Regulation 18 Draft Local Plan
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Regulation 18 Draft Local Plan
SP1: Spatial Strategy
Representation ID: 2045
Received: 22/04/2024
Respondent: Defence Infrastructure Organisation
Agent: Fisher German
A longer plan period may assist the Council in safeguarding the Plan and provide a buffer to any potential delays.
The Local Housing Need calculation should be updated.
Supportive of Grantham as a key focal point.
Removal of specific parts relating to agricultural land quality is considered logical.
Support
Regulation 18 Draft Local Plan
SP2: Settlement HierarchyIn
Representation ID: 2046
Received: 22/04/2024
Respondent: Defence Infrastructure Organisation
Agent: Fisher German
Policy SP2: Settlement Hierarchy has been updated to reflect updated evidence on settlement sustainability, as informed by the Settlement Hierarchy Review (2024). The DIO have no specific comments on the impacts this updated evidence has had on lower tier settlements. The DIO does however acknowledge and support the continued identification of Grantham as a Sub Regional Centre where the majority of development will be focused. The policies support for new development proposals on appropriate and deliverable brownfield and suitable greenfield sites, including through the provision of urban extensions is supported by the DIO.
Support
Regulation 18 Draft Local Plan
H1: Housing AllocationsThe
Representation ID: 2047
Received: 22/04/2024
Respondent: Defence Infrastructure Organisation
Agent: Fisher German
The DIO fully support the continued identification of Prince William of Gloucester (PWoG) Barracks as housing allocation (SKPR-65 (GR3 -H4)).
As a result, of the Biodiversity Net Gain requirements the capacity is estimated to have reduced from 4000 to 3000. The proposed delivery of 1,745 dwellings to 2041 will not change and considered to be deliverable.
The DIO have no objection to the site being transferred from essentially separate housing and employment policies to an integrated ‘mixed-use’ allocation.
Object
Regulation 18 Draft Local Plan
H2: Affordable Housing Contributions
Representation ID: 2048
Received: 22/04/2024
Respondent: Defence Infrastructure Organisation
Agent: Fisher German
At present the emerging policy, and indeed its associated evidence base are not justified and cannot be considered sound.
Object
Regulation 18 Draft Local Plan
H4: Meeting All Housing Needs
Representation ID: 2049
Received: 22/04/2024
Respondent: Defence Infrastructure Organisation
Agent: Fisher German
Reference to Part M4(2) should be removed entirely to better facilitate the delivery of potential future changes to building regulations.
Object
Regulation 18 Draft Local Plan
H3: Self and Custom Build Housing
Representation ID: 2050
Received: 22/04/2024
Respondent: Defence Infrastructure Organisation
Agent: Fisher German
The self and custom build requirement could be met by the number of single dwelling applications approved without the imposition of additional policy requirements of Policy H3 which could further constrain delivery of complex strategic sites.
Whilst the Self-build and Custom Housebuilding Act 2015 places a requirement to deliver Self-Build plots to meet the needs of those on the register, this in itself is not justification for the policy intervention proposed. The Council should seek to support Self-Building in other ways including those set out within the PPG.
Support
Regulation 18 Draft Local Plan
E2: Employment
Representation ID: 2051
Received: 22/04/2024
Respondent: Defence Infrastructure Organisation
Agent: Fisher German
The DIO support the identification of PWoG Barracks (SKPR65 (GR3-H4)) as an employment generating site. DIO are committed to the delivery of the site and are currently undertaking the significant quantum of background work required to support an outline planning application for a mixed-use scheme.
Supports the recognition within the Policy “other employment generating uses” may be appropriate. It is however requested that for sites such as SKPR65 (GR3-H4), this flexibility is extended to include all Class E uses.
Object
Regulation 18 Draft Local Plan
E6: Loss of Employment Land and Buildings to Non-Employment Uses
Representation ID: 2052
Received: 22/04/2024
Respondent: Defence Infrastructure Organisation
Agent: Fisher German
The DIO fully support the identification of PWoG Barracks (SKPR65 (GR3-H4)) as a mixed-use, employment generating site.
For clarity of implementation, the policy and/or the associated reasoned justification, should be explicit as to what uses are considered to be employment and non-employment uses. If the position is to fall back to Policy E2 as currently drafted, then the Policy would allow for predominantly B-class uses and an allowance to deliver E(g) uses. However, as detailed in our response to Policy E2, to enable flexibility of delivery this should be extended to all uses within Class E. It is requested that Policy E6 is also rewritten to allow for other employment generating uses within class E to be delivered. Such an approach would assist in ensuring that employment land is not lost to other non-employment generating uses.
Object
Regulation 18 Draft Local Plan
SB1: Sustainable Building
Representation ID: 2053
Received: 22/04/2024
Respondent: Defence Infrastructure Organisation
Agent: Fisher German
The Policy makes it clear that where the requirements of Policy SB1 cannot be met, it is incumbent on the applicant to demonstrate exceptional circumstances that compliance with the policy is not viable or feasible. This approach is not supported.
If this element of the policy is to be retained, then updated evidence should be provided demonstrating that there remains a localised issue which requires such a significant policy intervention above and beyond the requirements already set out in Building Regulations.
Support
Regulation 18 Draft Local Plan
SKPR-65 (GR3-H4): Prince William of Gloucester Barracks (Mixed Use Allocation)
Representation ID: 2054
Received: 22/04/2024
Respondent: Defence Infrastructure Organisation
Agent: Fisher German
The DIO fully supports the continued identification of its land interests at Prince William of Gloucester Barracks, Grantham, as a suitable site for strategic development.
The proposed amendment to the Policy to incorporate the employment generating uses and reflect the mixed-use nature of the site is supported.
Requested policy amendments
• Indicative Unit Numbers of 3,000 dwellings (approx. 1,745 anticipated to be constructed by 2041) including employment generating uses of 2.5 hectares.
And:
• New employment generating uses of approximately 2.5 hectares to be located within the sustainable community and to ensure compatibility with surrounding residential areas.
And:
• The updated requirement to include a Minerals Assessment is noted. However, due to the proximity of existing residential development this would restrict significantly where on the site mineral extraction could take place reducing the scale of any extraction to that which is not commercially viable.
And:
• Delete criteria vi.