Regulation 19 - Proposed Draft Local Plan Submission
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Regulation 19 - Proposed Draft Local Plan Submission
Policy DM06: Transport and Accessibility
Representation ID: 13687
Received: 06/05/2025
Respondent: Trustees of the Crane Estate and Mrs Jean Williams
Agent: Twenty5
The Crane Estate do not support DM06 as currently proposed. Further clarity is requested and it is considered that amendments to the wording of Part 1c and Parts 2c, 2d, 2e, and 2f. are required to ensure the policy is justified and sound.
Amend Part 1c to read: "c) ensuring that additional traffic movements do not cause an unacceptable impact to highway safety or result in the residual cumulative impact, following mitigation, on the road network being severe"
Amend Part 2c to read: c) deliver public transport and Demand Responsive Transport (DRT) enhancements where feasible to mitigate development impacts, including but not limited to bus routes, information and waiting facilities, community based services, and measures to encourage public transport use"
Delete Part 2 criteria d)
Amend Part 2e to read: "e) ensure car parking provision sufficient for the location and type of development, and make provision for Car Club spaces where suitable"
See attachment.
Support
Regulation 19 - Proposed Draft Local Plan Submission
Policy DM07: Managing Flood Risk
Representation ID: 13688
Received: 06/05/2025
Respondent: Trustees of the Crane Estate and Mrs Jean Williams
Agent: Twenty5
The Crane Estates note the need for a Sequential Test where necessary and have no further comments to raise at this moment in time.
See attachment.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy DM08: Sustainable Drainage
Representation ID: 13689
Received: 06/05/2025
Respondent: Trustees of the Crane Estate and Mrs Jean Williams
Agent: Twenty5
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Not supported, and has not been positively prepared, is not justified or based on sound evidence, as per paragraph 36 of the NPPF.
Part 1 and 2a, approach is vague and fails to provide further details in relation to rainwater storage.
Part 3f wording needs to be more specific in terms of return periods for the 20% reduction in run-off, and how the rate should be applied and what should be achieved. Also practical implications associated with 20% runoff rate.
It is unclear whether brownfield sites would need to revert to greenfield and if a further 20% would then need to be applied, which would be seemingly onerous.
We request that the policy is reviewed, with elements on rainwater storage and 20% runoff rates being specified further.
See attachment.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy DM09: Sustainable Construction and Climate Resilience
Representation ID: 13690
Received: 06/05/2025
Respondent: Trustees of the Crane Estate and Mrs Jean Williams
Agent: Twenty5
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
DM09 wording includes no flexibility and fails to have regard to viability and individual development proposals. It is not considered reasonable to restrict the delivery of residential development when the BRE Home Quality Mark certification is a voluntary certification and exceeds Building Regulations. The Councils approach is onerous and not supported by evidence.
Amend DM09 Part 1 from "must" to "should aim to"
Delete DM09 Part 2
See attachment.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy DM10: Biodiversity and Geodiversity Protection and Enhancement
Representation ID: 13691
Received: 06/05/2025
Respondent: Trustees of the Crane Estate and Mrs Jean Williams
Agent: Twenty5
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The Crane Estate support the principle of the policy and securing a mandatory requirement of 10% BNG. However, ss currently worded does not provide any flexibility and sets an absolute requirement. Request 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.
DM10 Part 1 delete "at least"
DM10 part 4 amend "must" to "should aim for"
See attachment.
Support
Regulation 19 - Proposed Draft Local Plan Submission
Policy DM12: Protection and Enhancement of Community Facilities
Representation ID: 13692
Received: 06/05/2025
Respondent: Trustees of the Crane Estate and Mrs Jean Williams
Agent: Twenty5
The Crane Estate broadly support the wording of the policy and the support to proposals that enhance the quality of existing community and education facilities.
See attachment.
Support
Regulation 19 - Proposed Draft Local Plan Submission
1.4
Representation ID: 13694
Received: 06/05/2025
Respondent: Trustees of the Crane Estate and Mrs Jean Williams
Agent: Twenty5
Policies map: Land South of Dunton Road, Broughton Astley is not subject to any formal designations. The Crane Estate consider it necessary for the Council to allocate additional sites within the District for housing, with the Site representing an unconstrained and deliverable option in a sustainable location. We ask this Site is considered to meet the District’s and Broughton Astley’s housing needs.
See attachment.
