Publication Plan November 2022

Support

Representation ID: 5149

Received: 21/12/2022

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

We are largely supportive of policy HC1 housing mix as it states that on major development sites, the market housing mix ‘must’ include a minimum of 70% of properties with three bedrooms or less. We would prefer the wording of ‘must include’ to be amended to ‘should’ as such a target would place a disproportionate and inflexible burden on small and medium housebuilders who may be more inclined to provide bespoke homes with a higher specification for customers seeking
larger homes.

We therefore do not consider this policy is consistent with NPPF para 82.

Support

Representation ID: 5150

Received: 21/12/2022

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

We are broadly supportive of the proposed housing density of 35 dwellings per hectare but feel that this policy should give some reference to best and most effective use of the land, to ensure efficient housing delivery where it is needed.

Support

Representation ID: 5151

Received: 21/12/2022

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

Our client has made us aware that they are willing to support a proposal that is above 30%.

We consider that in relation to the proposed 25% shared ownership and 25% first homes tenures, there should be some flexibility given here as it allows affordable rent to be substituted against shared ownership. To not include or indicate this within the policy would, in our view make the policy inconsistent with NPPF para 82.

Object

Representation ID: 5152

Received: 21/12/2022

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to the wording of Policy HC4 where it states the following:

‘All major developments will also be required to ensure 100% of both the market and affordable
housing meets the higher access standards Part M4(2) Category 2’

To require all major developments to meet the higher access standards of Part M4(2) Category 2 would have significant financial viability implications. This policy also does not seem to account for the redevelopment of (for instance) listed buildings, as in many cases it will not be possible to meet the access standards of Part M4(2) Category 2 within the confines of a listed building without
resulting in a detrimental impact or due to spatial restrictions. We therefore consider that this policy should be reconsidered to take into account more constrained sites where this would not be possible, or where viability would indicate that flexibility should be applied.

If such flexibility is not written into this policy, we consider it would be inconsistent with NPPF para
82.

Support

Representation ID: 5153

Received: 21/12/2022

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

Whilst we are broadly supportive of this policy, we consider that smaller housing sites need to be better defined. Given that Rural Exception Sites are delivered on the basis of local need, this policy assumes that sites can only be small, which runs contrary to the NPPF which does not stipulate such sites should be small:

Paragraph 78 states that ‘In rural areas, planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs. Local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs, and consider whether allowing some market housing on these sites would help to facilitate this.’

We therefore do not consider that this is consistent with national policy.

Comment

Representation ID: 5154

Received: 21/12/2022

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

Policy HC8 talks about major developments but does not give a percentage requirement of selfbuild/custom-build plots. We consider that the policy is vague and would benefit from clarification, given how precise the council have been about the proportion of affordable housing, for instance.

In light of the fact that the council are under an obligation to maintain a custom and self-build register, it should be clear what the requirements are and how a policy could address this appropriately.

Object

Representation ID: 5155

Received: 21/12/2022

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

We have considered Policy HC10 and note that there is a lack of reference to character areas in major sites, so this should be given greater emphasis. We also consider that the policy needs to be supportive of flexible approaches planning applications (such as a hybrid outline) now that the Hillside Judgement has been released.

The Hillside Judgment reaffirms the ‘Pilkington principle’. This establishes that where a development has already been built in accordance with and under a first permission, the ability to lawfully implement a second permission on part of the same defined site is dependent on whether it is physically possible to carry out that second permission based on what has already been caried out in the first permission. This occurrence is sometimes referred to as a ‘drop-in permission’.

With regard to point J in Policy HC10. – ‘Gives safe and convenient ease of movement to all users prioritising pedestrians and cycle users’ This point should include the requirements for developments to be adequately lit to ensure the safety of pedestrians and cycle users.

In order to be considered consistent with para 82 of the NPPF, this policy requires greater flexibility

Support

Representation ID: 5156

Received: 21/12/2022

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

We are widely supportive of this policy but consider that outlook also needs to be covered to consider the impact of development proposals on neighbouring living conditions. Furthermore, there should be some consideration within the policy of to the potential for overheating, under part O of Building Regs.

Object

Representation ID: 5157

Received: 21/12/2022

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

We note that this policy mentions outlook and mentions a garden area ratio under ‘external space’.However, has this been tested against the proposed net densities of 35 dwellings per hectare?

We also feel that the suggested 21m distance between dwellings from principal elevations should be subject to further review because it could result in excessively wide streets which may affect developments achieving net density targets. Moreover, it would not accommodate the sorts of street hierarchies that would typically be advocated in larger developments with multiple character areas. Furthermore, such separation distances could result in wide carriageways appearing over dominant throughout schemes.

We consider the policy, as worded, would be contrary to para 130 of the NPPF which states that 'Planning policies and decisions should ensure that developments … (d) establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit;’

Support

Representation ID: 5158

Received: 21/12/2022

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

We are supportive of this policy, but what is the formula to calculate open space provision requirements and has this been considered by the viability study? We consider that this should be included as part of the policy.