Publication Plan April 2024

Object

Representation ID: 6882

Received: 31/05/2024

Respondent: UKPI (Featherstone) Ltd

Agent: First City Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Further clarification is required on how policies HC4 and HC5 differ and what is the criteria for when they would be applied to a site and planning application as policy HC4 wording suggests it should be all major development sites whereas HC5 suggests there are a number of criterion to be met before the requirement for specialist housing to be integrated on a site.

Object

Representation ID: 6883

Received: 31/05/2024

Respondent: UKPI (Featherstone) Ltd

Agent: First City Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Paragraphs 147 of the NPPF makes comments about reviewing Green Belt boundaries and promoting substantive patterns of development. No further guidance is provided as to what this would entail or how this should be provided/maintained and determined if there is a threshold/quantity that should be provided. Policy DS2 advises on compensatory improvements being incorporated into Section 106 agreements and sets out a hierarchy of where this can be accommodated. There is also reference to a commuted sum being suggested in some instances. However, there is no indication as to what the amount of compensation either monetary or otherwise would be. We consider this should not apply to previous safeguarded land allocated for future development from previous plans brought forward to the emerging Local Plan. We have received confirmation of this following a conversation with Policy officers however, we consider this should be made clear within the text of the Local Plan. All sites which this applies to should be notified and the compensatory provision set out in Appendix B – F of the local plan as part of the key requirements. Further guidance at this stage should also be set out how the compensatory improvements to the environmental quality and accessibility to remain Green Belt related to biodiversity net gain and the duplication of compensation.

Support

Representation ID: 6884

Received: 31/05/2024

Respondent: UKPI (Featherstone) Ltd

Agent: First City Limited

We support the notion of creating a mixed, sustainable and inclusive community with a mixture of property sizes, types and tenures in order to meet the needs of different groups in the community.

Object

Representation ID: 6886

Received: 31/05/2024

Respondent: UKPI (Featherstone) Ltd

Agent: First City Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Do not agree with the plan being too prescriptive which could potentially hinder the delivery of sites.

There is a collective desire for a range of house types, but there is also the desire for sites to have an element of flexibility and individuality on a site by site basis.

Housing mix should be guided by market signals as reflected in the most up-to-date assessment of needs. Such assessments will need to be updated over the course of the Plan period. The requirement that 70% of properties comprise of three-bedrooms or less could be considered restrictive and may conflict with the flexibility expected by NPPF Paragraph 63 in order to meet the need to provide for a range of size, type, and tenure for different groups.

It is important to note that there remains a need for 4+ bedroom houses within the District as indicated in the supporting evidence within the Strategic Housing Market Assessment 2024 (Table 8.1).

The use of the phrase ‘disproportionate’ in the penultimate paragraph, when describing the quantum of 4+ bedroom houses, lacks a level of clarity and therefore is open to interpretation. The policy should recognise that needs and demand will vary from different areas and different sites.

Object

Representation ID: 6887

Received: 31/05/2024

Respondent: UKPI (Featherstone) Ltd

Agent: First City Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We do not object to a minimum density being applied to sites. However, again we do not consider policy should be too prescriptive as there needs to be a level of flexibility from area to area and site to site. A compulsory density would not be suitable for all sites. The density of development within a scheme may vary to take account of local character impacts, site specific characteristics and the provision of services and facilities across a development and should not impact or conflict with other policy provisions that apply to particular sites.

Object

Representation ID: 6888

Received: 31/05/2024

Respondent: UKPI (Featherstone) Ltd

Agent: First City Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The policy wording does not define 'older people', so it is unclear as to exactly who this Policy is targeting or who would be eligible to occupy such dwellings.
It stipulates that all major development should provide bungalows, age restricted single storey accommodation such as flats and maisonettes, sheltered/retirement living and extra care housing with care and other supported living.
It is unclear if the policy is requiring ALL of the above-mentioned housing types on all sites or whether a site should include one or some of the housing types.
If it is the former, we consider this to be overly prescriptive of enforcing every major site to accommodate all housing types in addition to all other policy requirements such as those set out within policies HC 1,2,3,5 and 8 in addition to open space needs and biodiversity net gain requirements etc.
It is important to note not all sites should be treated in the same way and certain types of housing are better suited to particular sites based on their location, size and the surroundings and the level of older people and other special housing elsewhere within the settlement. Therefore a one size fits all approach is not appropriate and unsound.
There needs to be a level of flexibility applied on a site by site basis to ensure sites have a level of individuality and take into consideration the surrounding area.

Object

Representation ID: 6889

Received: 31/05/2024

Respondent: UKPI (Featherstone) Ltd

Agent: First City Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Consideration needs to be given to the implications of the self-building and custom housebuilding policy on sites in conjunction with other policies set out within the Local Plan.
Currently, there is little information available in connection to what will be included in the self-build register (number of sites required, size of property preferred, location etc for example) to know how it could potentially impact proposed sites.
Paragraph 7.20 states there are only 36 entries on the Council’s self-build and custom house build register. If there are multiple sites available in one area, it would be important to understand how the need would apportion over multiple sites and how the self-build register housing numbers apply to allocated sites in comparison to windfall sites not currently identified and planned for in the Local Plan. We consider it would be unfair for the self-build requirement to fall solely on the proposed allocations.
Whilst we generally supports the concept of self-build/custom housing, we do not consider providing them as part of a larger housing development is the most appropriate solution because self/custom builders are more likely to want a more bespoke location/setting. Smaller dedicated self/custom sites are therefore a more appropriate answer.
We support the position that should a proposed custom self-build plot not be sold after 12 months following active marketing, then the developer will be permitted to build out the plan as a standard property type.

Object

Representation ID: 6890

Received: 31/05/2024

Respondent: UKPI (Featherstone) Ltd

Agent: First City Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The introduction of a new set of requirements to ensure high quality design and the creation of beautiful places in line with Government guidance is supported. However, again we do not consider the policy should be overly prescriptive to the extent where it is restrictive and prevents each scheme having individual flair and taking into consider the local characteristics.

Comment

Representation ID: 6891

Received: 31/05/2024

Respondent: UKPI (Featherstone) Ltd

Agent: First City Limited

We support the inclusion of guidance in connection to the space about dwelling amounts and inclusion of the statement “Flexibility may be applied in relation to the above standard, depending upon the site orientation and the individual merits of the development proposal.” This should apply to both the distance between dwellings and the amount of external space as this can be significantly impacted by the layout of sites and the orientation of dwellings.

Comment

Representation ID: 6892

Received: 31/05/2024

Respondent: UKPI (Featherstone) Ltd

Agent: First City Limited

Whilst there is no in principle objection to the requirements of the policy or the provision of open space within developments, some clarifications are required in order to ensure that the Policy is sound.
The policy requirement for on-site equipped play provision as a default is not supported as it will not be appropriate for every site, for example where there is already high-quality equipped play provision in the locality it would not make sense to duplicate this provision.
Open space should be located in places on sites which are deemed suitable by the applicant as a result of taking into consideration differences in the sites opportunities and constraints.
Open space policy and the requirements of the site should work in accordance with other proposed policies and should take into consideration biodiversity net gain requirements.
All areas of incidental green space should be considered as part of the open space as it will contribute to biodiversity, climate change mitigation and improved landscaping which will contribute to a positive design and improved appearance of the overall scheme and therefore should not be disregarded.
It is requested that the Council amend the policy to allow a more flexible approach to achieve the right design solution for each site.