Publication Plan November 2022

Object

Representation ID: 5178

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The provision of tree lined streets should be subject to highway authority agreement.

Delete reference to house types and tenures as this is repetition of material in policy HC1.

Object

Representation ID: 5179

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Certain house types, for example M4(2) dwellings should have smaller, more manageable gardens.

Introduce some flexibility into application of Nationally Described Space Standards (NDSS) as occasional non-compliance may be appropriate for sound urban design reasons.

Should Nationally Described Space Standards be pursued then the Council need to provide additional evidence to demonstrate the policy is sound. Taking account of the following issues:
-evidence should ensure that impacts of adopting space standards can be properly assessed e.g. impact on meeting demand for starter homes.
-viability impacts including on affordability
-timing of implementation to enable developers time to factor cost of standards into future land acquisitions.

The HMA does not provide any justification or evidence for requiring NDSS in the District.

Object

Representation ID: 5180

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

What level of impact is deemed unacceptable?
Policy should acknowledge that not all residents of a development will be new to a catchment area, some residents may already be registered locally and therefore will not create an additional burden. Careful analysis is required with regard to the capacity of existing infrastructure to accommodate new patients before any conclusions are reached.

Object

Representation ID: 5181

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy as currently written makes a blanket assumption that new education infrastructure will be required from all new development. Policy should recognise that new infrastructure will only be required where it can be demonstrated that existing capacity to accommodate growth does not currently exist.

Object

Representation ID: 5182

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Adopt a more flexible approach. High quality equipped play provision may not be required where such provision already exists in the locality. It is not appropriate to require open space on all sites to be centrally located, this does not take account of specific site characteristics/constraints.

Green Infrastructure provision should be based on quality rather than quantity. The exclusion of small incidental Green Infrastructure such as landscape buffers is not supported. Policy should be revisited and clarified with reference to national guidance to ensure that open space and green infrastructure is properly and clearly defined and to recognise the contribution which a range of spaces will bring to a development.

Object

Representation ID: 5183

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy should define standards expected from development as per the open space standard in policy HC17. This will provide greater certainty in respect of infrastructure delivery requirements. Must take account of delivery of all potential site obligations when determining levels of requirement.

Object

Representation ID: 5184

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Adopt a more flexible approach, particularly in light of increasing significance of modular methods of construction. Employment and skills plans should be requested on a site by site basis where appropriate. Relevant criteria should be identified within the policy to support the request for E&S plans.

Object

Representation ID: 5185

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Assessment of cumulative impact and mitigation must be proportionate.

Object

Representation ID: 5186

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Adopt a more flexible approach. Promote a pragmatic view in relation to biodiversity enhancements where there are clear landscape and habitat improvements rather than being wholly reliant on the output of a rigid calculator.
Reword part a) replacing ‘priority’ with ‘where possible’. It is questionable where sites are allocated for development that a goal of maintaining habitats is achievable.

Object

Representation ID: 5187

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Amend 2nd paragraph to read ‘All trees and hedgerows should be protected and retained wherever possible.’