Regulation 18 Draft Local Plan
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Regulation 18 Draft Local Plan
Chapter 2 - South Kesteven District
Representation ID: 1353
Received: 25/04/2024
Respondent: Wates Developments
Agent: Boyer Planning
We encourage the Council to extend the plan period by at least another two years to a time
horizon of 2043 which will allow for any further delays in plan making whilst still ensuring that the minimum time period can be achieved. Extending the plan period, also allows further years
of development and growth to take place and therefore provides a greater buffer in terms of
housing numbers (potentially an additional 1,402 units when using the housing target of 701
dwellings per annum as found in the plan) thus giving the local communities greater choice
and flexibility for housing and employment options.
Support
Regulation 18 Draft Local Plan
2041 Vision for South Kesteven
Representation ID: 1354
Received: 25/04/2024
Respondent: Wates Developments
Agent: Boyer Planning
We are in support of the overall Vision in increasing the importance of tackling Climate Change as well as creating sustainable, diverse, and safe communities across the district. To strengthen the Vision to further ensure it is considered as sound, as discussed, the Plan period should be increased, and the Vision should be amended accordingly to account for the additional years.
Support
Regulation 18 Draft Local Plan
Strategic Objectives for the Local Plan
Representation ID: 1355
Received: 25/04/2024
Respondent: Wates Developments
Agent: Boyer Planning
The draft Plan also provides the strategic Objectives for the Local Plan moving forwards. The Objectives have been amended to emphasise the approach towards Biodiversity and Climate Change. There are 2 Objectives identified within the Social Objectives (Housing, Health, Social and Community Needs), Objective 10 and Objective 11. However, there are additional Objectives that relate to housing provided within the Economic Objectives (Objectives 5 and 9) and the Environmental Objectives (Objectives 12 and 13).
We consider that Objective 9 should be amended to take into the consideration in the extension of the Plan period, and thus the increased need for housing across the district.
However, we are pleased to see that the Council have provided an approach and set Objectives which are largely pro-growth whilst requiring the provision of diverse and sustainable communities, that are well-designed to create safe communities which are energy efficient, assisting in combating Climate Change.
Support
Regulation 18 Draft Local Plan
SD1: The Principles of Sustainable Development in South Kesteven
Representation ID: 1357
Received: 25/04/2024
Respondent: Wates Developments
Agent: Boyer Planning
Although we are broadly supportive of the approach set out in Policy SD1, we would suggest that any further revisions to the policy provide greater clarity as to the expectations of how development proposals are to meet criteria a-m within the policy. At the moment, it is unclear as to whether each of these 13 requirements has to be met and the relationship between them and a future iteration of the policy should better reflect this to ensure the policy is effective and justified and therefore capable of being found “sound” when subject to Examination in the
future.
Support
Regulation 18 Draft Local Plan
The impacts of Climate Change in the UK
Representation ID: 1360
Received: 25/04/2024
Respondent: Wates Developments
Agent: Boyer Planning
The Council is rightly taking a positive and ambitions approach to addressing Climate Change
and has put this topic central to their actions as a local planning authority but has missed the
opportunity to seek meaningful and collaborative public engagement by not including any draft
policies within the Regulation 18 document.
Support
Regulation 18 Draft Local Plan
NEW POLICY 4: Biodiversity Opportunity and Delivering Measurable Net Gains
Representation ID: 1361
Received: 25/04/2024
Respondent: Wates Developments
Agent: Boyer Planning
Concerned that the policy simply repeats national policy and therefore is potentially not required, however it is positive to see the Council being proactive in ensuring that Biodiversity is achieved through developments.
Reference is made to development proposals being in line with other documents that are prepared outside of the Local Plan process which is a concern and needs to be addressed more accurately within the Regulation 19 document. We are also concerned that the Local
Nature Recovery Strategy is embedded into the policy wording even though this is not yet completed and question whether this would be an effective policy when considered against the test of soundness in the NPPF.
is positive to see that the Council seek on-site net gain where possible, but the policy has flexibility to allow for off-site measures to be considered in specific circumstances. It is important that any Local Plan policy incorporates flexibility and how this might be achieved through a combination of on-site and off-site measures where appropriate.
Support
Regulation 18 Draft Local Plan
SB1: Sustainable Building
Representation ID: 1363
Received: 25/04/2024
Respondent: Wates Developments
Agent: Boyer Planning
Over the plan period the requirements, standards and targets are likely to change as best practice and modern technologies change and evolve and bring about greater efficiencies and outcomes for both the residents of new residential dwellings, the local community and the development industry. As such we are concerned that policy SB1 as currently written will not be flexible and effective over the plan period and greater focus should be given to development proposals needing to meet the mandatory building regulations and where possible exceeding
these standards.
As the Council is aware, the building regulations are constantly being updated and revised to reflect more standards and legislation covering all aspects such as energy consumption, water use and requirements such as EV charging. Therefore policy SB1 is at risk of becoming redundant in the short term as building regulations will require greater standards than those outlined in the emerging policy.
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Regulation 18 Draft Local Plan
SKPR-109 – Land Fronting Deeping Road
Representation ID: 1366
Received: 25/04/2024
Respondent: Wates Developments
Agent: Boyer Planning
The Council are seeking to provide development within the sustainable, large villages of the district, of which Baston is able to demonstrate this position. Wates are passionate about tackling climate change and welcome this opportunity to work with South Kesteven District Council and the Parish Council of Baston to assist in improving the sustainability of housing across the district. This allocation and wider site is readily available for development as a
whole and is deliverable and has the ability to come forward in a timely manner early within plan period.
Further to the allocated site fronting Deeping Road for 86 dwellings, the allocation has the ability to be expanded to include the land adjacent to the west to provide a total of up to 250 dwellings in addition to further landscaping, open space, drainage and associated infrastructure.
Both sites (SKPR-109 and SKPR-110) are in the same land ownership and control and should come forward comprehensively to provide greater benefits for the local community and the District as a whole. Whilst we largely agree with the scoring of the RAG assessment and conclusion of the site as an appropriate location for development, after a review there are some constraints that are required to be rescored.
Support
Regulation 18 Draft Local Plan
Chapter 13 – Infrastructure and Developer Contributions
Representation ID: 1370
Received: 25/04/2024
Respondent: Wates Developments
Agent: Boyer Planning
The summary box on page 235 of the Regulation 18 document details that “An Infrastructure
Delivery Plan, including an Infrastructure Delivery Schedule, is being prepared and will inform
the policy once finalised.” We are concerned that the details of these important evidence base documents is not provided at this stage of the plan making process to allow for engagement and representations to be made on approach, requirements and timescales envisaged.
Paragraph 13.16 of the Regulation 18 document confirms that the Council will continue to seek developer contributions through Section 106 and may consider the introduction of a Community Infrastructure Levy or a replacement tariff following the Governments national
review. Although we broadly support this approach, the Local Plan needs to provide an indication as to the level of Section 106 that may be requested for different types of
development in different parts of the plan area. Without this clarification, the Council’s Viability Appraisal is flawed because assumptions used in relation to Section 106 may not be accurate and therefore could be under or over stating requirements that need to meet the tests for
planning obligations.
Support
Regulation 18 Draft Local Plan
ID1: Infrastructure for Growth
Representation ID: 1371
Received: 25/04/2024
Respondent: Wates Developments
Agent: Boyer Planning
Policy ID1: Infrastructure for Growth outlines the Council expectations for ensuring that the necessary infrastructure provision is provided at the appropriate time and in a suitable location. It is important that the policy and supporting text recognise that as part of development opportunities the provision of infrastructure is not solely within the “gift” of the developer/applicant. In most instances, the Section 106 obligation can provide the land and/or funds to aid the provision of infrastructure but often the service provider (such as education, utilities) is responsible for the delivery of the infrastructure. As a result, it is unreasonable to expect that development proposals provide the necessary infrastructure at an appropriate time as this fails to acknowledge the range of parties that need to align and be involved with bringing forward the infrastructure