Regulation 19 - Proposed Draft Local Plan Submission

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Object

Regulation 19 - Proposed Draft Local Plan Submission

Policy DS01 Development Strategy: Delivering Homes

Representation ID: 14180

Received: 02/05/2025

Respondent: IM Land

Agent: Stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

• The Council have not planned for sufficient levels of housing supply or growth in the Plan period. The Council need to plan for 1,176 dwellings per annum to account for evidenced local housing needs, affordable housing needs, and the unmet needs of Leicester and Leicestershire, rather than the proposed 657 dwellings per year between 2020 to 2036 and 534 dwellings per year between 2036 to 2041
• Increase the capacity of Site BA1 from 475 dwellings to 550 dwellings, given the Site is evidenced to be the most suitable and sustainable location for development in Broughton Astley. This would also contribute an additional 75 dwellings towards the evidenced needs for 1,176 dwellings

Attachments:

Support

Regulation 19 - Proposed Draft Local Plan Submission

Policy HN01 Housing Need: Affordable Homes

Representation ID: 14181

Received: 02/05/2025

Respondent: IM Land

Agent: Stantec

Representation Summary:

The provision of 40% affordable housing onsite is supported. In terms of the tenure split, the provision of 75% affordable / social rented and 25% affordable is broadly supported, although this needs to be expressed with flexibility to allow for change over time.

Attachments:

Object

Regulation 19 - Proposed Draft Local Plan Submission

Policy HN02 Housing Need: Mix of New Homes

Representation ID: 14182

Received: 02/05/2025

Respondent: IM Land

Agent: Stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Whilst IM Land acknowledge the need to provide a range of housing mixes and tenures, it is considered that the policy as drafted provides no scope or flexibility and fails to have regard to viability / deliverability factors. The requirement for all homes to meet M4(2) standards and provide 5% of market homes and 10% of affordable homes as M4(3)A and M4(3)B standards will be challenging from a deliverability and viability perspective, especially when considering the expenses associated with delivering M4(3)B and M4(3)A dwellings. Whilst IM Land welcome the inclusion of a Viability Assessment as part of the supporting evidence base for the draft Local Plan, concerns are raised regarding the need for policies to go further beyond matters in relation to Building Regulations and the impact this may have on the Local Plan’s ability to deliver both market and affordable housing where it is most needed.

Attachments:

Object

Regulation 19 - Proposed Draft Local Plan Submission

Policy HN03 Housing Need: Housing Type and Density

Representation ID: 14183

Received: 02/05/2025

Respondent: IM Land

Agent: Stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

IM Land wish to emphasise that the densities included within the policy should be viewed as a minimum. IM Land therefore do not support policy HN03 as currently drafted on the basis that it fails to accord with the tests set out at paragraph 36d of the NPPF and the need to use land efficiently. IM Land consider that the proposed minimum density for policy HN03 should be increased to 35dph

Attachments:

Object

Regulation 19 - Proposed Draft Local Plan Submission

Policy HN04 Housing Need: Supported and Specialist Housing

Representation ID: 14184

Received: 02/05/2025

Respondent: IM Land

Agent: Stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Whilst we acknowledge that the evidence prepared fails to justify the need for 10% specialist housing onsite and also doesn’t make reference to the need for 5% specialist housing, IM Land consider that a quantum of 5% is more reasonable and will be better accommodated within development sites. A quantum of 5% is also considered suitable given the evidence confirms that there is no standard methodology for assessing the housing care needs of older people.

Attachments:

Object

Regulation 19 - Proposed Draft Local Plan Submission

Policy HN05 Housing Need: Self and Custom Build Housing

Representation ID: 14185

Received: 02/05/2025

Respondent: IM Land

Agent: Stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Despite the cascade mechanism should there be no interest, ‘at least 10%’ self and custom build plots as currently drafted is not supported. The requirement for 10% is considered excessive. The availability of plots would significantly exceed demand, a concern shared by the Council hence a cascade mechanism is suggested.

The cascade mechanism is not supported due to the build out implications and phased approach of the development. This approach is not practicable or suitable. It is also considered that the period of 18 months is excessive and a period of 12 months is more suitable.

Part 6 re: plot passport/design code, is considered excessive and will potentially delay self/custom houses coming forward. No details on who would be responsible for preparing the design code and what the process for this would entail. Requirement should be removed.

Attachments:

Object

Regulation 19 - Proposed Draft Local Plan Submission

BA1

Representation ID: 14186

Received: 02/05/2025

Respondent: IM Land

Agent: Stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Whilst IM Land broadly support in principle the draft allocation of BA1 in the Draft Local Plan, they do not consider it is justified or based on sound evidence. IM Land therefore wish to see the allocation increased to 550 dwellings and wish to comment further on draft allocation BA1 through the Draft Local Plan process.

Attachments:

Object

Regulation 19 - Proposed Draft Local Plan Submission

Policy DM08: Sustainable Drainage

Representation ID: 14187

Received: 02/05/2025

Respondent: IM Land

Agent: Stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Part 1 approach is considered vague, failing to provide further details in relation rainwater storage. Rainwater storage could relate to either water butts or the provision of rainwater harvesting tanks. If the latter, regard will then need to be had to storage calculations and there being the possibility of an over provision of storage requirements. These comments also relate to part 2a of the policy.

Part 3f as currently drafted, it is unclear as to what return periods are being referenced to in respect of the 20% reduction in run-off rates. The wording of the policy needs to be more specific in this regard and advise how the 20% rate should be applied and what should be achieved. Crucial given the potential implications on storage requirements. Also need to be clearer re: brownfield sites. There are also practical implications associated with the 20% runoff rate, noting that discharge rates cannot be reduced to below 2 I/s due to blockage issues with the flow control devices.

Attachments:

Object

Regulation 19 - Proposed Draft Local Plan Submission

Policy DM09: Sustainable Construction and Climate Resilience

Representation ID: 14188

Received: 02/05/2025

Respondent: IM Land

Agent: Stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

When reviewing policy DM09 it is considered that the wording includes no flexibility and fails to have regard to viability and individual development proposals. As such, IM Land do not support the policy as currently drafted.

Further to the above, policy DM09 requires all new-build residential developments to achieve at least a three star rating under the BRE Home Quality Mark scheme. This is not supported. The BRE Home Quality Mark scheme is a voluntary certification scheme for new developments. To achieve the Home Quality Mark certification, new dwellings must exceed the requirements of established standards set out in Building Regulations. If a site is already meeting the requirements of Building Regulations, then there is no requirement in national policy for a site to go above and beyond this.

Attachments:

Object

Regulation 19 - Proposed Draft Local Plan Submission

Policy DM10: Biodiversity and Geodiversity Protection and Enhancement

Representation ID: 14189

Received: 02/05/2025

Respondent: IM Land

Agent: Stantec

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

• Whilst IM Land support the principle of the policy and securing a mandatory requirement of 10% BNG, it is considered that the policy as currently worded does not provide any flexibility and sets an absolute requirement. For example, part c) of the policy requires developments to protect and enhance green and blue infrastructure assets. It is unlikely that the majority of developments will be able to fully comply with this requirement. Many development sites require the removal of some trees or hedgerows to facilitate development due to constraints such as access or levels. As such, it is requested that flexibility is built into the policy to allow developments to be delivered even when they cannot meet all of the requirements set out in draft policy DM10.

Attachments:

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