Publication Plan April 2024

Support

Representation ID: 6694

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

RH welcome the objective of achieving a minimum net density of 35 dwellings per hectare on sites adjoining Tier 1 settlements and infill locations within built up areas of Tier 1 to 3 settlements across the District.
RH note the wording of the policy that seeks to encourage, rather than impose, strict adherence to the density requirements set out. RH supports this flexible approach to consideration of density noting that there may be instances where the character and site specific circumstances of a proposed development site dictate that there should be divergence away from the minimum density set out above. We consider this policy sound.

Comment

Representation ID: 6695

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

RH do not object to the requirement to provide 30% affordable housing within new development. Furthermore, the proposed breakdown of tenure to 25% first homes, 50% social rent and 25% shared ownership provide a useful starting point for considering affordable housing tenures within new development however, we consider the policy should include the ability to negotiate or diverge away from the proportions set out above. This is in order to respond to site specific or location specific requirements thus enabling an appropriate range of affordable units to be provided within new developments that best meet the needs of those that they are intended to meet. As it sounds, the policy is not effective and not therefore sound.

We would wish to see a sentence added that reflected the ability to negotiate the specific tenure on a site by site basis using the specified tenure mix as a starting point.

Comment

Representation ID: 6696

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

In principle RH do not object to the policy noting that housing delivery across the District should accommodate the housing need that has been identified. The housing market is not uniform across the whole District and there will be certain parts of the District that would be more appropriate to accommodate specific types and tenures of housing. It would not, therefore, be practical to seek to achieve a district wide housing mix on smaller sites for example where there may be other site-specific constraints that make this unfeasible. Notwithstanding this point there would be opportunities on larger sites such as the land that is proposed at Castlecroft Farm to deliver a wider mix of size of dwellings and tenures including affordable housing.

Object

Representation ID: 6697

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

RH, however, object to the requirement in the policy that at least 70% of all dwellings on major development housing sites should include a minimum of 70% of properties with 3 bedrooms or less. RH consider that the objective should be to deliver the requisite housing mix to meet the housing needs across the District rather than to specify the percentage of dwellings on individual sites and specifically seeking to restrict the provision of larger 4 bedroom properties for new development.

The policy goes on to state that all development that fails to make efficient use of land by providing a disproportionate amount of large 4 bed homes compared with local housing need would be refused. The reference to disproportionate is unclear and provides no certainty as to how the policy would be applied and how specifically developers would need to respond to it.

Comment

Representation ID: 6698

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

RH do not object in principle to the requirement to meet specific needs of older people and other groups with specialist requirements. In the case of RH this would typically involve the delivery of bungalows or other age restricted single storey accommodation such as flats and maisonettes.

The policy is not explicit in terms of what proportion of the total of these forms of housing should be provided and the policy could be clearer in terms of setting out what would be required when bringing development proposals forward. The delivery of bungalows is land hungry and could undermine the objective of achieving the 35dph requirement set out in policy HC2. The requirement to require developers to provide specialist accommodation should be softened to state that the Council should seek to negotiate. As such, we consider it unsound as it is not effective.

The policy should be reworded to state that the Council will seek to negotiate with developers to meet the needs of specific groups rather than requiring them to do so. (Proposed re-wording of policy can be found in full representation).

Comment

Representation ID: 6699

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

RH are unclear as to the evidence of the need for self-build plots and do not consider that this has been adequately demonstrated. The self-build list is not readily accessible on the Council’s website so we cannot see what the current level of demand is for self-build plots. Evidence of the need for self-build plots needs to be demonstrated in order to justify the requirement to provide them within new major development.

Comment

Representation ID: 6700

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

Any self-build plots may then require a design code to be agreed with the applicant and implemented by the developer of the plots. The agreement of a design code in our view would undermine the attractiveness of self-build plots if a prospective purchaser had to abide by a design code that they had no input into preparing.

Support

Representation ID: 6701

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

RH welcome the requirement to actively market self-build plots and that if these are not taken up, they can revert back to standard market dwellings to be developed by the developer. RH consider that a period of between 6 to 12 months of marketing would be appropriate. Furthermore, RH contend that the marketing of the plots should run concurrently with the start of the development. This is on the basis that if the plots are not taken up they can revert back to the developer and be completed as part of the wider development. If this were not the case the likelihood is that the plots would go undeveloped and would reduce the supply of housing as a result.

To address our concerns, we would wish to seek the deletion of the requirement for the design code to be removed from the policy. Furthermore, we seek the period of marketing to run for a period of 6 – 12 months and for the policy to clarify that this will commence at the same time as the commencement of the development.

Object

Representation ID: 6702

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

RH wish to object to the requirement that all new residential developments must meet or exceed the Government’s technical housing standards. (Text taken from the NPPF and PPG in full representation).

In light of the policy and guidance in the Framework and PPG it is not clear that the evidence of need for NDSS has been provided and, therefore, we do not consider there is sufficient justification for inclusion of the NDSS requirement within the policy. As such, we consider that the policy is unsound as the evidential requirements set out in policy and guidance has not been met. The policy is not justified.

RH therefore seek the removal of the requirement to provide NDSS from the policy until such time as the evidence required justify its inclusion has been presented.

Support

Representation ID: 6703

Received: 31/05/2024

Respondent: Redrow Homes

Agent: Harris Lamb

In respect of external space, the policy is helpful in setting out the external space requirements to be accommodated within new development. Furthermore, confirmation that the standards can be applied flexibly due to site orientation and other site constraints is also welcomed.