Regulation 18 Draft Local Plan

Object

Representation ID: 2527

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

SKPR-272 Barrowby is not considered to be capable of delivering the 270 units as identifed in the table in Policy H1. Part of this site has already been delivered and the rest of the site has planning applications already submitted. Paragraph 12.62 of the draft plan states ‘the allocation at Barrowby will deliver up to 270 new dwellings’ and acknowledges that ‘part of the site has been completed with 49 new homes delivered in 2021/2022 as part of an affordable housing scheme’. As such, part of the site has already been delivered and subsequently it is considered further dwellings will need to be found to replace the allocation.

Object

Representation ID: 2528

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

SKPR-272 Barrowby is not considered to be capable of delivering the 270 units as identifed in the table in Policy H1. Part of this site has already been delivered and the rest of the site has planning applications already submitted. Paragraph 12.62 of the draft plan states ‘the allocation at Barrowby will deliver up to 270 new dwellings’ and acknowledges that ‘part of the site has been completed with 49 new homes delivered in 2021/2022 as part of an affordable housing scheme’. As such, part of the site has already been delivered and subsequently it is considered further dwellings will need to be found to replace the allocation.

Object

Representation ID: 2529

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

The policy is considered to be at odds to the evidence and should be amended to state that ‘all development comprising 10 or more dwellings (or an area of 0.5ha or more) should make provision for 20-30% affordable’. This, by virtue, implies that the proposed allocations are not sufficient to meet the District’s affordable housing need.
Paragraph 7.18 of the supporting text (and table 4) provides the affordable housing mix that the Local Housing Needs Assessment (2023) recommends, however, the mix is not included in the policy and table 4 provides a percentage range, acknowledging that the range will depend on the site specifics and market. This is welcomed as the policy provides guidance but is flexible which is in accordance with paragraph 16 (b) of the NPPF which states ‘plans should be prepared positively, in a way that is aspirational but deliverable’.

Object

Representation ID: 2530

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

Consider that the requirement for 10% M4(2) properties should be properly evidenced and balanced against the need to make the most efficient use of land available and site viability.
DWH welcome that the housing mix is included within Table 4 and provides an ‘indictive’ mix of homes and ranges. This provides welcome flexibility as its not within the policy (the policy just says ‘provide appropriate type and size of dwellings’). However it is considered that draft plan should still refer to market considerations being key. This is referred to in our response to policy SP1 and explained in more detail.

Support

Representation ID: 2531

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

The inclusion of the wording ‘wherever feasible’ is welcomed as this provides flexibility which is in accordance with paragraph 16 (b) of the NPPF which states ‘plans should be prepared positively, in a way that is aspirational but deliverable’.
DWH’s Site land to the West of Swinehill, Harlaxton is proposing to provide facility land for a community use. It is considered that the location of the facility will be in accordance with criteria a-f. It will be well located to serve the community, prioritise and promote access by walking, cycling and public transport, the facility is accessible to a wider catchment, be physically accessible to all members of society. It is expected to be designed to be adaptable to future demands and will be operated without detriment to local residents. The provision of the 7
facility land will be a benefit to local residents and there is an opportunity for it to provide land for the doctor’s surgery which is considered to be currently oversubscribed.

Object

Representation ID: 2532

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

DWH do not support policy EN2. The policy states that ‘the Council…will facilitate…the…enhancement of the District’s Biodiversity…this includes seeking to enhance ecological networks and seeking to deliver a net gain on all proposals’ [Savills Emphasis]. It is considered that the policy should define the exact net gain expected (10%) to be delivered so it is in line with the requirements as defined in New Policy 4 and most importantly so the policy is consistent with national policy so it is in accordance with NPPF paragraph 35 (d) which states ‘plans are ‘sound’ of they are consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant’. The policy should also make clear that exempt development should not be required to deliver net gain.

Object

Representation ID: 2533

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

The policy does not explain what the ‘wider environmental gains’ and therefore is not in accordance with paragraph 16(d) of the NPPF which requires policies to be clearly written. It should be clarified in the policy that this is not in addition to the 10% BNG requirement.
DWH are unclear on mapping/identification of sites for the Biodiversity and Green Infrastructure Areas Opportunity Areas have been decided. Paragraph 16 (d) of the NPPF states ‘plans should contain policies that are clearly written and unambiguous, so it is evident how the decision maker should react to development it is considered this should be clearly set out in the policy or within the appendix.
As part of any development on the site, wider biodiversity and green infrastructure improvements could potentially be made to connect the biodiversity and green infrastructure opportunity areas identified east of Swinehill Lane and north of the A607.

DWH consider that the policy stating that ‘all qualifying development proposals…must deliver at least 10% measurable biodiversity net gain’

Support

Representation ID: 2534

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

DWH are unclear on mapping/identification of sites for the Biodiversity and Green Infrastructure Areas Opportunity Areas have been decided. Paragraph 16 (d) of the NPPF states ‘plans should contain policies that are clearly written and unambiguous, so it is evident how the decision maker should react to development it is considered this should be clearly set out in the policy or within the appendix.
As part of any development on the site, wider biodiversity and green infrastructure improvements could potentially be made to connect the biodiversity and green infrastructure opportunity areas identified east of Swinehill Lane and north of the A607.
DWH consider that the policy stating that ‘all qualifying development proposals…must deliver at least 10% measurable biodiversity net gain’.

Object

Representation ID: 2535

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

DWH object to policy EN4 and consider it be rephrased to state: ‘Where practical and viable development should seek to minimise pollution…’ This amending wording is in accordance with the NPPF paragraph 16 (b) which states ‘plans should be prepared positively, in a way that is aspirational but deliverable’.

Object

Representation ID: 2536

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

DWH object to policy EN5. The policy should ensure it makes it clear that the sequential test is only required 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’.