Regulation 18 Draft Local Plan
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Regulation 18 Draft Local Plan
SD1: The Principles of Sustainable Development in South Kesteven
Representation ID: 1935
Received: 24/04/2024
Respondent: Hallam Land Management & Barratt Developments PLC
Agent: Pegasus Planning Group
This draft policy is supported.
Object
Regulation 18 Draft Local Plan
SP1: Spatial Strategy
Representation ID: 1936
Received: 24/04/2024
Respondent: Hallam Land Management & Barratt Developments PLC
Agent: Pegasus Planning Group
The plan period is not considered to be long enough plan period to ensure the plan provides a 15 year time horizon from the adoption of the plan, in line with paragraph 22 of the NPPF. The Council can avoid further unnecessary delays during the Examination process by extending the plan period now to at least 2042, and given the potential for further delays to 2043. At this stage in the process this change can be made without undermining the overall strategy or creating the need for additional consultation, as there will be further consultation at the Regulation 19 stage.
The latest affordability ratio reduces the Council’s standard method LHN by 14 to 687 homes a year. Two additional years would only require additional 1,094 new homes. Client’s site south of Harrowby Lane can accommodate the need without revisiting evidence base.
Support
Regulation 18 Draft Local Plan
SP2: Settlement HierarchyIn
Representation ID: 1937
Received: 24/04/2024
Respondent: Hallam Land Management & Barratt Developments PLC
Agent: Pegasus Planning Group
This Draft Policy focuses the majority of development in Grantham, in order to support and strengthen its role as a Sub-Regional Centre. New development proposals will be supported on sustainable greenfield sites which includes urban extensions , where development will not compromise the town’s nature and character. This draft policy is supported. This has been updated to reflect the conclusions of the Settlement Hierarchy Review (2023). This study continues to support Grantham as a Market Town at the top of the settlement hierarchy, which is supported.
Object
Regulation 18 Draft Local Plan
SP4: New Residential Development on the Edge of Settlements
Representation ID: 1938
Received: 24/04/2024
Respondent: Hallam Land Management & Barratt Developments PLC
Agent: Pegasus Planning Group
As Criteria (a) is existing it would be helpful to consider and reflect on the evidence of whether this policy has been successful in supporting new development in sustainable locations.
Suggests that criterion (d) is broadened to allow for sites to come forward to address need across the District as a whole rather than proven local need in areas. This would better reflect the spatial strategy which directs development to the most sustainable locations and provides further flexibility to ensure the housing supply is maintained throughout the plan period.
Object
Regulation 18 Draft Local Plan
H1: Housing AllocationsThe
Representation ID: 1939
Received: 24/04/2024
Respondent: Hallam Land Management & Barratt Developments PLC
Agent: Pegasus Planning Group
The inclusion of a 20% buffer is supported.
It would be helpful to confirm there is no double counting with commitments and adopted Local Plan allocations with permission in Table 2.
Supportive of focusing growth in Grantham.
It is considered important that opportunities in the towns are revisited ahead of this scale of development being proposed further down the hierarchy.
Supportive of allocations at GR3-H1 and GR3-H4 as creates opportunity for additional growth to the eastern edge of Grantham as the supporting infrastructure and urban form extends eastwards and opens up new opportunities to enable the continued focus of development at Grantham as the Sub-Regional Centre and support the long term economic success of this town.
Site SKPR-82 should be reconsidered ahead of the Regulation 19 consultation, as a suitable longer term strategic direction of growth beyond the current plan period to complement the existing proposed development to the east of Grantham.
Support
Regulation 18 Draft Local Plan
H2: Affordable Housing Contributions
Representation ID: 1940
Received: 24/04/2024
Respondent: Hallam Land Management & Barratt Developments PLC
Agent: Pegasus Planning Group
The consultation document sets out that all developments comprising 10 or more dwellings (or an area of 0.5ha or more) will be required to make provision for between 27-57% affordable housing. The exact requirement is to be established following the outcome of the Whole Plan Viability Assessment. This approach of using the Whole Plan Viability Assessment to inform the policy requirement is supported, as a potential requirement of up to 57% is a significant concern for viability of development and would not be supported. The overlap in the policy requirement for First Homes and affordable ownership housing is explained in the supporting text but should be made clearer in the policy to avoid confusion.
Object
Regulation 18 Draft Local Plan
H4: Meeting All Housing Needs
Representation ID: 1941
Received: 24/04/2024
Respondent: Hallam Land Management & Barratt Developments PLC
Agent: Pegasus Planning Group
It is important for the policy to recognise that there are other factors that will need to be taken into account when considering the housing mix on a site. It is suggested that the draft policy includes reference to having regard to housing market evidence, economic conditions and viability, character and design and site-specific circumstances, all of which may affect the most appropriate mix for a site. It is important that the policy allows for a flexible approach that will support the deliverability of development. The housing mix sought is a factor that should be considered in the Whole Plan Viability Assessment as this will have an impact on site viability and the level of affordable housing that it is possible to support.
If the Government implements proposed changes to Part M of the Building Regulations, the Council's proposed approach would represent an unnecessary duplication of Building Regulations.
Object
Regulation 18 Draft Local Plan
H3: Self and Custom Build Housing
Representation ID: 1942
Received: 24/04/2024
Respondent: Hallam Land Management & Barratt Developments PLC
Agent: Pegasus Planning Group
A key issue to consider is whether large scale sites are where the self-builders and custombuilders
want to be located and what happens if plots are not taken up. This approach to requiring a percentage of larger sites is unlikely to meet the aspirations of the majority of those on the self-build register. The demand is likely to be for small scale sites within rural areas rather than plots within more urban sites. It is important that the aspirations of selfbuilders are considered in the preparation of this policy to ensure it is effective. The proposed policy also needs to consider local needs/demands, health and safety risks of empty plots or plots being delivered later than the rest of the development and design impacts, for example how to avoid creating long term gaps in the street scene. Whilst there is general support for the concept of self-build/custom housing, it is considered that the policy should support this through a criteria based policy which encourages the delivery of such plots where they are thought out, fully justified, and flexible.
Object
Regulation 18 Draft Local Plan
NEW POLICY 4: Biodiversity Opportunity and Delivering Measurable Net Gains
Representation ID: 1943
Received: 24/04/2024
Respondent: Hallam Land Management & Barratt Developments PLC
Agent: Pegasus Planning Group
The proposal to exhaust all on-site opportunities before considering off-site provision of biodiversity net gain is not supported. It is not always the best approach to deliver biodiversity enhancements on site; this can create pockets of enhancement that are less beneficial to biodiversity than focusing these enhancements in strategic locations. This means on site improvements or improvements close to the site may be less beneficial than focusing enhancements within an important corridor for example.
Support
Regulation 18 Draft Local Plan
ID1: Infrastructure for Growth
Representation ID: 1944
Received: 24/04/2024
Respondent: Hallam Land Management & Barratt Developments PLC
Agent: Pegasus Planning Group
Infrastructure is critical to successful growth and this policy approach is supported and is aligned with the Community Infrastructure Levy Regulations. Our client’s site, Land south of Harrowby Lane, Grantham offers an opportunity to deliver significant new infrastructure for the benefit of existing and new residents.