Publication Plan April 2024

Comment

Representation ID: 7153

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Whilst the importance of brownfield sites is recognised, this balanced alongside strategic growth within open countryside and through Green Belt release is necessary to overcome those weaknesses identified by SSDC.

Comment

Representation ID: 7154

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

The Council have allocated the minimum figure of housing required by the standard method – Taylor Wimpey objects to this position as it is insufficient to meet the district’s housing needs. In light of the extended Plan period, consideration must be given to expected population growth and the additional shortfall of housing across the GBBCHMA. Housing provision should be considered in excess of the standard method. (Details of HMA shortfall and housing figures are in paragraphs 4.7 – 4.11 of the full representation).

Comment

Representation ID: 7155

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

The Plan provides a buffer of 10%, this has been reduced from 13% in the 2022 Publication Plan. In view of the 2024 Publication Plan reducing housing supply rather than reducing the buffer, it ought to be increasing it as there will be less supply overall and a proportionally greater impact if sites do not come forward.

Comment

Representation ID: 7156

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Windfall development comprises 600 homes. Historic windfall delivery rates have been based on historic permissions to achieve a capacity of 35dph. These developments were based on less onerous policy provisions which did not require the delivery of 10% BNG, NDSS or M4(2)/M4(3) compliant homes. The strategy also fails to address affordability concerns, stating that affordable housing could be reduced to below 30% if viability is an issue. (Details of HMA shortfall and housing figures are in paragraphs 4.7 – 4.11 of the full representation).

Comment

Representation ID: 7157

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

The requirement that 70% of properties comprise 3-bedrooms or less is restrictive and does not afford the flexibility expected by NPPF paragraph 63. The use of the phrase ‘disproportionate’ lacks the precision and clarity needed for a Plan policy. The policy should recognise that needs and demand will vary from area to area, including individual settlements. Clarification should also be made in defining ‘major’ development. Taylor Wimpey suggest a definition of major development should be reintroduced to the Plan, with the DMPO definition referred to for the avoidance of doubt. The policy is considered unsound.

Comment

Representation ID: 7158

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

The flexibility afforded to housing density and the recognition that although a minimum of 35dph across the wider site should be delivered, the density of development within a scheme may vary to take account of local character impacts and the provision of services and facilities across a development, is welcomed.

Comment

Representation ID: 7159

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

The use of the term ‘major residential development’ in this context requires a definition. The 30% requirement appears to be supported by the Viability Study but it does highlight the challenges in delivering such a requirement and the need for higher site values to be achieved to deliver this. The Council’s position to continue using S106 agreements to secure the necessary infrastructure to support and mitigate development is supported.
The requirement to ‘pepper pot’ affordable housing is generally supported. However, the policy should recognise that for management purposes, Registered Providers do require a degree of clustering of affordable housing within a development.
The frequent reference to the Affordable Housing SPD is noted, but it should do no more than clarify the Local Plan policy.

Comment

Representation ID: 7160

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

The policy needs to define ‘older people’ as it is unclear as to exactly who the policy is targeting or who would be eligible to occupy such dwellings. Extra care and retirement living often need a minimum critical mass to be viable and the Council needs to determine which should be able to support the provision of such accommodation, it also needs to provide much greater clarity on when such housing will be required and to make clear that some housing types may be required on any given site.

Object

Representation ID: 7161

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

It is noted that the Plan continues to require 100% of all housing to be M4(2) compliant. This raises an issue of affordability. Whilst the principle is agreed, it is not a requirement of the whole population to have such a provision and delivering this will have an impact on the overall capacity of sites to deliver new homes. The M4(2) standard is optional within Building Regulations, if the Government had intended that evidence of an ageing population alone justifies adoption of optional standards, then such standard would be mandatory. The requirement for 100% M4(2) homes is not considered to be adequately justified.

Comment

Representation ID: 7162

Received: 31/05/2024

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

The policy should be clear that in having regard to the Council’s self-build register, it is only Part 1 of the register which needs to be considered. The policy should also recognise that delivery of self-build housing on new residential sites successfully occurs when there is a distinct phasing or grouping of plots secured for such delivery. Whilst Taylor Wimpey generally supports the concept of self-build housing, they do not consider providing them as part of a larger housing development is the most appropriate solution. Taylor Wimpey supports the position that should a proposed custom self-build not be sold after 12 months following marketing, then the developer will be permitted to building out the plan as a standard property type.