Regulation 18 Draft Local Plan
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Regulation 18 Draft Local Plan
The issue for South Kesteven
Representation ID: 1101
Received: 24/04/2024
Respondent: Persimmon Homes East Midlands
If a policy is included in the Reg 19 Plan it should accord with the Housing Minister's Statement from December 2023 in terms of justification and evidence base. If such a policy is included in the Regulation 19 Plan it should be worded to allow for flexible application with regards to technical feasibility and viability.
Support
Regulation 18 Draft Local Plan
SP4: New Residential Development on the Edge of Settlements
Representation ID: 1103
Received: 24/04/2024
Respondent: Persimmon Homes East Midlands
Persimmon Homes would suggest point a) should be amended as community support would rarely be forthcoming. The policy also needs to define what is meant by 'edge of settlement'.
Support
Regulation 18 Draft Local Plan
SP5: Development Outside of Settlements
Representation ID: 1104
Received: 24/04/2024
Respondent: Persimmon Homes East Midlands
Clarification is needed within the plan on what is meant by the term 'outside of settlements' as there are no settlement boundaries within the Plan.
Object
Regulation 18 Draft Local Plan
H2: Affordable Housing Contributions
Representation ID: 1107
Received: 24/04/2024
Respondent: Persimmon Homes East Midlands
Exact affordable housing requirements should be specified in the policy and these should not be above the indicative figures set out in the Whole Plan Viability Assessment 2024.
A higher requirement for affordable housing on strategic sites is questioned given the high infrastructure costs for such developments. First Home discounts should be set at 30%.
The Whole Plan Viability needs to recognise that revenues are down, build costs are up and extra requirements on sites (BNG and Building Regs Part L) impact on the viability of schemes.
Support
Regulation 18 Draft Local Plan
H4: Meeting All Housing Needs
Representation ID: 1108
Received: 24/04/2024
Respondent: Persimmon Homes East Midlands
It is unclear from criteria paint 9a) exactly what is expected from housing developments, for example, on smaller ‘major development’ sites it will not be feasible to provide retirement accommodation, extra care and residential care housing.
To allow for the flexible application of criteria points a) to d), Persimmon Homes would suggest adding the word ‘consider’ be added to the statement ‘New housing proposals should also consider:’
Support
Regulation 18 Draft Local Plan
NEW POLICY 4: Biodiversity Opportunity and Delivering Measurable Net Gains
Representation ID: 1113
Received: 24/04/2024
Respondent: Persimmon Homes East Midlands
Suggest the first sentence of paragraph 2 be amended to allow some element of flexibility.
Clarification is needed on what is expected in terms of the delivery of wider environmental net gains.
In terms of planning application submissions, criteria points c, d and e should encouraged rather than mandatory.
Support
Regulation 18 Draft Local Plan
EN4: Pollution Control
Representation ID: 1115
Received: 24/04/2024
Respondent: Persimmon Homes East Midlands
Persimmon Homes are of the view that developments should not have to improve any existing harmful impacts.
Support
Regulation 18 Draft Local Plan
EN5: Water Environment and Flood Risk Management
Representation ID: 1116
Received: 24/04/2024
Respondent: Persimmon Homes East Midlands
Paragraph 1 and 2 of this policy set out that where new development is proposed within high risk flood areas a sequential test is required. Persimmon Homes are of the view that this policy needs to acknowledge that such an assessment is not required if the site is an allocation within the Local Plan.
Object
Regulation 18 Draft Local Plan
EN6: The Historic Environment
Representation ID: 1117
Received: 24/04/2024
Respondent: Persimmon Homes East Midlands
Preservation in situ should not be a default preferred solution . Whether remains need to be preserved in situ will be determined on a site by site basis, depending on results of the Desk Based Assessment and on site investigations, alongside early engagement with the County Council's Historic Environment Team.
Support
Regulation 18 Draft Local Plan
DE1: Promoting Good Quality Design
Representation ID: 1118
Received: 24/04/2024
Respondent: Persimmon Homes East Midlands
Paragraph 1 sets out that all development proposes will be expected to ‘adhere’ to Design Codes and SPD’s. Persimmon Homes are of the view that the word ‘adhere’ be replaced with ‘in accordance with’, this wording would allow some flexibility in the application of this policy. For the same reason, Persimmon Homes would also suggest that the paragraph starting ‘All major development (as defined in the Glossary must demonstrate compliance with..’ be reworded to ‘All major developments (as defined in the Glossary) shall be in accordance with …’.
