Regulation 18 Draft Local Plan
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Regulation 18 Draft Local Plan
Strategic Objectives for the Local Plan
Representation ID: 2451
Received: 23/04/2024
Respondent: Saint Land and Development Ltd
Agent: Marrons
We welcome Objectives 1, 5, and 8.
Consider Objective 9 plays down a key element of national planning policy which is to "boost significantly" the supply of housing, not merely achieving an adequate supply. The provision of housing goes beyond offering a choice in the market but rather defining and addressing needs in a manner that addresses the challenges experienced by the Plan Area and also delivers the Plan's ambitions.
Object
Regulation 18 Draft Local Plan
SP1: Spatial Strategy
Representation ID: 2452
Received: 23/04/2024
Respondent: Saint Land and Development Ltd
Agent: Marrons
The LHN figure should not be re-calculated midway through the plan preparation process and the figure used should be that which aligns with the date at which the LPR was commenced. The LHN and therefore the housing requirement for South Kesteven should be at least 754 dpa or 15,080 over the plan period.
There is no explanation within the Draft Plan or its evidence base as to why it is not possible to meet affordable housing needs in full or at least more than would otherwise be met by Draft Policy SP1’s housing requirement.
We would strongly encourage the local planning authority to investigate the linkages between the overall planned level of economic growth and housing provision to ensure an alignment between the two and to incorporate an uplift to the Standard Method figure as appropriate as part of the LPR’s housing requirement.
Object
Regulation 18 Draft Local Plan
Plan period
Representation ID: 2453
Received: 23/04/2024
Respondent: Saint Land and Development Ltd
Agent: Marrons
As it stands, the LPR would look only five years beyond the end date of the adopted local plan and it is questionable whether such a short timespan would enable to the LPR to anticipate and respond to long-term requirements and opportunities. As set out in the housing trajectory at page 47 of the Draft Plan, housing completions will drop below the 701 dpa from 2036/2037 with substantial drop-off in completions occurring in 2038/2039 and in every monitoring year thereafter. The LPR would therefore not deliver sufficient housing completions to meet annualised need significantly beyond 2036, the end date of the adopted local plan.
Support
Regulation 18 Draft Local Plan
SP2: Settlement HierarchyIn
Representation ID: 2454
Received: 23/04/2024
Respondent: Saint Land and Development Ltd
Agent: Marrons
We support Policy SP2 as it identifies a robust settlement hierarchy that is justified against the evidence base. We specifically support the identification of a number of Larger Villages which have good levels of services and accessibility and their inclusion within the hierarchy.
The Settlement Hierarchy Review is generally robust and competent.
In specific regard to Great Gonerby, we support the identification of this settlement as a Larger Village and generally as a location for proportionate housing growth. We also note that Great Gonerby is closely related to Grantham and so is also supported by the further services and facilities of Grantham.
Object
Regulation 18 Draft Local Plan
SKPR-57 – Land off Belton Lane
Representation ID: 2455
Received: 23/04/2024
Respondent: Saint Land and Development Ltd
Agent: Marrons
SKPR-57 was identified as a ‘preferred site’ in the Draft Site Assessment. This is despite the fact that the Site Assessment identified issues with the junction between Newark Hill and Belton Lane, which highlights whether SKPR-57 could feasibly be delivered within a suitable timeframe given the extent of highways improvement works required.
The site will encroach on the separation between the two settlements and increase the risk of Grantham and Great Gonerby merging. However, the Land North of Belton Lane is appropriately located so that it is not in close proximity to any other settlement in any direction.
Object
Regulation 18 Draft Local Plan
SKPR-241 – Land Off Church Lane
Representation ID: 2456
Received: 23/04/2024
Respondent: Saint Land and Development Ltd
Agent: Marrons
The Draft Site Assessment report highlights the access issues regarding site SKPR-241 and it states that the site will need “to make highway improvements to Church Lane” in order to be suitable for development. That being said, the report identified the Church Lane site as being a preferred site for development. In addition, arguably, development of the land at Church Lane could have more significant traffic impacts on the village, particularly during construction, given its location to the south of the village.
Object
Regulation 18 Draft Local Plan
H1: Housing AllocationsThe
Representation ID: 2457
Received: 23/04/2024
Respondent: Saint Land and Development Ltd
Agent: Marrons
As present, Policy H1 does not propose to allocate Land to the North of Belton Lane. It is however submitted that this site is wholly deliverable and is located within a highly sustainable settlement, closely aligned to Grantham itself and in a relatively close proximity to large scale employment sites, therefore providing sustainable housing options for employees of those sites. Consequently, it would be prudent to commit to its allocation within the emerging local plan.
It may also be prudent for the council to commit to further draft allocations or intensify the previously identified draft allocations where appropriate and sustainable to do so.
Object
Regulation 18 Draft Local Plan
H2: Affordable Housing Contributions
Representation ID: 2458
Received: 23/04/2024
Respondent: Saint Land and Development Ltd
Agent: Marrons
It seems very unlikely that the local planning authority will be able to seek anywhere close to 57% affordable housing provision particularly not given the fact that slightly under half of the LPR’s overall housing provision will be located at Grantham, which has a generally less buoyant housing market than other parts of the District.
It is welcomed that the council will consider site specific viability assessments in certain cases. This will ensure that developments are context based.
Object
Regulation 18 Draft Local Plan
H4: Meeting All Housing Needs
Representation ID: 2459
Received: 23/04/2024
Respondent: Saint Land and Development Ltd
Agent: Marrons
We support the aspirations and aims of these policies, but would caution the use of a number of policies that place a greater burden upon the delivery of development without a thorough understanding of the viability implications of this approach.
We are supportive in principle of the NDSS but these may not be appropriate or reasonable for all development proposals – possibly due to density, design or viability. We would encourage balancing clauses in all these policies to enable reasonable flexibility to avoid the potential for developments which would otherwise be acceptable to fail.
Object
Regulation 18 Draft Local Plan
ID1: Infrastructure for Growth
Representation ID: 2460
Received: 23/04/2024
Respondent: Saint Land and Development Ltd
Agent: Marrons
We are supportive of Policy ID1 which states that all development proposals will be expected to demonstrate that there is, or will be, sufficient infrastructure capacity (including blue and green infrastructure) to support and meet the essential infrastructure requirements arising from the proposed development.
We would welcome an acknowledgement of the delivery of an excess or a significant improvement in local infrastructure that could enable additional sustainable development.