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: 2517
Received: 24/04/2024
Respondent: David Wilson Homes East Midlands
Agent: Savills
DWH support draft Policy SD1. It is considered that policy wording used is reasonably flexible and accords with paragraph 35 (d) of the NPPF. This policy does not set standards beyond adopted policy and is therefore considered in line with the ministerial statement that was issued in December 2023. It is considered that the plan should only require development to comply with current or planned building regulations.
Object
Regulation 18 Draft Local Plan
Plan period
Representation ID: 2518
Received: 24/04/2024
Respondent: David Wilson Homes East Midlands
Agent: Savills
Object to the plan period currently being used (2021 to 2041). SKDC are already 3 years into the plan period and it is likely that the plan will not be adopted until 2026 at the earliest which leaves just 15 years of the plan period remaining. To allow for the timing of the plan adoption being delayed we consider that the plan period should be extended and if the plan period is extended they will need to find more sites. If more sites are required it is considered that more development should be directed towards the Larger Villages such as Harlaxton. DWH’s Site land to the West of Swinehill, Harlaxton offers a sustainable residential development opportunity that should be considered.
Object
Regulation 18 Draft Local Plan
SP1: Spatial Strategy
Representation ID: 2519
Received: 24/04/2024
Respondent: David Wilson Homes East Midlands
Agent: Savills
The Government’s standard methodology identifies the minimum annual housing need which should be used as a starting point. In SKDC’s Local Housing Needs Assessment (February 2024) it suggests that the Council may need to consider increasing the housing need from the standard method figure due to the affordable housing need. Policy H2 provides a requirement for sites 10 dwellings or more (or an area of 0.5 hectares or more) to make a provision for 27-57% affordable housing. 57% is significant and therefore, it is considered that South Kesteven should be planning for more than the minimum level of housing.
The proposed housing mix should be determined on a site by site basis at the time of an application and be informed by market demand. This is considered to be the true measure of housing need within the locality and in accordance with paragraph 31 of the NPPF which states ‘the preparation and review of all policies should be underpinned by relevant and up to date evidence…and take into account relevant market signals’.
Object
Regulation 18 Draft Local Plan
Delivering New Homes
Representation ID: 2520
Received: 24/04/2024
Respondent: David Wilson Homes East Midlands
Agent: Savills
Percentage distribution in Larger Villages is considered to be a small percentage and therefore provides a ‘limited role’ rather than a ‘supporting role’ as stated in the policy. Considers development should be spread further across the identifed sustainable settlements and not just be concentrated in Grantham and the market towns. Harlaxton is classified a Larger Village in the draft Policy SP2 Settlement Hierarchy and is suitable for further growth. The draft policy also states that the proposed allocations should “provide for a variety of site types and sizes to ensure choice is offered to the market and delivery is achievable”. Currently, the draft plan has only allocated one small site in Harlaxton which does not offer much variety in what is offered. Therefore, it is considered further sites should be allocated in Harlaxton, not least sites which have the potential to enhance the sustainability credentials of Larger Villages such as the proposed site.
Support
Regulation 18 Draft Local Plan
SP2: Settlement HierarchyIn
Representation ID: 2521
Received: 24/04/2024
Respondent: David Wilson Homes East Midlands
Agent: Savills
DWH support Harlaxton being identified as a Larger Village. However, despite Harlaxton being one of the most sustainable Larger Villages and having not been the subject of any growth in the adopted Local Plan, only a single small scale allocation is proposed in the settlement (draft allocation SKPR- 74 for 24 dwellings).
The Settlement Hierarchy Study 2017 Harlaxton classed the 4th sustainable Larger Village, however, in the Council’s recent Settlement Hierarchy Review, Harlaxton is classified as 10th sustainable of the 16 settlements regarded ‘Larger Village’. Clarity of why there been such a significant change in how sustainable the settlement is in just 7 years even if other Larger Villages have new facilities.
Object
Regulation 18 Draft Local Plan
SP3: Residential Development within Settlements
Representation ID: 2522
Received: 24/04/2024
Respondent: David Wilson Homes East Midlands
Agent: Savills
DWH do not support draft policy SP3 as clarity is needed on whether this policy is just for sites not allocated. Paragraph 16 (d) of the NPPF states that ‘plans should contain policies that are clearly written and unambiguous, so it is evident how the decision maker should react to development proposals’.
Object
Regulation 18 Draft Local Plan
SP4: New Residential Development on the Edge of Settlements
Representation ID: 2523
Received: 24/04/2024
Respondent: David Wilson Homes East Midlands
Agent: Savills
DWH object to the criteria in policy SP4 states ‘proposals for new residential development… will be supported provided that the essential criteria a-d below are met. It’s considered to be onerous, unclear on what clear local support means. Does it mean the majority (e.g. 51%) support the proposals. It needs to be clear support for the principle of development or the whole proposal (e.g. design). The NPPF outlines pre-application/engagement with the community however, does not state that residential developments adjacent to existing settlements are required to have substantial support from the community for them to be acceptable.
The Policy should be amended in order to only refer to ‘greenfield’ sites on the edge of settlements and not brownfield schemes.
Consideration that the policy be amended so its flexible, recognising that residential development beyond the settlement boun daries in SKDC cannot demonstrate a Five Year Housing Land Supply and the need for substantial community support is removed. Land outside/adjacent to the limits to development are in suitable locations for new development and existing sites within the development limits are not the most appropriate land to deliver the development required.
Object
Regulation 18 Draft Local Plan
SP5: Development Outside of Settlements
Representation ID: 2524
Received: 24/04/2024
Respondent: David Wilson Homes East Midlands
Agent: Savills
This criteria for countryside exemption development is stricter than the exemptions listed under in the NPPF for Green Belt development (paragraph 154). There is also no reference in the draft policy to other national exemptions for isolated homes in the countryside (e.g. exceptional design quality) (NPPF paragraph 84). Draft Policy SP5 goes above and beyond the NPPF and is therefore not consistent with national policy (paragraph 35).
Object
Regulation 18 Draft Local Plan
NEW POLICY 2: Best and Most Versatile Agricultural Land
Representation ID: 2525
Received: 24/04/2024
Respondent: David Wilson Homes East Midlands
Agent: Savills
It is considered that the criteria included is stricter than what is required in NPPF paragraph 180 and is therefore not consistent with national policy (paragraph 35).
This Policy should only be relevant to sites not allocated within the plan and the key item which should be required in this policy is for windfall proposals to demonstrate that the benefits of the scheme outweigh the loss of the agricultural land. A review of other agricultural land should not be required.
Object
Regulation 18 Draft Local Plan
H1: Housing AllocationsThe
Representation ID: 2526
Received: 24/04/2024
Respondent: David Wilson Homes East Midlands
Agent: Savills
As part of the Local Plan review SKDC should undertake a detailed assessment of the progress of historic allocations and if these have been partly delivered or have applications submitted they should not be carried forward as the housing the site will deliver should be for the housing requirement from the previous plan.
We object to only one site being allocated in Harlaxton (SKPR – 74) for 24 dwellings. DWH’s Site land to the West of Swinehill, Harlaxton, for residential development (SHLAA reference SKPR-198) is considered suitable for a residential allocation.