Regulation 18 Draft Local Plan
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Regulation 18 Draft Local Plan
H1: Housing AllocationsThe
Representation ID: 2500
Received: 23/04/2024
Respondent: William Davis Homes
Agent: Planning and Design Group
Surprised and disappointed to note that no further allocations are made in Barrowby.
Site Land Off Casthorpe Road, Barrowby (SKPR-70, SKPR-206, SKPR-265) should be allocated. The site provides and excellent opportunity to deliver new housing in a sustainable location. In summary, the site is considered suitable, achievable, and deliverable for housing, due to the following reasons:
- The site is in single ownership and available now.
- It will provide much needed market and policy compliant affordable housing in a sustainable location.
- The site has full access including active travel routes to the village centre (see below).
- It is in Flood Zone 1 (lowest risk of flooding).
- The site is not covered by any planning, landscape, heritage or ecological designations.
Object
Regulation 18 Draft Local Plan
SP1: Spatial Strategy
Representation ID: 2501
Received: 23/04/2024
Respondent: William Davis Homes
Agent: Planning and Design Group
The Council should now be looking for a level of growth in housing delivery to help address the economic and social issues in the district (as well as being ‘aspirational’).
The DLP (as proposed) is not sound because it is not:
Justified – It does not have an appropriate strategy which considers reasonable alternatives based on proportionate evidence. There are severe social and the district. The Councils SA does not test an alternative of delivering a higher level of housing (as opposed to just the minimum). If it did, it is highly likely that the benefits of a higher housing delivery (in terms of helping address social and economic problems) would have been identified. This possible approach has been ignored by the Council in creating the draft plan which is considered unsound plan making.
Consistent with national policy – The strategy is not in-line with the Government’s aim to significantly boost the supply of homes. Nor does it properly deliver sustainable development as it does not robustly consider social and economic objectives.
Support
Regulation 18 Draft Local Plan
SP2: Settlement HierarchyIn
Representation ID: 2502
Received: 23/04/2024
Respondent: William Davis Homes
Agent: Planning and Design Group
Supports the DLP’s recognition that Grantham is a ‘Sub-Regional Centre’ due to its high level of services and facilities and the support function it provides for nearby settlements.
Also supports Barrowby’s continued designation as ‘Larger Village’. However, believes that the DLP should, when allocating new development, recognise Barrowby’s close proximity to Grantham.
Object
Regulation 18 Draft Local Plan
NEW POLICY 2: Best and Most Versatile Agricultural Land
Representation ID: 2503
Received: 23/04/2024
Respondent: William Davis Homes
Agent: Planning and Design Group
Recognises the need to protect ‘best and most versatile agricultural land’ but believes this policy to be too restrictive and it could prevent otherwise sustainable development from coming forward. To fully understand the impact development could have, William Davies suggest that the following criteria is added:
-Is the land currently in active agricultural use for food production?
- What percentage of the existing agricultural holding does the site represent?
- Would its loss prevent the wider landholding continuing as an active agricultural land holding?
- Could the site deliver 10%+ BNG to compensate for the loss of food production?
This would provide the Council with a greater understanding of the site and make clearer what mitigation could be provided to enable development to come forward (subject to the usual planning policy).
Object
Regulation 18 Draft Local Plan
NEW POLICY 4: Biodiversity Opportunity and Delivering Measurable Net Gains
Representation ID: 2504
Received: 23/04/2024
Respondent: William Davis Homes
Agent: Planning and Design Group
Concerned over the use of the “at least”. As defined by the Environment Act 2021, recently published legislation requiring a 10% biodiversity net gain (BNG) from major development (Schedule 7A of the Town and Country Planning Act 1990 (as inserted by Schedule 14 of the Environment Act 2021)) was a result of widespread consultation and input from various professional bodies. This was to understand what was realistic in terms of deliverability and availability for biodiversity net gain.
If requirements for BNG are made higher than the 10% identified in this very recent piece of legislation, there’s a strong risk that development will become unviable or other important deliverables (such as policy levels of affordable housing) will be impossible to deliver as part of the scheme.
The Council should note that the Government’s Planning Practice Guidance (PPG) states: “Plan-makers should not seek a higher percentage than the statutory objective of
10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified.”