Object

Representation ID: 1446

Received: 13/12/2021

Respondent: Richborough Estates

Agent: Pegasus Group

HC1 – Is not sufficiently clear or flexible with expectations and should be subject to viability assessment. Major development should be defined using DMPO, not NPPF.
HC2 –Blanket approach is unlikely to be effective.
HC3 – Should justify why social rent (rather than affordable rent) is the preferred tenure. Registered providers do require a degree of clustering for affordable housing. Funding mechanisms for affordable housing delivery are not a planning matter.
HC4 –Unclear justification for use of M4(2) and for the proportion sought, which does not reflect SHMA.
HC7 – Smaller dedicated self/custom build sites should be identified, rather than a blanket requirement and should include flexibility if no demand.
HC9 – Tree-lined streets should only be required with highways authority agreement. Design codes should be limited to strategic sites.
HC11 – M4(2) dwellings should have smaller gardens. NDSS is only supported by the SHMA on accessible/adaptable homes, not all properties.
HC12 – Standards (including EV chargers) are supported.
HC14/15 – SSDC should engage with CCG and SCC education to ensure all likely costs are known and assessed through viability.
HC17 – On-site equipped play is not supported where existing provision exists nearby. Requirements for centrally located greenspace and exclusion of small incidental green infrastructure is not supported.
HC18 – Should define standards expected from development.
EC3 – Blanket requirement is not supported and fails to recognise the benefits of modular methods of construction.
EC9 – Engagement with providers should be taking place now.
EC10 – A detailed list of infrastructure requirements should be included in plan.
NB3 – Studies should influence policy approach
NB6 – Policy should confirm threshold for sites requiring energy statement.