Preferred Options November 2021

Object

Representation ID: 1276

Received: 13/12/2021

Respondent: CCB Investments

Agent: RCA Regeneration

- Strategic Objective 1: Concerned at the lack of clarity of how this objective will be delivered; unlikely that most developers will have control over other land parcels. Do not consider this objective deliverable.
- Strategic Objective 2: It is unclear how this contribution is disaggregated across the HMA. Details of agreements made under the Duty to Co-operate should be included in the evidence base.
- Strategic Objective 9: Strategy relies on new rail stations but rail is not mentioned in the objective – suggest this is mentioned. The importance placed upon rail does not reflect some of the sites selected.

Object

Representation ID: 1277

Received: 13/12/2021

Respondent: CCB Investments

Agent: RCA Regeneration

Policy DS1 repeats the Framework and could be – in part – removed. On-site green infrastructure can be delivered but compensatory improvements create uncertainties for landowners and developers and are unlikely to be deliverable. It is unclear how development in the Green Belt could maintain its character and openness. Encourage the Council to set out the exceptional circumstances required to remove sites from the Green Belt.

Policy DS2 – It is unclear what forms of development would or would not be acceptable in open countryside. The policy wording as a whole should be revisited.

Object

Representation ID: 1278

Received: 13/12/2021

Respondent: CCB Investments

Agent: RCA Regeneration

The plan should be revisited to reflect updated March 2022 affordability ratios. Unclear whether safeguarded land is to remain as safeguarded, but safeguarded land should be included in addition to housing requirement. Windfall allowance is excessive. Spatial strategy overlooks growth opportunities in sustainable settlements and is over reliant on urban extensions which require significant infrastructure to be made sustainable. Pattingham is one of the most unaffordable areas in the District and this has not been factored in to the strategy.

Given the time that has elapsed since the spatial strategy was adopted more progress should have been made to deliver the Land at Cross Green housing site.

Object

Representation ID: 1279

Received: 13/12/2021

Respondent: CCB Investments

Agent: RCA Regeneration

The plan should be revisited to reflect updated March 2022 affordability ratios. Unclear whether safeguarded land is to remain as safeguarded, but safeguarded land should be included in addition to housing requirement. Windfall allowance is excessive. Spatial strategy overlooks growth opportunities in sustainable settlements and is over reliant on urban extensions which require significant infrastructure to be made sustainable. Pattingham is one of the most unaffordable areas in the District and this has not been factored in to the strategy.

Given the time that has elapsed since the spatial strategy was adopted more progress should have been made to deliver the Land at Cross Green housing site.

Object

Representation ID: 1280

Received: 13/12/2021

Respondent: CCB Investments

Agent: RCA Regeneration

Why is the policy included when it applies to a time period outside the scope of the plan -why not extend the plan period instead?

Object

Representation ID: 1281

Received: 13/12/2021

Respondent: CCB Investments

Agent: RCA Regeneration

Policy SA2 – Delivery of the site is heavily reliant on the ‘Land at Cross Green SPD’ and there is no clear justification to demonstrate that this allocation can be implemented. As there is no clear timeline for delivery the plan should allocate further sites to ensure it can meet the 8,881 dwelling housing target.

Object

Representation ID: 1282

Received: 13/12/2021

Respondent: CCB Investments

Agent: RCA Regeneration

Strongly object to omission of Westbeech Road, Pattingham (Site 253). Site is sustainably located without need for major infrastructure investment. Site owners are in negotiation with a local GP to accommodate a new purpose-built medical centre. Site is highly sustainably located, would have little/no impact in terms of infrastructure and would only result in minor Green Belt harm. In comparison, proposed Site 255 is not in a sustainable location, is not well screened compared to Site 253 and could adversely impact the setting of a listed building. Proposed Site 251 is of questionable sustainability and has a greater impact on heritage assets than Site 253. Allocating Site 253 reinforces the overall strategy and should be allocated in this Local Plan Review.

Object

Representation ID: 1283

Received: 13/12/2021

Respondent: CCB Investments

Agent: RCA Regeneration

HC1 – Should be flexible to allow for development outside of the plan scope
HC3 – Policy should be amended to avoid affordable housing being fixed. Greater clarity on pepper potting thresholds should be given. Provision relating to grant funding should be removed. Offsite/financial contributions should be subject to viability/market evidence.
HC4 – unclear what the justification is for requiring both NDSS and M4(2) on 30% of new dwellings.
HC6 – the restriction on market housing cross-funding should be lifted in the Green Belt. Do not consider policy consistent with the NPPF.
HC7 – Requiring self-build plots on all major developments is onerous and provides no certainty in terms of level of provision. Specific small plots should be allocated for self-build instead.
HC9 – Tree lined streets should be detailed further and may have viability implications. Requiring a Design and Access Statement for all applications would be overly onerous for householders and very minor applications.
HC11 – Suggest flexibility to indicate most development should meet NDSS
Amend policies to clarify that development should not solve existing infrastructure problems.
HC17 – Requiring play equipment on all schemes is disproportionate on smaller sites near existing facilities. Provision should be based on bedspaces and requiring open space to be centrally located should be removed.
HC19 – Vague policy that should be substantiated prior to an SPD.
NB5 – Omission of energy storage needs addressing to address intermittent renewable generation.
NB7 – Disagree that all major developments should provide an FRA. Disagree that all major developments should provide SuDS, particularly on brownfield sites.