Regulation 19 - Proposed Draft Local Plan Submission

Object

Representation ID: 13793

Received: 04/05/2025

Respondent: Davidsons Development Ltd

Agent: Marrons

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Prudent for the HLP housing requirement to build in; a contingency to address Leicester's unmet needs beyond 2036 and potential wider shortfalls within the HMA, an uplift to address the acute need for affordable housing and a higher supply-side buffer (closer to 20%).
There is a clear and compelling case to test a higher housing requirements and its suggested the overall quantity of growth should be subject to further testing through the SA process.
Spatial distribution to Large Villages and to Great Glen is generally supported as being reflective of the settlement hierarchy and addressing needs close to where they arise. Allocating suitable sites in large villages would provide flexibility and contingency amongst the most sustainable locations, rather than at the lower end of the settlement hierarchy.

Object

Representation ID: 13814

Received: 04/05/2025

Respondent: Davidsons Development Ltd

Agent: Marrons

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

DS05 1d) We do not consider it practical or necessary to consider cumulative and cross boundary impacts between OA1 and GG1, because they will likely not be constructed in the same time period.
DS05 3. Not clear what this intends to achieve. Its requirements should be rephrased to address specific site-by-site requirements and phasing, for upfront clarity.
DS04c) Not justified, as its a statutory requirement.
DS05 4 d) The bulleted list is insufficiently focused and its not sufficiently clear that contributions should only be proportionate to address the impacts of the specific development.

Object

Representation ID: 13828

Received: 04/05/2025

Respondent: Davidsons Development Ltd

Agent: Marrons

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Generally support the allocation of GG1, and the need for an Area of Separation between GG1 and OA1.
The following issues are raised about GG1 policy requirements 1,2, 3 and 9; there is no need for a discrete comprehensive masterplan, the text of SA01 should recognise that development greater than 3 storeys is unlikely, it is impractical / unnecessary to consider the transport impacts of GG1 and OA1 cumulatively, and the distance from waste safeguarding sites makes material impacts implausible.
An Agricultural Land Report, confirming the site is entirely sub-grade 3b, is provided to supplement HDC's Stage 4 Technical Site Assessment.

Object

Representation ID: 13839

Received: 04/05/2025

Respondent: Davidsons Development Ltd

Agent: Marrons

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Observations are made about the following assumptions made in the Viability Report; allowance for on-site infrastructure is too high, allowance for professional fees for strategic sites is not clear, the use of lower quartile BCIS costs and that economies of scale cannot be universally assumed across an entire site.
It is also not clear how the cumulative policy burdens of the HLP have been factored into the viability appraisal.

Object

Representation ID: 13840

Received: 04/05/2025

Respondent: Davidsons Development Ltd

Agent: Marrons

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The evidence on need is based principally on the District's ageing population, a national trend. The Written Ministerial Statement and PGG allows adoption of enhanced technical standards on an authority by authority basis based on local evidence including; accessibility and adaptability of the existing housing stock.
Policy is not currently justified by local evidence including how the threshold of 100 units and the percentage requirement relates to the overall scale of needs.
This policy is not currently justified by evidence and needs to be revisited prior to submission of the Local Plan.

Object

Representation ID: 13841

Received: 04/05/2025

Respondent: Davidsons Development Ltd

Agent: Marrons

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

A number of observations are made about; the appropriateness of a blanket percentage across all schemes of a certain size, its failure to contemplate a scenario of lack of demand, and its lack of provision for accomodation to be delivered as market units if an evidenced lack of demand.
The viability impact of the policy does not appear to have been assessed cumulatively with other policy burdens.

Object

Representation ID: 13842

Received: 04/05/2025

Respondent: Davidsons Development Ltd

Agent: Marrons

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Integrating self and custom-build plots within large-scale housing developments is challenging because it; is difficult to co-ordinate construction, poses health and safety risks, comes forward over much longer timeframes and is often not liable to Section 106 contributions towards infrastructure.
Self build should be encouraged using council-owned land or designating specific sites via negotiations with landowners.
Supportive of a mechanism to allow unsold plots to be built out as market housing, however 18 months is overly restrictive. Six months is adequate, with no requirement for plots to be available immediately to validly commence the marketing period.

Object

Representation ID: 13843

Received: 04/05/2025

Respondent: Davidsons Development Ltd

Agent: Marrons

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Generally supportive of a policy requirement to safeguard residential amenity. Development should be opposed on amenity grounds only where it causes material or significant harm to users of nearby land and buildings—not based on subjective thresholds of “acceptability.”

Support

Representation ID: 13844

Received: 04/05/2025

Respondent: Davidsons Development Ltd

Agent: Marrons

Whilst generally supportive of a policy requirement to address landscape character and sensitivity, Part 1 d) of the policy refers to restoring and providing equivalent mitigation for damaged features and/or landscapes that would be damaged or degraded as a result of development. It is not clear what this element of the policy requires. It is clearly not practical, viable or developable to expect new development to restore or compensate for the loss of landscapes themselves as all new development will, by its nature, have a landscape impact.
Landscape features lost can be provided for where practicable.