Publication Plan November 2022

Comment

Representation ID: 4613

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Four Ashes Road Ltd notes Policy DS6, which recognises the Council’s aspiration to explore the potential for a sustainable, independent new settlement.
Policy DS6 recognises that such an option would not contribute to housing growth during the proposed plan period to 2039 which is agreed. A new settlement proposal, even if a suitable and viable option were to be identified, would take a long time to masterplan and facilitate and would need to be delivered alongside infrastructure on a scale much larger than a usual
development.

Comment

Representation ID: 4614

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Four Ashes Road Ltd notes the identification of four strategic housing allocations and the included housing trajectory at Appendix H of the Publication Plan. It is considered a more detailed housing trajectory should be
included to ensure the reliance on these strategic sites does not undermine the timely delivery of housing against a non-stepped trajectory, recognising the assumed reduction in completions to 2026.

Comment

Representation ID: 4615

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Four Ashes Road Ltd notes the identification of four strategic housing allocations and the included housing trajectory at Appendix H of the Publication Plan. It is considered a more detailed housing trajectory should be
included to ensure the reliance on these strategic sites does not undermine the timely delivery of housing against a non-stepped trajectory, recognising the
assumed reduction in completions to 2026.

Comment

Representation ID: 4616

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Four Ashes Road Ltd notes the identification of four strategic housing allocations and the included housing trajectory at Appendix H of the Publication Plan. It is considered a more detailed housing trajectory should be
included to ensure the reliance on these strategic sites does not undermine the timely delivery of housing against a non-stepped trajectory, recognising the
assumed reduction in completions to 2026.

Comment

Representation ID: 4617

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Four Ashes Road Ltd notes the identification of four strategic housing allocations and the included housing trajectory at Appendix H of the Publication Plan. It is considered a more detailed housing trajectory should be
included to ensure the reliance on these strategic sites does not undermine the timely delivery of housing against a non-stepped trajectory, recognising the
assumed reduction in completions to 2026.

Comment

Representation ID: 4618

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

The efficient use of land, in accordance with National Planning Policy and Guidance, is supported. The flexibility provided by Policy HC2 to allow sites to be considered on a site-by-site basis, having regard to the prevailing local character, context and other planning policy requirements or opportunities for supporting infrastructure, is welcomed.
Nevertheless, due to the size of the site at Four Ashes Road and the lack of identified constraints that are unmitigable, it is realistic to expect the delivery
of an efficient scheme that could achieve a minimum average net density of 35dph. However, this would be achieved through the provision of areas of varying density and reflective of the character of surrounding development.

Comment

Representation ID: 4619

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Four Ashes Road Ltd notes that for all major developments 30% of all homes are to be delivered as affordable housing. This appears to be broadly supported by the 2021 Stage 1 Viability Study which determined the current affordable housing requirement of 40% affordable provision is very unlikely to prove supportable on larger schemes with significant infrastructure costs.
Viability is dynamic and the Council’s evidence relates to a snapshot in time.
Therefore, the mechanism within Policy HC3 is supported, which allows for the submission of a viability assessment at the application stage if it can be
demonstrated that circumstances have changed. Such circumstances should include increasing infrastructure costs or changes to house prices or build costs.

Comment

Representation ID: 4620

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

The 2022 SHMA identifies 30 applicants on the self-build register as of Spring 2022, recognising that 10 of these applicants are also on a register within another LPA. This demonstrates a very low level of demand.
Policy HC8 provides a justified and proportionate approach to meeting this specific need, which requires the consideration of the Council’s Self Build
Register on major developments but falls short of requiring a specific percentage of provision.

Comment

Representation ID: 4621

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

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.
It should be noted that Four Ashes Road Ltd is intending to enter into preapplication discussions to inform the emerging proposal for land at Four Ashes Road.

Comment

Representation ID: 4622

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

In respect of EVCPs, The Department of Transport Consultation Response:
Electric Vehicle Charging Points (EVCP) in Residential & Non-Residential Buildings dated November 2021 sets out that from 15th June 2022 new dwellings
with associated parking within the boundary of the dwelling) will have at least 1 EVCP per dwelling. Therefore, it is no longer necessary for the Council to have a proposed policy requirement for EVCPs.
It is noted that the Council’s Viability Assessment includes a cost of only £500 per EVCP. This cost is below the Government’s cost estimate and excludes any
costs for upgrading local networks. The Department for Transport - Electric Vehicle Charging in Residential & Non-Residential Buildings consultation estimated a cost of £974 per EVCP plus an automatic levy for upgrading
networks capped at £3,600. This is not reflected in the Stage 2 Viability Study.