appears to have relatively few constraints, it is anticipated that the level of housing that could be achieved on the site may be slightly higher than 285 dwellings. We support the site assessment undertaken by Bourne Town Council for the Neighborhood Plan which has estimated a site capacity of 300-350 dwellings to be closer to the likely yield. However, we will seek to clarify this through the undertaking of further technical work and a concept masterplan for the site.