Regulation 18 Draft Local Plan

Support

Representation ID: 2537

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

DWH support Policy EN6 and the wording which states ‘development that is likely to cause harm to the significance of a heritage asset or its setting will only be granted permission where the public benefits of the proposal outweigh the potential harm’ and consider it to be in accordance with paragraphs 208 of the NPPF which states ‘where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use’. The rest of the policy is written using wording such as ‘development proposals should aim to’ [Savills Emphasis] which is in a way that 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’.
Site is also proposing to provide facility land which is a community benefit.

Object

Representation ID: 2538

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

DE1: Promoting Good Quality Design
DWH do not support policy DE1. The policy states: ‘applications for Planning Permission that are not well designed will be refused’ [Savills Emphasis]. The wording is not clear as ‘well designed’ is subjective. Further to this, the language used is not flexible and words such as ‘must’ and ‘should’ are used throughout the policy. Words used should be more flexible such as ‘where practicable’ or ‘could’ or ‘where feasible’ rather than applying unrealistic blanket restrictions to all development. This is in accordance with paragraph 16 (b) of the NPPF which states: ‘plans should be prepared positively in a way that it is aspirational but deliverable’. DWH also consider that bullet 3 (c) should be reworded to align with the NPPF and footnote 53 ‘unless, in specific cases, there are clear, justifiable and compelling reasons why this would be inappropriate layouts should be designed to ensure that sufficient space is given for the creation of tree lined streets and trees within other public spaces’

Object

Representation ID: 2539

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

The policy as stated in the Ministerial Statement that was issued in December 20233 should not go beyond national standards. The Ministerial Statement states ‘a further change to energy efficiency building regulations is planned for 2025 meaning that homes built to that standard will be net zero ready and should need no significant work to ensure that they have zero carbon emissions as the grid continue to decarbonise. Compared to varied local standards, these nationally applied standards provide much-needed clarity and consistency for businesses, large and small, to invest and prepare to build net-zero ready homes’. It goes on to state that ‘the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations’ [Savills Emphasis]. Therefore, it is considered that the plan should only require development to comply with current or planned building regulations and not ask developers to meet local needs which go beyond these.

Support

Representation ID: 2540

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

DWH are generally supportive of this policy. However, it is important that all statutory consultees provide realistic assumptions on contributions that will be sought for proposed allocations in order to avoid the need for further viability assessment at the decision making stage (PPG Reference ID: 10-002-20190509). Currently the Viability Assessment just notes an assumption of S106 Agreement costs of £20,000 per unit. It is unclear from the Assessment whether this is based on what has been requested by consultees or just experience by the Consultants elsewhere.

Support

Representation ID: 2541

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

DWH generally supports this policy and that the viability assessment referred to includes infrastructure improvement costs in the assessment. This is in accordance with the PPG Paragraph: 001 Reference ID: 10- 001-20190509 ‘plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such as that needed for education, health, transport, flood and water management, green and digital infrastructure)’. However, the specifics on what the infrastructure requirements are have not been set out as such therefore it is not clear what the figures are based on.

Object

Representation ID: 2542

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

DWH object to Policy ID3. It is considered that ‘where possible’ should be added so the policy states ‘where possible new developments must be served by either: Fibre to the Premises…or Fibre to the Cabinet technology’. This is accordance with NPPF paragraph 16 (b) which states that ‘plans should be prepared positively, in a way that is aspirational but deliverable’.

Object

Representation ID: 2543

Received: 24/04/2024

Respondent: David Wilson Homes East Midlands

Agent: Savills

DWH object to the complete policy removal of Policy M1. Although it is considered that SKDC do not need to commit to an early review of their plan they should keep a review policy in as in accordance with paragraph 33 of the NPPF they will need to review the plan after 5 years.