Publication Plan April 2024

Support

Representation ID: 6756

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Savills

Clowes supports HC8 as the approach is flexible.

Object

Representation ID: 6757

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Clowes objects to HC17 as written because it is not effective or justified. No definition of what constitutes ‘small’ is provided or how applicants can demonstrate that it serves a purpose. SSDC has also not provided any information to justify why small areas of green infrastructure will not be regarded as part of the open space provision. These areas may not always be ‘useable’ from a recreation perspective but they can still provide visual benefits for residents and place-making. Policy HC17 should be amended to remove reference to smaller areas of incidental green infrastructure not forming part of the on-site open space standard as it is too restrictive.

Object

Representation ID: 6758

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Clowes objects to NB4 because it is not in accordance with national policy, justified or effective. There is no requirement in the NPPF to protect all trees. We do not consider that Category C or U trees should be afforded any specific protection within the policy. In order for the policy to be consistent with national policy, it should be amended to remove protection of trees which are not defined as ‘irreplaceable habitats’.

Object

Representation ID: 6760

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We object to SA3 because it is not justified, and therefore does not meet the tests of soundness. We consider this policy should be amended to include Land at Lawnswood Road (site 654). We have critiqued the Council’s evidence base position and reviewed this against a new evidence base which provides a more detailed assessment of the site specific position. All details relating to this assessment and the development proposals for the site can be found in the full representation (SA3).

Comment

Representation ID: 7038

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Despite acknowledging a higher-than-average aging population and decline in families and working age residents, SSDC does not seek to directly address this issue by prioritizing the delivery of family homes and ensuring the housing needs of the working age population are met across the Plan period. Contributing a larger proportion of homes to the HMA would assist in addressing this issue, improving affordability of homes.

Comment

Representation ID: 7039

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

The Plan’s vision and objectives should be amended to reflect the need to meet both the present and future housing requirements, including those pressures arising through the Duty to Cooperate with neighbouring authorities, in particular the GBBCHMA.

Object

Representation ID: 7040

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Strategic Objective 1 lacks clarity and does not define the exceptional circumstances for release of Green Belt land as part of its strategy. It should be made clear that the need to identify land for growth and development over the Plan period, and beyond, means that there are exceptional circumstances arising which have required a full & detailed Green Belt boundary review.

Comment

Representation ID: 7041

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

Strategic Objective 2 could be strengthened in meeting the needs of both existing and new residents of the District and GBBCHMA. In determining what is considered to be a proportionate contribution to the HMA’s unmet housing needs, SSDC must ensure specific consideration has been given to the district’s ability to make a substantially larger contribution, and greater recognition should be given to Tier 2 and 3 settlements.

Comment

Representation ID: 7042

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

DS1 is broadly in line with the relevant paragraphs in the NPPF and is therefore supported. However, Clowes do not accept the Council’s proposition that Green Belt ‘contributes towards rural character’. Green Belt is a development restraint policy set out at Chapter 13 of the NPPF and therefore the Council should amend the text in DS1 and its supporting text to represent national policy.

Comment

Representation ID: 7043

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Pegasus Group

The Council are of the view that the Growth Study, on which the 4,000 contribution to the HMA was based, is out of date. Details on the HMA and shortfalls for other LA’s can be found in paragraphs 5.3 – 5.8 of the full representation. The Green Belt Exceptional Circumstances Topic Paper 2024 continues to acknowledge the exceptional circumstances for the release of Green Belt land, however, in terms of delivering housing for the District and HMA, this continues to focus on non-Green Belt options. Only 0.16% of the district’s Green Belt is proposed for release despite the significant unmet need for the HMA. There are clear opportunities for sustainable housing development across the district through Green Belt release whilst ensuring a significant quantum of high value Green Belt land is protected.