Regulation 18 Draft Local Plan

Support

Representation ID: 2491

Received: 24/04/2024

Respondent: The Dean and Chapter of the Cathedral Church of Christ in Oxford of the Foundation of King Henry the Eighth

Agent: Savills

Our Client is aware that this Regulation 18 version of the Local Plan proposes to allocate part of this site for housing.
The site is within a single ownership and is available for development. The site is therefore deliverable within the first five years of the new Local Plan. Our Client has developed a Responsible Ownership Policy for Property (ROPP) which is applied to development land within its control. This means that, from inception, there is a keen focus on environmental and social benefits for the local community.
The development is promoted to be a low carbon development, in design, delivery, use and future use.
Given our Client’s land interest in Deeping St James, the proposed allocation on Priory Farm Land at Policies H1 and SKPR-26 is fully supported. The support for this allocation is offered without prejudice to our Client’s overall position that these policies of the Local Plan should include the entire site as a new allocation. This can be done without any conflict with proposed Spatial Strategy.

Support

Representation ID: 2492

Received: 24/04/2024

Respondent: The Dean and Chapter of the Cathedral Church of Christ in Oxford of the Foundation of King Henry the Eighth

Agent: Savills

Welcomes the inclusion of a 21% buffer to the minimum Standard Method figure as a positive step by the Council to try to ensure that enough homes will come forward to provide a genuine choice of sites for new residents.
The housing supply position is very marginal at 5.01 years and susceptible to supply side shocks that may not be within the Council’s control.

This Policy does not appear to make any allowances for demand for housing driven by economic growth and this relationship should be made clearer. The Greater Lincolnshire Local Enterprise Partnership (GLLEP) has published a Strategic Economic Plan 2014 -2030 that seeks to drive economic growth in the region. It is not clear how this Plan can be achieved without corresponding growth in housing. The Spatial Strategy of this Plan needs to match the ambition of the GLLEP.
Deeping is one of the most appropriate locations for growth in the district and welcomes the draft Plan’s recognition of this.

Support

Representation ID: 2493

Received: 24/04/2024

Respondent: The Dean and Chapter of the Cathedral Church of Christ in Oxford of the Foundation of King Henry the Eighth

Agent: Savills

Our Client fully supports the classification of the Deepings as second only to Grantham in the hierarchy. The policy notes, “Development which maintains and supports the role of the three market towns of Stamford, Bourne and the Deepings, will be allowed, provided that it does not compromise their nature and character. Priority will be given to the delivery of sustainable sites within the built up part of the town and appropriate edge of settlement extensions.”

This site is precisely the type of development to which Policy is worded to offer in-principle support. As such, our Client considers that the extent of the Priory Farm allocation can be extended to include the whole site being promoted without any conflict with the draft Local Plan.

Object

Representation ID: 2494

Received: 24/04/2024

Respondent: The Dean and Chapter of the Cathedral Church of Christ in Oxford of the Foundation of King Henry the Eighth

Agent: Savills

If not allocated in the Plan, the principle of our Client’s site would fall to be assessed against this draft Policy which our Client does not support in its current form. The policy requires, “demonstrate clear evidence of substantial support from the local community through an appropriate, thorough, and proportionate pre-application community consultation exercise. Where this cannot be determined, support (or otherwise) should be sought from the Town or Parish Council or Neighbourhood Plan Group or Forum, based upon material planning considerations.”
Our Client fully accepts the need for extensive and positive pre-application engagement on development proposals but does not consider that the success of a planning application can be dependent on the outcomes of a process over which an applicant does not have control.
An applicant will always enter into pre-application discussions in good faith but has no control over the intentions of those who choose to engage in response. As drafted, this Policy is open to abuse from “bad actors” and is conflating the process of preparing an application with the planning merits of a proposal.
Therefore, this Policy should be amended to remove the requirement of public support. The remaining criteria of this Policy are reasonable and supported.

Object

Representation ID: 2495

Received: 24/04/2024

Respondent: The Dean and Chapter of the Cathedral Church of Christ in Oxford of the Foundation of King Henry the Eighth

Agent: Savills

Beyond the support for the Priory Farm allocation, our Client has some concerns about the approach taken to this Policy. The distribution of new housing across the district seems to be somewhat at odds with the Settlement Hierarchy of Policy SP2.

That hierarchy is based on Grantham and the market towns being the most sustainable locations for growth, yet 20% of the new housing is directed to the villages (large and small). In contrast, only 8% of the housing is allocated to the Deepings. Given the extensive range of facilities available in the Deepings, our Client considers that the town should be the focus of a greater proportion of the planned growth than is currently proposed.

Our Client considers that the wider Priory Farm site is extremely well located to allow access to the key facilities of Deeping St James and should be included in full as site SKPR-26.

Object

Representation ID: 2496

Received: 24/04/2024

Respondent: The Dean and Chapter of the Cathedral Church of Christ in Oxford of the Foundation of King Henry the Eighth

Agent: Savills

Our Client is fully committed to providing a policy-compliant level of affordable housing at Priory Farm but is cautious about the wide range of potential affordable requirements in Policy H2 as currently drafted. This uncertainty is anathema to potential development partners.

Our Client considers it paramount that this Policy is subject to a comprehensive viability review to demonstrate the 27 - 57% provision is achievable. Furthermore, as is currently the case, individual sites should be able to provide their own viability case to justify a non-policy compliant level of affordable housing.

Support

Representation ID: 2497

Received: 24/04/2024

Respondent: The Dean and Chapter of the Cathedral Church of Christ in Oxford of the Foundation of King Henry the Eighth

Agent: Savills

Our Client fully supports this Policy that seeks to use national standards to achieve biodiversity net gain. As shown on the plans accompanying this representation, our Client has set aside part of the site to provide new habitats that will provide a policy-compliant level of net gain.

Object

Representation ID: 2498

Received: 24/04/2024

Respondent: The Dean and Chapter of the Cathedral Church of Christ in Oxford of the Foundation of King Henry the Eighth

Agent: Savills

As drafted, this Policy requires, “New development should strive to be zero carbon ready through minimising energy use and choice of low carbon energy sources. New development should demonstrate how carbon dioxide emissions have been minimised…” Our Client supports this aim and as discussed, our Client’s own ROPP confirms a commitment to low carbon developments.
Nonetheless, the requirements of this Policy should be tested by the whole Plan viability assessment given the implications for development of achieving net zero. The policy needs to be drafted in such a way that its requirements fall away as they are superseded by national planning guidance and Building Regulations.
In the longer term our Client considers national legislation is the appropriate mechanism to deliver net zero, so again Policy SB1 should be drafted in a manner that means its requirements fall away once national guidance/regulations catch up and overtake the Policy.